Privacy Policy – Game 789 Pakistan Online Gaming Platform

1Who We Are

Game 789 is an online gaming and sports betting platform operating at game789.im, serving players in Pakistan across a range of game categories including cricket betting, PSL, esports betting, Ludo games, card games, crash games and virtual sports. All transactions on Game 789 are conducted in Pakistani Rupees (PKR) using local payment methods including Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT and Visa/Mastercard.

For the purposes of this Privacy Policy, Game 789 is the data controller — meaning we determine the purposes for which your personal data is collected and the manner in which it is processed. We are committed to handling your data responsibly, transparently and in compliance with applicable data protection principles.

This Privacy Policy applies to all personal data collected through the Game 789 website, any mobile-optimised version of the platform and all related communications including email, Live Chat and support interactions. It should be read alongside our Terms and Conditions and our Responsible Gaming policy, both of which form part of the overall agreement between you and Game 789.

2Personal Data We Collect

Game 789 collects personal data in several categories depending on how you interact with the platform. The table below summarises the main categories of data we collect and why.

We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, health data or biometric identifiers unless strictly required for legal compliance, in which case we will inform you separately and obtain explicit consent before collecting such information.

3How We Collect Your Data

Game 789 collects your personal data through the following channels:

• Direct collection: Information you provide when registering an account, completing a deposit or withdrawal, contacting our support team, participating in a promotion or updating your account profile.
• Automated collection: Technical data (IP address, device information, session data) collected automatically when you access and use the Game 789 platform, using standard web server logs, cookies and similar tracking technologies.
• Payment processors: Confirmation data received from Easypaisa, JazzCash, NayaPay, SadaPay, your bank (for IBFT) or card payment processors confirming transaction status. We receive only the information needed to reconcile your account — we do not receive or store your full card number or bank account PIN.
• Third-party identity verification: Where we are required to verify your identity for compliance purposes, we may use a third-party verification service that cross-references your provided information against publicly available records. The third party involved will be named in the verification request.
• Marketing opt-in: If you opt in to receive promotional communications from Game 789, additional preference data is collected to tailor the communications you receive.

4How We Use Your Personal Data

Game 789 uses your personal data only for legitimate, defined purposes. We do not use your data in ways you would not reasonably expect based on your relationship with the platform. The primary purposes for which we use your personal data are:

• Account management: Creating and maintaining your Game 789 account, authenticating your identity at login, processing your deposits and withdrawals in PKR and managing your betting and game history.
• Service delivery: Enabling you to access and use all Game 789 features including cricket betting, PSL live in-play markets, esports betting, Ludo games, card games, crash games and virtual sports.
• Payment processing: Initiating and confirming deposits via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT or card, and processing withdrawal requests to your registered payment method.
• Security and fraud prevention: Monitoring account activity for suspicious patterns, detecting and preventing unauthorised access, multi-accounting, bonus abuse and other fraudulent behaviour that could harm the integrity of the platform or other players.
• Responsible gaming: Monitoring player behaviour for indicators that may suggest problematic gaming patterns, and proactively reaching out to offer support tools. This is not surveillance — it is a commitment to player welfare that is central to how Game 789 operates.
• Legal and regulatory compliance: Retaining and producing records as required by applicable laws, responding to law enforcement requests where legally obligated and maintaining audit trails for financial transactions.
• Customer support: Resolving your queries, complaints and disputes using your account history and communication records.
• Platform improvement: Analysing aggregated, anonymised usage data to understand how players interact with the platform and make improvements to the user experience.
• Marketing communications: Sending you promotional offers, bonus notifications and platform updates — but only if you have opted in to receive them. You can withdraw this consent at any time.

5Legal Basis for Processing

Game 789 processes your personal data on one or more of the following legal bases, depending on the specific purpose:

• Contract performance: Processing is necessary to deliver the services you signed up for — including account operation, deposits, withdrawals and game access.
• Legal obligation: Processing is required to comply with applicable laws — including anti-money laundering (AML) obligations, financial record-keeping requirements and responses to lawful authority requests.
• Legitimate interests: Game 789 has a legitimate interest in keeping the platform secure, preventing fraud, improving the service and monitoring for responsible gaming concerns — provided these interests do not override your rights and freedoms.
• Consent: For optional processing activities — such as sending you marketing communications or using non-essential cookies — we process your data only with your explicit, freely given consent. You may withdraw consent at any time with no impact on your use of the core Game 789 service.

