Privacy Policy — AQ789

This Privacy Policy ("Policy") describes how AQ789 ("we", "us", "our") collects, uses, stores and discloses personal data in connection with your use of the AQ789 online gaming platform, including all associated websites, mobile interfaces and related services (collectively, the "Platform").

AQ789 is an English-language online gaming information and betting platform designed to serve users in Pakistan and other permitted jurisdictions. This Policy applies to all users who access or register on the Platform, regardless of location.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy. By creating an Account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy.

We are committed to processing your personal data lawfully, fairly and transparently. We apply data minimisation principles — collecting only what is genuinely necessary — and we do not sell your personal data to third parties for marketing purposes.

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

• "Personal Data" — any information that identifies or can reasonably identify a living individual, directly or indirectly, including name, email address, IP address, device identifiers and financial account details.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, erasure or any combination thereof.
• "Data Controller" — AQ789, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" — a third party that processes Personal Data on behalf of AQ789 under a contractual arrangement and in accordance with our instructions.
• "Consent" — a freely given, specific, informed and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
• "KYC Data" — identity and age verification documentation collected to fulfil Know Your Customer compliance obligations.
• "Cookies" — small text files placed on your device by a website to store session information, preferences and analytics data.
• "User" or "You" — any individual who accesses or registers on the AQ789 Platform.

AQ789 collects Personal Data through several channels. The categories of data we may collect include:

3.1 Registration Data

• Full name and date of birth
• Email address and account password (stored in hashed form)
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar)
• Mobile phone number, where provided
• Preferred currency and language settings

3.2 KYC Verification Data

• Government-issued photo identification (e.g., CNIC, passport, driving licence)
• Proof of address documentation
• Proof of payment method ownership (e.g., confirmation of ownership of a bank account used for deposits — referenced as a familiar local payment reference only, not as an endorsement of those providers)
• Selfie or liveness verification image, where required by our KYC provider

3.3 Transactional Data

• Deposit and withdrawal history, including amounts, dates and payment methods used
• Bet and game history, including stakes, outcomes and session duration
• Bonus and promotion redemption records

3.4 Technical & Device Data

• IP address and approximate geolocation derived from it
• Device type, operating system and browser version
• Session timestamps and duration
• Referral source and UTM parameters, where applicable

3.5 Communication Data

• Support chat transcripts and email correspondence
• Feedback, complaints and dispute records

We process your Personal Data for specific, legitimate purposes. The table below sets out the primary processing purposes and the legal basis we rely on for each:

Where we rely on legitimate interest as our legal basis, we carry out a balancing assessment to ensure that our interests do not override your fundamental rights and freedoms as a data subject.

Where we rely on consent — for example, for direct marketing communications — you may withdraw that consent at any time by contacting Support or using the unsubscribe mechanism in any marketing email. Withdrawal of consent does not affect the lawfulness of any processing carried out before withdrawal.

AQ789 uses cookies and similar tracking technologies (including local storage, session tokens and analytics scripts) to operate and improve the Platform. The categories of cookies we use are:

• Strictly Necessary Cookies: Required for the Platform to function correctly, including session authentication, cart management and security tokens. These cannot be disabled without affecting Platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised data about how users interact with the Platform — pages visited, time on site, error events. This data is aggregated and does not identify individual users.
• Functional Cookies: Store your preferences such as language settings, odds format (decimal/fractional) and responsible gambling reminder configurations.
• Marketing Cookies (where consent is given): Used to track referral sources and deliver relevant promotional content. These are only activated where you have provided explicit consent.

You can manage or disable non-essential cookies through your browser's settings or cookie preference centre. Disabling certain cookies may affect the functionality of the Platform. Please note that AQ789 does not control cookies set by third-party service providers that operate under their own privacy policies.

AQ789 does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. We may share your Personal Data with the following categories of recipients, strictly for the purposes described in this Policy:

• KYC & Identity Verification Providers: Third-party services that verify identity documents and perform age checks as part of our compliance obligations.
• Payment Processors: Entities that facilitate deposit and withdrawal transactions. Reference to familiar Pakistani payment methods (such as bank transfers via HBL, UBL, Meezan Bank, Bank Alfalah, or mobile wallets) is made as local context only — we do not claim these providers endorse or support gambling.
• Fraud Prevention & Security Services: Third-party systems that analyse transaction patterns and access behaviour to detect and prevent fraudulent activity.
• Responsible Gambling Monitoring Services: Where integrated, services that assist with player protection monitoring and intervention workflows.
• IT Infrastructure & Hosting Providers: Cloud hosting and data storage partners who process data on our behalf under strict data processing agreements.
• Legal & Regulatory Authorities: Where required by applicable law, court order or regulatory instruction, we may be required to disclose Personal Data to law enforcement agencies or other competent authorities.

All third-party Data Processors are bound by contractual data protection obligations consistent with applicable data protection law and are permitted to use your data only for the specific purpose for which it was shared.

As an internationally operated platform, AQ789 may transfer your Personal Data to countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.

Where we transfer Personal Data internationally, we implement appropriate safeguards including, where applicable, standard contractual clauses, binding corporate rules or other legally recognised transfer mechanisms. We require all recipients of transferred data to maintain adequate security standards.

