up789 Privacy Policy

1. Who We Are

up789 (referred to in this document as "up789", "we", "our", or "us") operates the online gaming platform accessible at up789.pro. up789 is the data controller responsible for the personal information collected from players and visitors in connection with the platform's services.

up789 serves the Pakistan market primarily, offering sports betting including PSL cricket and international cricket fixtures, live dealer casino games, Aviator and Bird Catcher crash games, and a library of over 500 certified slot titles. All services are delivered exclusively to adults aged 21 years and above.

For any queries relating to this Privacy Policy or the handling of your personal data, you may contact our Data Protection contact at [email protected]. Our support team operates 24 hours a day, 7 days a week, including public holidays in Pakistan.

2. Data We Collect

up789 collects personal data that is necessary to provide its services, meet its legal obligations, and maintain a safe gaming environment. The categories of personal data we may collect include:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (for mandatory age verification — you must be 21 or older)
• National Identity Card (CNIC) number or passport number
• Residential address (city, province, Pakistan)
• Email address
• Mobile phone number

2.2 Financial Data

• JazzCash account details (account number / registered mobile number)
• EasyPaisa account details
• Raast ID or bank account details where used for deposit or withdrawal
• HBL, UBL, or Meezan Bank account references where applicable
• Transaction history including deposits, withdrawals, and bonus activity

2.3 Technical and Usage Data

• IP address and approximate geolocation data
• Device type, operating system, and browser information
• Session data including login timestamps and session duration
• Pages visited, games played, and betting history on the platform
• Crash game round history (Aviator, Bird Catcher)
• Communication records with up789 support (chat logs, emails)

2.4 Verification Documents

• Copies of government-issued photo identification submitted during KYC
• Proof of address documents
• Screenshots or confirmation of payment method ownership

3. How We Collect Your Data

up789 collects personal data through the following channels and mechanisms:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, or contacting our support team.
• Automated collection: Technical and usage data collected automatically when you access the up789 platform, including IP address, device identifiers, browser type, and session activity logs.
• Payment providers: Transaction confirmation data received from JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and 1LINK when you make a deposit or request a withdrawal.
• Cookies and tracking technologies: Data collected via cookies, pixel tags, and similar technologies as described in Section 7 of this policy.
• Third-party identity verification services: Where up789 uses an automated KYC verification partner to cross-reference identity documents against authoritative databases.
• Customer support interactions: Records of chat conversations, email correspondence, and any other communication you initiate with the up789 support team.

4. Why We Use Your Data

up789 uses your personal data only for specific, legitimate purposes directly related to providing and improving its services. The table below sets out the primary purposes for which your data is processed:

• Account registration and management: To create and maintain your up789 player account, authenticate your identity at login, and manage your account preferences and settings.
• Age and identity verification: To confirm that you are at least 21 years of age and to verify your identity in compliance with KYC obligations. This is a legal requirement and cannot be waived.
• Payment processing: To process deposits made via JazzCash, EasyPaisa, Raast, and other accepted payment channels, and to execute withdrawal requests to your verified payment method.
• Responsible gaming monitoring: To monitor your gaming behaviour for indicators of problem gambling and to enforce any deposit limits, session limits, cooling-off periods, or self-exclusion measures you have activated or that up789 applies under its responsible gaming obligations.
• Anti-money laundering and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other financial crimes on the platform.
• Customer support: To respond to your queries, complaints, and support requests in a timely and effective manner.
• Legal and regulatory compliance: To meet obligations imposed by applicable law, including responding to lawful requests from regulatory or law enforcement authorities.
• Platform improvement: To analyse usage patterns, identify technical issues, and improve the quality, performance, and security of the up789 platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent to receive such communications. You may withdraw this consent at any time by contacting [email protected].

5. Legal Basis for Processing

up789 processes your personal data on one or more of the following legal bases, depending on the specific processing activity involved:

• Contractual necessity: Processing is necessary to perform the contract between you and up789 — specifically, to provide access to the gaming platform and to process your financial transactions.
• Legal obligation: Processing is required to comply with applicable legal and regulatory requirements, including KYC, anti-money laundering obligations, and age verification mandates.
• Legitimate interests: Processing is necessary for up789's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided those interests are not overridden by your own rights and interests.
• Consent: For certain processing activities such as marketing communications and the use of non-essential cookies, up789 relies on your explicit, freely given consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Data Sharing and Disclosure

up789 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. Your data may however be shared with the following categories of recipients in the circumstances described below:

6.1 Payment Processors

Your financial data is shared with payment service providers including JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and 1LINK solely to the extent necessary to process your transactions. These providers are contractually obligated to handle your data securely and in accordance with applicable financial data protection requirements.

6.2 Identity Verification and KYC Partners

Where up789 employs third-party KYC or identity verification service providers, your identity documents and personal details may be shared with those providers for the purpose of verifying your identity and age. Such providers are bound by strict confidentiality and data processing agreements.

6.3 Regulatory and Law Enforcement Authorities

up789 may be required by law, court order, or regulatory directive to disclose your personal data to competent authorities. In such cases, up789 will disclose only the minimum data necessary to comply with the legal obligation and will, where legally permissible, notify you of such disclosure.

6.4 Fraud and Security Partners

up789 may share data with third-party fraud prevention and cybersecurity service providers for the purpose of detecting and preventing fraudulent activity, account takeovers, and other security threats. All such partners operate under binding data processing agreements.

