up789 is committed to protecting the personal data of every user on our platform. This Privacy Policy explains in plain English what data we collect, why we collect it, how we use and protect it, and the rights you hold over your own information.
Effective Date: 1 January 2026These cards highlight key aspects of our data practices. They are a summary only — please read the full policy below for complete information.
We collect personal data you provide during registration (name, date of birth, email, CNIC for Pakistani users) and data generated by your use of the Platform (transaction records, game history, device and connection information).
Your data is used to operate your account, process transactions in PKR, verify your identity (KYC), personalise your experience, comply with legal obligations and — where you have consented — to send relevant promotional communications.
We share data only with trusted service providers necessary to operate the Platform (payment processors, KYC verification services, technology partners). We never sell your personal data to third parties for marketing purposes.
SSL encryption protects data in transit. Access controls, secure server infrastructure and regular security reviews protect data at rest. Only authorised personnel with a legitimate operational need may access personal data.
You have the right to access, correct, and in certain circumstances delete your personal data. You may also withdraw marketing consent and request a copy of the data we hold about you at any time via the Help Centre.
We retain personal data for as long as your account is active and for the legally required period thereafter — typically a minimum of five (5) years for financial transaction records to meet AML obligations. Specific retention periods are set out in Section 8.
Understanding the lifecycle of your personal data helps you make informed decisions about using the Platform. Here is a simplified view of how information moves through up789 from the moment you register.
No Data Sales: up789 does not sell, rent or trade your personal data to any third party for marketing, advertising or commercial profiling purposes. Full stop.
You provide your name, date of birth, email address and CNIC (for Pakistani users). This data is used to create your account and complete identity verification as required by the Operator's compliance obligations.
When you deposit funds — whether via bank transfer (HBL, UBL, Meezan Bank, Bank Alfalah), digital wallet references (Easypaisa, JazzCash, Raast) or cryptocurrency (BTC, USDT) — transaction metadata is recorded for AML compliance and account management. Full payment card or wallet credentials are handled by the payment processor directly.
Your game history, bet records, session timestamps and in-platform interactions are logged for account management, responsible gambling monitoring, fraud prevention and service personalisation.
IP address, browser type, operating system, device identifiers and cookie data are collected automatically when you access the Platform. This data supports security, fraud detection and performance analytics.
After account closure, data is retained for the legally required period and then securely deleted or anonymised. You may request deletion of marketing preferences and non-legally-required data at any time through the Help Centre.
This Privacy Policy ("Policy") is issued by up789 (the "Operator", "we", "us" or "our"), the operator of the online gaming and sports betting platform accessible at https://up789.cam (the "Platform"). It applies to all personal data collected from users ("you", "User" or "Account Holder") who access or use the Platform in any capacity.
This Policy explains what personal data we collect, the purposes for which we process it, the legal bases on which we rely, how long we retain it, to whom we may disclose it, and what rights you have in relation to it. Please read this Policy carefully before registering an Account or providing any personal information to us.
By registering an Account or continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood its contents. This Policy should be read alongside our Terms & Conditions.
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person, including name, email address, date of birth, CNIC, IP address and transaction records. |
| "Processing" | Any operation performed on Personal Data, including collection, storage, use, disclosure, erasure or destruction. |
| "Data Controller" | The entity that determines the purposes and means of processing Personal Data — in this case, up789. |
| "Data Processor" | A third party that processes Personal Data on behalf of the Data Controller under a contractual arrangement (e.g., payment processors, KYC verification providers). |
| "Consent" | Freely given, specific, informed and unambiguous agreement to the processing of Personal Data for a defined purpose, which may be withdrawn at any time. |
| "Cookie" | A small text file placed on your device by the Platform to enable functionality, session management and analytics. |
| "KYC" | Know Your Customer — the identity and age verification process required by the Operator before processing withdrawals or as otherwise required by applicable obligations. |
up789 acts as the Data Controller in respect of the Personal Data collected through the Platform. The Operator is responsible for determining the purposes and means of processing and for ensuring that such processing is conducted in accordance with applicable data protection laws.
