Privacy Policy — com789

1. Introduction

This Privacy Policy ("Policy") is issued by com789 ("com789", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at https://com789.cam ("Platform"). It sets out how we collect, use, store, disclose and protect the personal data of individuals ("User", "you", "your") who register for or access the Platform.

This Policy applies to all personal data processed in connection with the Platform, including data provided during account registration, identity verification (KYC), deposits, withdrawals, wagering activity, customer support interactions and browsing behaviour on the Platform.

By registering an account or otherwise using the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not access or use the Platform.

2. Definitions

In this Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means com789, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of com789 under a data processing agreement.
• "KYC" means Know Your Customer — the identity and age verification process required by the Platform's compliance obligations.
• "Cookie" means a small text file placed on your device by the Platform that stores session or analytics information.
• "Sensitive Personal Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data or financial data beyond standard transaction records.

3. Data We Collect

We collect the following categories of personal data from users of the Platform:

3.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID.
• Date of birth (to verify minimum age eligibility).
• Residential address.
• Nationality and country of residence.
• Username chosen at registration.

3.2 Contact Data

• Email address (primary communication channel).
• Mobile number, where provided.

3.3 Identity Verification (KYC) Documents

• Scanned or photographed copies of a valid government-issued photo ID. For Pakistani users, this typically means a valid CNIC (Computerised National Identity Card, both sides) or a valid Pakistani Passport biographical data page.
• Proof of address where required (e.g., utility bill or bank statement dated within the past three months).
• Liveness-check image or short video as requested during the verification flow.

3.4 Financial & Transaction Data

• Deposit and withdrawal records, including amounts (displayed in PKR), timestamps and reference numbers.
• Payment method identifiers (e.g., partial wallet or account numbers sufficient for reconciliation but not full credentials).
• Wagering history: stakes placed, markets selected, game titles accessed, outcomes and resulting balances.

3.5 Device & Usage Data

• IP address and approximate geographic location derived from IP.
• Browser type, version and operating system.
• Device identifiers where accessible.
• Pages visited, session duration and clickstream data within the Platform.

3.6 Communications Data

• Records of support chat conversations, emails and any other communications you send to or receive from com789.

3.7 Data We Do Not Intentionally Collect

We do not intentionally collect Sensitive Personal Data relating to racial or ethnic origin, political opinions, religious beliefs or health status unless directly relevant to a responsible gambling assessment where you have voluntarily provided such information. Full payment credentials such as complete card numbers, CVV codes, wallet PINs or OTPs are never stored by com789 — these are handled directly by our licensed payment processor.

4. Legal Basis for Processing

We process your personal data on the following legal bases:

5. How We Use Your Data

com789 processes your personal data for the following specific purposes:

• Account operation: To create, maintain and administer your Account, including displaying your PKR balance, recording wagering history, and managing login credentials.
• Identity and age verification: To confirm you meet the minimum age requirement and are eligible to use the Platform in accordance with our Terms & Conditions.
• Transaction processing: To process deposits and withdrawals through the payment methods available in your cashier, which may include references to familiar Pakistani payment rails such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah. References to these providers do not imply their endorsement of com789 or their support for gambling transactions.
• Fraud prevention and AML: To screen transactions and account behaviour for indicators of money laundering, payment fraud, bonus abuse, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible gambling: To monitor account activity that may indicate problematic gambling behaviour, to apply deposit or loss limits you have set, and to enforce self-exclusions.
• Customer support: To respond to your enquiries, resolve disputes, and maintain records of communications for quality and compliance purposes.
• Platform improvement: To analyse aggregated, pseudonymised usage data and improve the functionality, security and content of the Platform.
• Legal and regulatory compliance: To comply with applicable legal obligations in the operator's licensing jurisdiction, including record-keeping, reporting and audit requirements.

6. Data Sharing & Disclosure

com789 does not sell, rent or trade your personal data to third parties for their own marketing purposes. We disclose personal data only in the following circumstances:

6.1 Licensed Service Providers

We share data with third-party processors who provide services essential to platform operation, including KYC and identity verification vendors, payment processing gateways, fraud and AML screening tools, game studios and live dealer technology suppliers, cloud infrastructure providers, and customer support platforms. All processors are required to handle your data under binding confidentiality obligations and may only process it for the specific purposes we instruct.

6.2 Legal and Regulatory Disclosure

We may disclose personal data where required by applicable law, court order, regulatory direction or governmental authority in the operator's licensing jurisdiction. We will endeavour to notify you of such disclosure requests where permitted by law.