6.5 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets involving up789, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and the privacy terms applicable to your data going forward.

7. Cookies and Tracking Technologies

up789 uses cookies and similar tracking technologies on its platform to ensure proper functionality, enhance the user experience, and collect analytics data. A cookie is a small text file stored on your device when you visit a website. The types of cookies used by up789 include:

• Essential cookies: Necessary for the platform to function correctly. These include session authentication cookies that keep you logged in, and security cookies that protect your account. These cannot be disabled without affecting platform functionality.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the up789 platform, including which pages are visited most frequently and where technical errors occur. This data helps us improve platform performance.
• Preference cookies: Store your platform preferences such as language settings and display options so that you do not need to re-enter them on each visit.
• Marketing cookies: Used, with your consent, to track your engagement with promotional content and to measure the effectiveness of up789's marketing campaigns. These cookies do not track your activity on third-party websites.

You may manage your cookie preferences through your browser settings. Please note that disabling essential cookies will impair your ability to use the up789 platform. For browsers commonly used in Pakistan — including Chrome on Android, Safari on iOS, and Samsung Internet — cookie management settings are accessible through the browser's privacy or settings menu.

8. Data Retention

up789 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any applicable legal, accounting, regulatory, or reporting requirements. The general retention principles applied by up789 are as follows:

• Active accounts: Personal data is retained for the full duration of your account being active on the up789 platform.
• Closed accounts: Following account closure, up789 retains identity, financial transaction, and KYC data for a minimum period required under applicable anti-money laundering and gaming regulations. This period is typically five (5) years from the date of account closure.
• Support communications: Records of support interactions are retained for a period of three (3) years to assist with complaint resolution and audit purposes.
• Marketing consent records: Records of your marketing consent or withdrawal thereof are retained for as long as necessary to demonstrate compliance with your stated preferences.

Once your data is no longer required for any of the above purposes and no legal retention obligation applies, up789 will securely delete or anonymise your personal data so that it can no longer be attributed to you as an individual.

9. Data Security

up789 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the up789 platform
• Encryption of sensitive data at rest, including financial records and identity documents
• Access controls ensuring that only authorised personnel can access personal data, on a strict need-to-know basis
• Regular security audits and vulnerability assessments of the up789 platform infrastructure
• Two-factor authentication options available to players for enhanced account security
• Continuous monitoring of platform systems for suspicious activity and potential data breaches

While up789 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, up789 will notify affected players promptly and take immediate remediation steps.

You also have a role to play in keeping your account secure. Use a strong, unique password for your up789 account, do not share your login credentials with anyone, and contact [email protected] immediately if you suspect unauthorised access to your account.

10. Your Privacy Rights

As a user of the up789 platform, you hold certain rights with respect to your personal data. up789 is committed to honouring these rights promptly and transparently. Your rights include:

• Right of access: You may request a copy of the personal data that up789 holds about you at any time.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data held by up789.
• Right to erasure: You may request deletion of your personal data in certain circumstances, subject to up789's legal retention obligations.
• Right to restrict processing: You may request that up789 limit the processing of your data in specific circumstances, for example while the accuracy of your data is being verified.
• Right to data portability: You may request that up789 provide your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to object: You may object to the processing of your personal data where up789 relies on legitimate interests as the legal basis, or where your data is processed for direct marketing purposes.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

To exercise any of the above rights, please contact up789 at [email protected] with a clear description of your request. up789 will respond within a reasonable timeframe and may need to verify your identity before processing your request. There is no charge for exercising your privacy rights in most circumstances.

11. Children and Minors

up789 employs active age verification measures during the registration process and through ongoing KYC checks to prevent underage access to its platform. Parents and guardians who become aware that a minor under their care has registered on up789 should contact [email protected] immediately so that the account can be closed and all associated data deleted without delay.

up789 encourages parents and guardians to make use of parental control tools available on devices commonly used in Pakistani households, including Android parental controls, Screen Time on iOS, and third-party family safety applications, to prevent minors from accessing online gaming platforms.

12. Third-Party Services

The up789 platform integrates with a number of third-party service providers to deliver its full range of features. These include game content providers, payment gateway operators, identity verification services, and platform analytics tools. While up789 selects these partners carefully and binds them to appropriate data protection obligations, up789 is not responsible for the independent privacy practices of third-party providers.

Where a third-party service collects data directly from you — for example, during a payment transaction processed through JazzCash or EasyPaisa — that collection is governed by the third party's own privacy policy. up789 encourages you to review the privacy policies of any payment providers whose services you use in connection with your up789 account.

up789 does not permit third-party advertising networks to collect data about your activity on the up789 platform for the purpose of serving targeted advertisements on other websites or applications.

13. Changes to This Policy

up789 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. When material changes are made, up789 will notify registered players by email and by posting a prominent notice on the platform prior to the changes taking effect.

The effective date displayed at the top of this document reflects when the current version came into force. Your continued use of the up789 platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you should cease using the platform and may request account closure by contacting support.

We recommend that you revisit this Privacy Policy periodically to stay informed about how up789 protects your personal data. All previous versions of this policy are available on request by contacting our support team.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by up789, please reach out to us through the following channels:

• Email: [email protected] (response within 2 hours)
• Live Chat: Available 24/7 through the up789 platform after logging in to your account

When contacting us regarding a privacy matter, please include your registered account username and a clear description of your query or request so that our team can assist you as efficiently as possible.