Privacy Policy
— d789 Platform

d789 ("d789", "we", "us", "our") operates the online casino and sports betting platform accessible at https://d789.cam (the "Platform"). We are committed to protecting the privacy and security of the personal data of all individuals who interact with our Platform ("Users", "Players", "you").

This Privacy Policy describes the categories of personal data we collect, the purposes for which we process that data, the legal bases on which we rely, the circumstances in which we may share your data with third parties, and the rights available to you in relation to your personal information.

This Policy applies to all Users of the d789 Platform, including players based in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and elsewhere. By registering an account or continuing to use the Platform after any material update to this Policy, you acknowledge that you have read and understood its terms.

This Privacy Policy should be read alongside our Terms & Conditions, which govern the overall contractual relationship between you and d789.

Throughout this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person ("data subject"), including name, identification number, location data, online identifiers or factors specific to that person's physical, economic or social identity.
• "Processing" — any operation performed on personal data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, restriction, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. d789 acts as the Data Controller in respect of User data collected through the Platform.
• "Data Processor" — a natural or legal person, public authority, agency or other body that processes personal data on behalf of the Data Controller.
• "Consent" — freely given, specific, informed and unambiguous agreement by the data subject to the processing of their personal data for one or more specified purposes.
• "KYC" — Know Your Customer — the regulatory identity and age-verification process applied to registered accounts.
• "Cookies" — small text files placed on your device by the Platform for the purposes of session management, analytics and user experience personalisation.
• "Third Party" — any natural or legal person other than the data subject, d789, or those acting under d789's direct authority to process personal data.

d789 is the Data Controller responsible for the personal data processed through the Platform at https://d789.cam. As Data Controller, d789 determines the purposes for which personal data is collected and the manner in which it is processed, stored and, where applicable, shared with authorised third-party data processors.

All enquiries, requests and complaints relating to the handling of your personal data should be directed to the d789 Data Protection contact set out in Section 16 of this Policy.

d789 collects the following categories of personal data in the course of providing the Platform and its associated services:

d789 collects personal data through the following channels:

d789 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and d789 — specifically, to operate your account, process deposits and withdrawals in PKR, settle wagers and provide customer support.
• Legal Obligation: Processing is required to comply with legal obligations to which d789 is subject, including anti-money laundering (AML) checks, identity verification requirements and regulatory reporting obligations.
• Legitimate Interests: Processing is necessary for d789's legitimate interests, including fraud prevention, platform security, responsible gambling monitoring and improvement of Platform services — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where d789 relies on consent as a legal basis — for example, in relation to certain marketing communications — you retain the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

d789 processes your personal data for the following specific purposes:

d789 does not sell, rent or trade your personal data to third parties for their own commercial purposes. We share your personal data only in the following defined circumstances:

• Payment Processors: Necessary financial data is shared with authorised payment service providers to facilitate deposit and withdrawal transactions. These processors handle PKR transactions via methods commonly referenced by Pakistani players, including bank transfer networks and digital wallet infrastructures. These providers are bound by strict data processing agreements and may not use your data for purposes beyond processing your specific transactions.
• Identity Verification Partners: KYC-related data (including identification documents) is shared with contracted identity verification service providers for the sole purpose of confirming your identity and age. These partners operate under binding data processing agreements.
• Fraud Prevention Services: Relevant account and transaction data may be shared with fraud intelligence platforms to detect and prevent financial crime and platform abuse.
• Game Content Providers: Gaming activity data (session metadata, bets placed, game outcomes) may be shared with the licensed content studios supplying games to the Platform. This sharing is limited to data technically necessary for game functionality and is governed by contractual data protection arrangements.
• Regulatory and Legal Disclosure: d789 may disclose personal data to competent authorities, regulators, courts or law enforcement bodies where required to do so by applicable law, court order or regulatory direction — including in connection with AML investigations or other statutory obligations.
• Corporate Transactions: In the event of a merger, acquisition or restructuring involving d789, personal data held by the Platform may be transferred to the successor entity, subject to equivalent data protection commitments.