6.3 Business Transfers

In the event of a merger, acquisition, sale of assets or restructuring involving com789, personal data may be transferred to the acquirer as part of that transaction, subject to equivalent data protection obligations.

6.4 Protection of Rights

We may share data with third parties when reasonably necessary to enforce our Terms & Conditions, prevent fraud, protect the security of the Platform, or protect the rights, property or safety of com789, its users or others.

7. Data Retention

We retain personal data only for as long as is necessary for the purposes for which it was collected or as required by applicable law. In practice:

• Account and transaction data is retained for a minimum of five (5) years from the date of the last transaction or account closure, as required by standard AML and financial record-keeping obligations in most licensing jurisdictions.
• KYC documents are retained for the minimum period required by applicable regulatory obligations and deleted securely thereafter.
• Support communications are retained for a period sufficient to resolve any outstanding dispute and thereafter archived or deleted.
• Analytics and usage data is retained in pseudonymised form for platform improvement purposes and reviewed periodically for necessity.
• Marketing consent records are retained for as long as you remain opted in and for a reasonable period thereafter to evidence the consent history.

On expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.

8. Security Measures

com789 implements a range of technical and organisational measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• 256-bit Transport Layer Security (TLS) encryption for all data transmitted between your browser and our servers.
• Encryption at rest for particularly sensitive data categories, including KYC documents.
• Role-based access controls limiting internal access to personal data to staff with a demonstrable operational need.
• Regular security assessments and penetration testing of Platform infrastructure.
• Two-factor authentication options for user accounts to reduce the risk of unauthorised access.
• Logging and monitoring of access to systems holding personal data.

9. Cookies & Tracking Technologies

The Platform uses cookies and similar tracking technologies (such as pixel tags and local storage) to operate the Platform, maintain your session and analyse usage patterns. The categories of cookies we use are set out below:

You can manage cookie preferences through your browser settings. Note that disabling non-essential cookies may affect the performance or personalisation of certain Platform features. We do not use cookies to build advertising profiles or share cookie data with advertising networks.

10. Your Rights

Subject to applicable data protection law and certain conditions, you have the following rights with respect to your personal data held by com789:

• Right of Access: You may request a copy of the personal data we hold about you (commonly known as a Subject Access Request).
• Right to Rectification: You may request that we correct inaccurate or incomplete personal data.
• Right to Erasure: You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected and where we have no overriding legal obligation to retain it.
• Right to Restrict Processing: You may request that we restrict the processing of your data in certain circumstances, for example while a rectification request is being assessed.
• Right to Data Portability: Where processing is based on your consent or on a contract, you may request that we provide your data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interest, including profiling, unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact our support team via support@com789.cam (plain text — not a clickable link). We will respond within the timeframe required by applicable law, generally within 30 calendar days. We may need to verify your identity before processing your request.

11. International Data Transfers

com789 operates through cloud infrastructure and third-party service providers whose servers may be located outside Pakistan or the operator's primary licensing jurisdiction. Where personal data is transferred internationally, we ensure that appropriate safeguards are in place, such as binding data processing agreements incorporating standard contractual clauses or equivalent mechanisms recognised under applicable data protection law.

By using the Platform, you acknowledge that your data may be transferred to, stored in and processed in countries other than your country of residence, which may have different data protection standards.

12. Minors

The Platform is strictly intended for adults aged 18 and above — or the higher minimum age required by the operator's license jurisdiction. com789 does not knowingly collect personal data from individuals under the applicable minimum age. Age verification is a mandatory component of the KYC process.

If we become aware that personal data has been collected from a person below the minimum age without appropriate consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact us at support@com789.cam immediately.

13. Policy Amendments

com789 reserves the right to update or amend this Privacy Policy at any time. Where changes are material — for example, a change to the categories of data collected or to the purposes for which data is used — we will provide reasonable notice via a prominent notice on the Platform or by email to your registered address.

Continued use of the Platform after the effective date of any amendment constitutes your acceptance of the updated Policy. We recommend reviewing this page periodically. The last-reviewed date is displayed in the page header.

14. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to report a data protection concern, please contact our support team through the following channel:

• Support Email: support@com789.cam (plain text — not a clickable link)
• Support Hours: 24 hours a day, 7 days a week
• Response Language: English (Urdu assistance may be available on request)

For questions about your account eligibility, bonus terms or wagering rules, please visit our FAQ page or read our full Terms & Conditions.