The Operator is incorporated and regulated in its license jurisdiction. Details of the applicable regulatory framework are available on the Platform. For data-related queries or to exercise your rights, please contact us using the details provided in Section 16.
Minimum Data Principle: up789 collects only the Personal Data that is necessary for the specific purposes described in this Policy. We do not collect sensitive categories of Personal Data (such as religious beliefs, political opinions or health data) unless directly relevant to a responsible gambling assessment and only with your explicit consent.
We process your Personal Data for the following purposes, each supported by a distinct legal basis:
| Purpose | Legal Basis |
|---|---|
| Account creation and management | Performance of a contract (the Terms & Conditions you accept at registration) |
| Payment processing and PKR transaction management | Performance of a contract; compliance with legal obligations |
| Identity verification and KYC compliance | Compliance with legal obligations (AML/CTF requirements) |
| Fraud prevention and security monitoring | Legitimate interests of the Operator in protecting the Platform and its users |
| Responsible gambling monitoring and intervention | Compliance with legal obligations; legitimate interests in user welfare |
| Customer support and complaint resolution | Performance of a contract; legitimate interests |
| Platform analytics and service improvement | Legitimate interests in improving the Platform |
| Marketing communications (where opted in) | Your consent, which may be withdrawn at any time |
| Regulatory reporting and legal compliance | Compliance with legal obligations |
We engage carefully selected third-party service providers to assist us in operating the Platform. These providers process Personal Data on our behalf under contractual terms that restrict their use of the data to the specific services they provide. Categories of Data Processors include:
The listing of familiar Pakistan payment references — Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah — in the cashier does not imply that those providers are Data Processors for up789. Each provider operates independently under its own privacy practices.
We may disclose Personal Data to regulatory authorities, law enforcement bodies or courts where we are required to do so by applicable law, court order or regulatory obligation. This includes disclosures related to anti-money laundering investigations, fraud reporting and compliance with the Operator's license conditions.
In the event of a merger, acquisition, asset sale or restructuring of the Operator's business, Personal Data held on the Platform may be transferred to the acquiring entity. You will be notified in advance of any such transfer and of any resulting changes to this Policy.
No Data Sales: up789 does not sell, lease or otherwise transfer your Personal Data to third parties for their own marketing or commercial purposes. Any sharing is strictly limited to the categories described above.
As an online platform, up789 may process and store Personal Data on servers located outside Pakistan. Where Personal Data is transferred to jurisdictions that may not offer the same level of data protection as the country in which you reside, the Operator implements appropriate safeguards — such as contractual protections — to ensure that your data receives equivalent protection wherever it is processed.
Pakistan does not currently have a comprehensive federal data protection law equivalent to the EU's GDPR. The Operator applies data protection standards aligned with the applicable regulatory framework of its license jurisdiction and, where appropriate, international best practices.
We retain Personal Data for as long as is necessary for the purposes described in this Policy, or as required by applicable law. The following indicative retention periods apply:
When Personal Data is no longer required for any lawful purpose, it is securely deleted or irreversibly anonymised.
up789 implements technical and organisational security measures designed to protect Personal Data against unauthorised access, disclosure, alteration or destruction. These measures include:
While we take all reasonable precautions, no method of electronic transmission or storage is entirely secure. You are responsible for keeping your login credentials confidential and for notifying us immediately of any suspected unauthorised access to your Account.
Data Breach Notification: In the event of a Personal Data breach that is likely to result in a high risk to your rights and freedoms, up789 will notify affected individuals without undue delay in accordance with applicable data protection requirements.
The Platform uses cookies and similar tracking technologies to deliver and improve the service. The categories of cookies we deploy are as follows:
You may control non-essential cookies through the cookie preference centre on the Platform or by adjusting your browser settings. Note that disabling certain cookies may affect the functionality of the Platform.