The d789 Platform uses cookies and similar tracking technologies to support Platform functionality, maintain authenticated sessions and collect analytics data. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the Platform — including session authentication, security tokens and load-balancing functions. These cookies cannot be disabled without impairing core Platform functionality.
• Functional Cookies: Enable the Platform to remember your preferences and settings — such as language, display preferences and responsible gambling limit configurations — across sessions.
• Analytics Cookies: Collect pseudonymised data about how Users interact with the Platform, including pages visited, game categories accessed, session duration and device type. This data is used in aggregate form to improve the Platform experience, particularly for mobile users.
• Marketing / Preference Cookies: Used to deliver personalised promotional content and track the effectiveness of campaigns where you have consented to such personalisation.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use core Platform features including account login. Adjusting cookie preferences does not affect any personal data already legitimately processed by d789 prior to the change.

d789 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Specific retention periods are as follows:

• Active Account Data: Retained for the full duration of your active account relationship with d789.
• Post-Closure Retention: Following account closure, core account data (registration records, KYC documents and transaction history) is retained for a minimum period as required by applicable anti-money laundering and gaming regulatory obligations — typically a minimum of five (5) years from the date of account closure, unless a longer period is required by law.
• Communications Records: Support communications are retained for a minimum of two (2) years from the date of the relevant interaction, for dispute resolution and quality-assurance purposes.
• Marketing Data: Where consent is the legal basis for marketing communications, related preference data is retained until consent is withdrawn and for a reasonable period thereafter to maintain a suppression record.

At the conclusion of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with d789's internal data destruction procedures.

d789 implements technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, disclosure, alteration or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and d789 servers;
• Encryption of sensitive data at rest, including KYC documents and payment-related identifiers;
• Role-based access controls limiting data access to authorised d789 personnel with a demonstrated operational need;
• Regular security assessments and vulnerability reviews of Platform infrastructure;
• Incident response procedures for the detection, containment and reporting of personal data breaches.

Subject to applicable law and the legal bases on which your data is processed, you have the following rights in relation to your personal data held by d789:

The d789 Platform is strictly an adults-only service. Access to real-money gambling features requires the User to be at least 18 years of age — or such higher minimum age as is required by the operator's licence jurisdiction — as verified through the KYC process.

d789 does not knowingly collect personal data from individuals under the minimum age threshold. If d789 becomes aware that personal data has been collected from an underage individual, the relevant account will be immediately suspended, any funds deposited will be handled in accordance with our Terms & Conditions, and the associated personal data will be deleted as promptly as possible consistent with applicable legal requirements.

If you believe that a minor has registered an account on d789 or has accessed the Platform using your credentials, please contact our support team immediately via the details in Section 16. For more on our age verification approach, visit our Responsible Gambling page.

In the course of providing the Platform and its associated services, your personal data may be transferred to, processed in or stored in jurisdictions outside the country in which you are located. This may include transfers to countries that may not provide the same level of data protection as applicable laws in your home jurisdiction.

Where such transfers occur, d789 takes appropriate steps to ensure that your personal data receives an adequate level of protection. These steps may include:

• Entering into standard contractual clauses or equivalent contractual protections with receiving entities;
• Transferring data only to jurisdictions that provide an adequate level of data protection as determined by applicable regulatory frameworks;
• Implementing supplementary technical and organisational security measures appropriate to the transfer.

By using the d789 Platform, you acknowledge that your personal data may be transferred internationally in the manner described above and consent to such transfers where consent is required under applicable law.

d789 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our business operations or the way we process personal data. The "Last Updated" date at the top of this page will be revised whenever a material change is made.

For material changes affecting your rights or the way we process your personal data, d789 will provide notice to registered Users via email notification to the address on file, or through a prominent notice on the Platform, prior to the change taking effect.

Your continued use of the d789 Platform following notification of a material policy update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to remain informed about how we protect your information.

If you wish to exercise any of your data rights, raise a privacy concern, submit a data protection complaint, or ask any questions about this Privacy Policy or d789's data handling practices, please contact us using the details below.

For general support queries unrelated to data rights, you may also contact the d789 team via the 24/7 live chat widget available on the Platform.