Users in Pakistan should be aware that data protection laws in Pakistan — most notably the Personal Data Protection Act (PDPA) framework as it develops — may differ from the international standards we apply. AQ789 aims to meet or exceed applicable data protection requirements as they evolve.

We retain your Personal Data for as long as your Account remains active and for a period thereafter as required by our applicable licensing obligations, anti-money laundering (AML) regulations and general legal requirements. Retention periods by data category are as follows:

• Account and KYC Data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in line with standard AML and licensing compliance requirements.
• Transactional Data: Retained for a minimum of five (5) years from the date of the relevant transaction.
• Support and Communication Records: Retained for three (3) years from the date of the last communication, or longer where a dispute or regulatory matter is outstanding.
• Marketing Consent Records: Retained until consent is withdrawn, plus a reasonable period to demonstrate compliance.
• Analytics and Technical Data: Retained in anonymised or aggregated form; identifiable technical data is retained for up to twelve (12) months.

When Personal Data is no longer required for its original purpose and no legal obligation requires its retention, it will be securely deleted or anonymised.

Subject to applicable data protection law, you have the following rights in relation to your Personal Data held by AQ789:

To exercise any of these rights, please contact our Support team via the Help Centre within your Account or by email at the address listed in Section 15. We aim to respond to all data subject requests within thirty (30) calendar days. Complex or multiple requests may require an extension, and we will inform you if that is the case. Identity verification may be required before we act on any request.

AQ789 is an adults-only platform. Access to the Platform is strictly prohibited for any individual under the age of 18, or under the higher minimum age required by the applicable operator or licence jurisdiction.

We do not knowingly collect Personal Data from minors. If we become aware that a minor has registered an Account, we will immediately close that Account, return any deposited funds and securely delete the associated Personal Data as soon as practically possible under applicable retention obligations.

If you believe that a minor may have accessed or registered on AQ789, please contact our Support team immediately so that we may take appropriate action.

When you make a deposit or withdrawal on AQ789, your payment details are processed through our third-party payment processor partners. AQ789 does not store full payment card numbers or sensitive authentication data on its own servers. Payment data is tokenised and handled in accordance with applicable payment security standards.

AQ789 references familiar Pakistani payment methods — such as bank transfers via HBL, UBL, Meezan Bank and Bank Alfalah, and mobile wallet services — as payment context only, to help Pakistani users understand available options. These payment-provider names are used for contextual familiarity only. AQ789 does not claim that Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah or any other Pakistani financial institution endorses, supports or is affiliated with AQ789 or with online gambling.

Pakistan's data protection landscape is evolving, most recently through the Personal Data Protection Act framework. AQ789 monitors applicable legal developments and aims to meet relevant data protection standards for Pakistani users. This Policy does not constitute legal advice, and users are encouraged to seek independent advice regarding their data rights under Pakistani law.

AQ789 implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction or disclosure:

• SSL/TLS Encryption: All data transmitted between your device and the Platform is encrypted using industry-standard Transport Layer Security (TLS).
• Password Hashing: Account passwords are stored using one-way cryptographic hashing algorithms. AQ789 staff cannot view your password in plain text.
• Access Controls: Access to Personal Data is restricted on a need-to-know basis. Staff are trained on data protection obligations and confidentiality requirements.
• Infrastructure Security: Our hosting infrastructure is maintained with regular security patching, vulnerability scanning and intrusion detection monitoring.
• Incident Response: In the event of a data breach that is likely to result in a risk to your rights and freedoms, AQ789 will notify affected users and relevant authorities as required by applicable law.

While we apply strong security standards, no system is entirely immune to security threats. Users are responsible for keeping their own Account credentials secure and for notifying Support immediately if they suspect unauthorised access to their Account.

The AQ789 Platform may contain references to third-party services, technologies or providers in a descriptive or contextual capacity. AQ789 does not include outbound hyperlinks to third-party websites within the Platform's content pages.

Where third-party integrations exist — such as KYC verification tools, analytics systems or payment processing widgets — those third parties operate under their own privacy policies and data processing frameworks. AQ789 is not responsible for the privacy practices of third-party services that operate under separate agreements.

AQ789 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing activities, applicable law, or regulatory requirements.

Where changes are material, we will notify you via email to your registered Account address or through a prominent notice on the Platform prior to the changes taking effect. The date of the most recent update is displayed at the top of this page.

Continued use of the Platform after the effective date of any revised Policy constitutes your acknowledgement of and agreement to the updated terms. We recommend reviewing this Policy periodically to remain informed of how we protect your data.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to raise a concern about our data processing practices, please contact our Data Protection team via:

• Help Centre: Accessible directly from within your Account dashboard.
• Email (plain text only — not a clickable link): [email protected]

Support is available in English, with Urdu-language assistance available where possible. We aim to acknowledge all privacy-related enquiries within five (5) business days and to provide a substantive response within thirty (30) calendar days.

The email address above is provided as plain text only and is not a clickable hyperlink. AQ789 does not accept responsibility for communications sent through unverified channels.