Privacy Policy — How qr789 Protects Your Data

This Privacy Policy ("Policy") is issued by qr789 ("the Company," "we," "us," "our") and applies to all personal data collected, processed, and stored in connection with your use of the qr789 website, mobile platform, and associated services (collectively, the "Platform"). The Policy applies to all registered players, including players based in Pakistan, and to any visitor who browses the qr789 website without registering.

qr789 is committed to handling personal data responsibly, transparently, and in accordance with applicable data protection principles under its international gaming licence obligations. This Policy explains in clear terms what data we collect, why we collect it, how it is used, who we share it with, how long we keep it, and what rights you have in relation to it.

By registering an account on the qr789 platform, making a deposit, or continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the qr789 Platform and contact support to close your account.

This Policy should be read alongside the qr789 Terms and Conditions and Responsible Gaming Policy, which together form the full legal framework governing your relationship with qr789.

qr789 collects the following categories of personal data in connection with the operation of the Platform:

We do not knowingly collect special category data (such as health information, racial or ethnic origin, political opinions, or religious beliefs) unless it is volunteered by a player in the context of a responsible gaming or self-exclusion request, in which case it is processed solely for the purpose of administering the relevant protective measure.

qr789 collects personal data through the following channels:

• Direct submission: Data you provide when registering your account, completing KYC verification, making a deposit or withdrawal, contacting our support team, or responding to a survey or promotion.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 7 (Cookies & Tracking) for further detail.
• Third-party payment processors: Confirmation and reference data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency network providers when you initiate a financial transaction on the Platform.
• Identity verification providers: Results and reports from licensed KYC and anti-money-laundering service providers used to verify the identity documents you submit during the verification process.
• Fraud prevention and risk platforms: Data signals received from third-party fraud detection services that help qr789 identify suspicious account activity and protect the integrity of the Platform.

Where qr789 collects data from third-party sources, we ensure that the source has a lawful basis for sharing that data with us and that its use is consistent with the purpose for which it was originally collected.

qr789 processes your personal data only for clearly defined, legitimate purposes. The primary purposes for which we use your data are as follows:

• Account management: Creating, maintaining, and managing your qr789 player account, including processing account updates, password resets, and account closure requests.
• Payment processing: Facilitating deposits and withdrawals in PKR via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency channels, and maintaining accurate financial records of all transactions.
• Identity verification (KYC): Verifying your identity, age (21+), and the source of your deposited funds in accordance with qr789's anti-money-laundering obligations under its international gaming licence.
• Platform operation and improvement: Providing, maintaining, and improving the qr789 gaming Platform, diagnosing technical issues, and developing new features based on aggregated usage data.
• Responsible gaming: Monitoring gameplay patterns for indicators of problem gambling behaviour, administering deposit limits, cooling-off periods, and self-exclusion requests, and contacting players who may be at risk.
• Fraud prevention and security: Detecting and preventing fraudulent activity, collusion, money laundering, unauthorised account access, and other forms of abuse.
• Legal and regulatory compliance: Meeting qr789's obligations under its gaming licence, responding to regulatory enquiries, and complying with applicable court orders or lawful requests from authorised bodies.
• Marketing communications: Sending promotional offers, bonus notifications, PSL and cricket betting promotions, and platform updates — but only to players who have given explicit consent to receive such communications.
• Customer support: Responding to your queries, complaints, and requests through our 24/7 live chat and email support channels.

qr789 does not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for the new processing activity.

qr789 processes your personal data on the following legal bases, depending on the specific processing activity involved:

• Contractual necessity: Processing that is necessary to perform the contract between you and qr789 (i.e., the Terms and Conditions you accept at registration), including account management, payment processing, and KYC verification.
• Legal obligation: Processing that is required to comply with qr789's obligations under its international gaming licence, including anti-money-laundering checks, age verification, and regulatory reporting.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and the improvement of qr789's services, provided such interests are not overridden by your rights and interests.
• Consent: Processing for marketing communications, optional analytics, and any other processing activity for which qr789 has specifically requested and obtained your explicit consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

qr789 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. Data is shared with third parties only in the following limited and controlled circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency network providers receive only the transactional data necessary to process your deposit or withdrawal. These providers operate under their own privacy policies and are independently regulated.
• KYC and compliance providers: Licensed identity verification and anti-money-laundering service providers receive the identity documents and data you submit during the verification process. These providers are bound by strict confidentiality and data security obligations.
• Game software providers: Third-party game providers such as Evolution Gaming and Pragmatic Play may receive session identifiers and game data necessary to deliver and support the games on the Platform. They do not receive your full personal profile.
• Fraud prevention services: Anonymised or pseudonymised data may be shared with fraud detection platforms to identify patterns of suspicious activity. Full personal profiles are not shared with these services as standard.
• IT and infrastructure providers: Cloud hosting, content delivery, and technical support providers who process data on qr789's behalf under binding data processing agreements that restrict their use of the data to the provision of services to qr789.
• Regulatory and legal authorities: qr789 will disclose personal data to regulators, law enforcement agencies, or courts where required to do so by law, by a valid court order, or in connection with its obligations under its gaming licence. qr789 will, where lawfully permitted, notify you of any such disclosure.

All third-party service providers engaged by qr789 are subject to due diligence assessments and are required to implement appropriate technical and organisational security measures to protect any personal data they process on qr789's behalf.

qr789 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the qr789 website. Cookies allow the Platform to recognise your device, maintain your session, and personalise your experience.

qr789 uses the following categories of cookies:

• Strictly necessary cookies: Essential to the operation of the Platform. These cookies enable core functions such as user authentication, session management, and security features. They cannot be disabled without breaking the Platform's functionality.
• Functional cookies: Allow the Platform to remember your preferences — such as your chosen language, preferred game categories, and display settings — to provide a more personalised experience on your next visit.
• Analytics cookies: Used to collect aggregated, anonymised data about how players navigate and use the Platform. This information helps qr789 identify areas for improvement and measure the effectiveness of platform updates. Analytics data is not linked to your individual identity.
• Marketing cookies: Used only if you have consented to receive targeted promotional content. These cookies help qr789 and its approved marketing partners deliver relevant bonus offers and promotions based on your gaming preferences and history.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies will affect the functionality of the Platform, and some features may not operate correctly. Disabling marketing cookies will not prevent you from seeing general promotions — it will only prevent the personalisation of those promotions.

qr789 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and our licensing obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account and for a minimum period of five years following account closure, in accordance with standard anti-money-laundering record-keeping requirements under international gaming licence conditions.
• Financial transaction records: Retained for a minimum of five years from the date of the transaction, as required by our licensing obligations and applicable financial record-keeping standards.
• KYC verification documents: Retained for the period required by our licensing authority's anti-money-laundering guidelines, typically five years from the date of verification or account closure, whichever is later.
• Customer support communications: Retained for three years from the date of the final communication in the relevant support thread, or longer if the communication is related to an unresolved dispute or regulatory matter.
• Gaming and session data: Retained for up to five years for regulatory compliance, fraud investigation, and dispute resolution purposes.
• Marketing data: Retained until you withdraw your consent to receive marketing communications, or for up to two years of marketing inactivity, whichever comes first.
• Anonymised analytics data: May be retained indefinitely as it cannot be used to identify individual players.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with qr789's data destruction procedures. Where data must be retained beyond the standard period due to an ongoing legal, regulatory, or dispute-related obligation, qr789 will restrict its processing to only what is necessary for that specific purpose.

qr789 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the qr789 Platform is encrypted using 256-bit SSL/TLS encryption, preventing interception by unauthorised parties.
• Secure data storage: Personal data is stored on secured, access-controlled servers. Database access is restricted to authorised personnel on a strictly need-to-know basis.
• Access controls: qr789 employees and contractors are granted access to personal data only to the extent necessary for their specific role. Access permissions are reviewed regularly and revoked immediately upon change of role or termination of employment.
• Account security: Player accounts are protected by password hashing, and qr789 supports two-factor authentication to provide an additional layer of protection against unauthorised access.
• Security monitoring: The Platform is subject to continuous security monitoring, intrusion detection systems, and regular third-party penetration testing to identify and remediate vulnerabilities.
• Staff training: All qr789 staff who handle personal data undergo regular training on data protection responsibilities and security best practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, qr789 will notify you promptly and take immediate remedial action in accordance with its incident response procedures and applicable licensing obligations.