6Sharing Your Personal Data

Game 789 does not sell your personal data to any third party. We do not share your information with advertisers, data brokers or any commercial third party for their own purposes. Your data is shared only in the following limited and necessary circumstances:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT networks and card payment processors receive only the transaction data necessary to process your deposit or withdrawal in PKR. These processors are contractually bound to use your data solely for this purpose.
• Identity verification partners: Where required for KYC compliance, a trusted third-party identity verification service may receive your provided identity information to confirm its accuracy. We use reputable, audited verification providers.
• Legal authorities: Game 789 will disclose your personal data to law enforcement agencies, regulatory bodies or courts where we are legally required to do so — for example, in response to a valid court order, a regulatory investigation or an AML disclosure obligation.
• Platform security and fraud prevention providers: Technical security partners who assist Game 789 in detecting fraud, preventing multi-accounting and maintaining platform integrity. These partners process data only under our instruction and are contractually prohibited from using it for any other purpose.
• Business transfers: In the event that Game 789 is acquired, merged or undergoes a change of control, your personal data may be transferred to the acquiring party as part of that transaction. You would be notified in advance and the receiving party would be bound by obligations at least as protective as this Policy.

7Cookies and Tracking Technologies

Game 789 uses cookies and similar tracking technologies to operate the platform, maintain your session and understand how the platform is being used. A cookie is a small data file stored in your browser when you visit a website. We use the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function — including maintaining your login session, remembering your account preferences and processing transactions. These cannot be disabled without breaking the platform.
• Performance and analytics cookies: Help us understand which parts of the platform are most used, where players encounter difficulties and how we can improve the experience. Data is collected in aggregated, anonymised form and is not used to identify individual players.
• Functionality cookies: Remember your stated preferences — such as your language setting and responsible gaming limits — so you do not have to reset them on every visit.
• Marketing cookies: Used only if you have opted in to receive personalised Game 789 promotional communications. These help us send you offers relevant to the games and tournaments you actually use rather than generic bulk promotions.

You can manage your cookie preferences through your browser settings at any time. Disabling non-essential cookies will not prevent you from accessing Game 789 — only the personalisation and analytics features dependent on those cookies will be affected.

8Data Security

Game 789 implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration or disclosure. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and our servers — the same encryption standard used by Pakistani banks and financial institutions.
• Encrypted data storage — sensitive personal and financial data stored on Game 789 servers is encrypted at rest using industry-standard encryption algorithms.
• No card credential storage — Game 789 never stores your full card number, CVV or bank PIN. Payment credentials are processed directly by our PCI-DSS compliant payment partners and never pass through Game 789 servers in full.
• Access controls — Game 789 employee access to personal data is restricted on a strict need-to-know basis. All internal access is logged and audited.
• Regular security testing — our platform undergoes regular penetration testing and vulnerability assessments by independent third-party security firms.
• Two-factor authentication (2FA) — available as an optional security enhancement for all player accounts. We strongly encourage all Game 789 players to enable 2FA in their account settings.

9Data Retention

Game 789 retains your personal data only for as long as is necessary for the purposes described in this Policy and to comply with our legal obligations. The following retention principles apply:

• Active accounts: Personal data associated with active Game 789 accounts is retained for the duration of the account's active status and is kept accessible for account management and support purposes.
• Financial transaction records: Records of deposits, withdrawals and betting activity are retained for a minimum of 5 years following the date of the transaction, as required by anti-money laundering and financial record-keeping regulations.
• Closed accounts: When you close your Game 789 account, certain identity and transaction records are retained for the regulatory minimum period. Other data that is no longer necessary is deleted or anonymised within 90 days of account closure.
• Support communications: Live Chat transcripts and support email records are retained for 2 years from the date of the interaction for quality assurance and dispute resolution purposes.
• Marketing data: If you have opted in to marketing communications and subsequently withdraw your consent, your marketing preferences are updated immediately and you are removed from all active marketing lists within 48 hours. The record of your consent withdrawal is retained for compliance purposes.

10Your Data Rights

As a Game 789 player, you have the following rights with respect to your personal data. To exercise any of these rights, contact us at support@game789.im. We will acknowledge your request within 2 business days and respond fully within 5 business days.