The Platform is strictly for adults aged 18 or older (or the higher minimum age required under the operator's license jurisdiction). up789 does not knowingly collect Personal Data from individuals under the minimum age. If we become aware that Personal Data has been collected from a minor, we will delete it promptly and close the associated Account.
If you are a parent or guardian and believe that a minor in your care has registered on the Platform, please contact us immediately via the Help Centre or Live Chat so that we can take appropriate action.
Depending on your jurisdiction and the applicable data protection framework, you may hold some or all of the following rights in relation to your Personal Data. To exercise any of these rights, contact us using the details in Section 16.
Request a copy of the Personal Data we hold about you and information about how it is processed.
Request correction of inaccurate or incomplete Personal Data held in your Account.
Request deletion of Personal Data where it is no longer necessary for the purposes for which it was collected (subject to legal retention obligations).
Request that we limit our processing of your Personal Data in certain defined circumstances.
Receive a structured, machine-readable copy of Personal Data you provided to us, where technically feasible.
Object to processing based on legitimate interests, including direct marketing. We will cease such processing unless we can demonstrate compelling legitimate grounds.
We will respond to all verifiable data rights requests within thirty (30) calendar days of receipt, or within such longer period as permitted by applicable law where the request is complex. We may request proof of identity before processing a rights request to protect against fraudulent or unauthorised requests.
Where you have consented to receive marketing communications, we may contact you by email or in-platform notification with information about promotions, bonuses, new games, cricket betting markets and other Platform features that may be of interest to you.
You may withdraw your marketing consent at any time by:
Withdrawal of marketing consent does not affect the lawfulness of processing carried out before the withdrawal, and does not prevent us from sending you service communications that are necessary for the management of your Account (such as security alerts, withdrawal confirmations or policy change notices).
up789 acknowledges that Pakistan does not currently have a comprehensive federal data protection statute equivalent to the EU General Data Protection Regulation. The Operator applies data protection standards aligned with the applicable regulatory framework of its license jurisdiction and international best practices, including principles of purpose limitation, data minimisation, storage limitation and security.
Pakistani users submitting KYC documentation — including CNIC copies — should be aware that this data is processed solely for identity and age verification purposes and is not shared with Pakistani governmental or regulatory authorities except where we are legally compelled to do so by a valid legal order.
Legal Compliance Responsibility: up789 does not claim to be licensed, approved or regulated by any Pakistani authority. Pakistani users are solely responsible for ensuring that their use of the Platform and any associated data sharing complies with applicable Pakistani law. This notice does not constitute legal advice.
up789 reserves the right to amend this Privacy Policy at any time. Material changes — those that significantly affect the manner in which we process your Personal Data or your rights in relation to it — will be communicated to registered Account Holders by email or via a prominent on-Platform notification at least seven (7) days before they take effect.
Non-material changes (such as clarifications, typographical corrections or minor structural reorganisation that do not affect substantive data practices) may be made without prior notice. The "Effective Date" at the top of this Policy will be updated on each revision.
Your continued use of the Platform after the effective date of a revised Policy constitutes your acknowledgment of the updated terms. If you object to any changes, you must cease using the Platform and may request Account closure.
For any questions about this Privacy Policy, to exercise your data rights, or to raise a complaint about our data processing practices, please contact us through the following channels:
Please include your registered account username, the nature of your request and, for rights requests, sufficient information to allow us to verify your identity. We aim to acknowledge all data-related correspondence within five (5) business days and to provide a substantive response within thirty (30) calendar days.
If you are unsatisfied with our response to a data protection complaint, you may have the right to lodge a complaint with the relevant supervisory authority in the Operator's license jurisdiction. Details of the applicable supervisory authority are available on the Platform or upon request from our support team.
Our Commitment: up789 takes data protection seriously. We will always endeavour to handle your personal information with care, transparency and respect. If we fall short of that standard, we want to know — and we will work to put it right.
If you have a question about your data or want to exercise your rights, our support team is ready to help. Alternatively, explore our other policy pages or head back to the homepage.