As a player on the qr789 Platform, you have the following rights in relation to your personal data. qr789 will respond to all valid rights requests within 30 calendar days of receipt:

• Right of access: You have the right to request a copy of the personal data qr789 holds about you. We will provide this in a structured, commonly used format.
• Right to rectification: If any personal data qr789 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You may also update certain details directly through your account settings.
• Right to erasure: You may request that qr789 delete your personal data. This right is not absolute — qr789 may be required to retain certain data to comply with its legal and licensing obligations, in which case we will inform you of the specific retention basis.
• Right to restriction: You have the right to request that qr789 restrict the processing of your personal data in certain circumstances — for example, while a dispute regarding the accuracy of your data is being resolved.
• Right to data portability: Where processing is based on your consent or on a contract with you, you have the right to receive your personal data in a machine-readable format and to request that it be transferred to another service provider where technically feasible.
• Right to object: You have the right to object to the processing of your personal data where it is based on qr789's legitimate interests. qr789 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent (such as marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact the qr789 support team via live chat or by emailing [email protected] with the subject line "Data Rights Request." Please include your full registered name and account email address so that we can verify your identity before processing your request.

The qr789 Platform is strictly intended for adults aged 21 and over. qr789 does not knowingly collect, process, or store personal data belonging to any person under the age of 21. The Platform incorporates age verification checks at the point of account registration, and KYC verification confirms the age of all players before withdrawals are permitted.

If qr789 becomes aware that personal data has been collected from a person under the age of 21 — whether through circumvention of the age verification process or any other means — the relevant account will be immediately closed, any deposited funds returned to the originating payment method (subject to verification), and all associated personal data deleted from qr789's systems without delay.

If you are a parent or guardian and believe that a minor has registered on the qr789 Platform using your payment details or personal information, please contact our support team immediately via live chat so that the matter can be investigated and resolved as a priority.

qr789 operates under an international gaming licence, and as a result, some of the third-party service providers we engage — including cloud infrastructure providers, KYC platforms, and game software suppliers — may process personal data in jurisdictions outside Pakistan. These may include countries in Europe, Asia, and North America.

Where personal data is transferred outside the country in which it was collected, qr789 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that applied within the Platform. Such safeguards may include:

• Standard contractual clauses or data processing agreements between qr789 and the relevant third-party provider
• Transfer to jurisdictions that are recognised as providing an adequate level of data protection
• Binding corporate rules where the transfer is to a member of the same corporate group as qr789

If you would like further information about the specific safeguards in place for any particular international data transfer, please contact our support team at [email protected].

qr789 reserves the right to update or amend this Privacy Policy at any time. Where changes are material — meaning they affect your rights or how your data is used in a significant way — qr789 will provide at least 14 days' advance notice by publishing the updated Policy on the Platform and, where reasonably practicable, notifying you via your registered email address.

The effective date at the top of this Policy will be updated each time changes are made. Minor amendments — such as corrections to typographical errors, clarifications that do not affect the substance of any provision, or updates required to reflect new services that do not introduce new data processing activities — may be made without advance notice and will take effect immediately upon publication.

Your continued use of the qr789 Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. We recommend that you review this Policy periodically to stay informed of how qr789 handles your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way qr789 handles your personal data, please get in touch through any of the following channels:

• Live Chat: Available 24/7 directly on the qr789 Platform — the fastest way to get a response
• Email: [email protected] — please use the subject line "Privacy Enquiry" for data-related requests

qr789's support team includes staff who are familiar with the specific context of Pakistani players, including queries related to JazzCash and EasyPaisa payment data, CNIC verification documents, and PKR transaction records. We aim to acknowledge all privacy-related enquiries within one business day and to provide a substantive response within 30 calendar days.