Privacy
Policy

01 Introduction

This Privacy Policy ("Policy") describes how p989 ("p989", "we", "us", "our") collects, processes, stores, discloses and protects personal data relating to registered users, visitors and any other individuals ("you", "User") who interact with the p989 platform, website or any associated digital services (collectively, the "Platform").

p989 is committed to respecting your privacy and handling your personal data with care, transparency and in accordance with applicable data-protection law. By accessing or using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with the practices described herein, please discontinue use of the Platform and contact us to request account closure.

02 Definitions

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information that identifies or could reasonably identify a natural person, directly or indirectly, including name, date of birth, identification number, contact details, IP address and financial information.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means p989, the entity that determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means any third-party entity that processes Personal Data on behalf of p989 under a contractual arrangement.
• "KYC" means Know Your Customer — the identity verification process required for regulatory compliance and withdrawal processing.
• "Cookie" means a small text file stored on a User's device by a web browser at the instruction of a website for session management, analytics or preference purposes.
• "Consent" means a freely given, specific, informed and unambiguous indication of the User's agreement to the processing of their Personal Data for a stated purpose.

03 Data We Collect

p989 collects Personal Data across several categories depending on how you interact with the Platform. The table below summarises the main data categories and their sources.

3.1 Data You Are Not Required to Provide

You are not required to provide sensitive categories of Personal Data such as racial or ethnic origin, religious beliefs or health information. If such information is incidentally disclosed to support agents (for example, in the context of a responsible-gambling self-exclusion request citing health reasons), it will be handled with heightened confidentiality and used only for the specific purpose for which it was disclosed.

04 Legal Basis for Processing

Where applicable data-protection law requires p989 to identify a legal basis for processing Personal Data, the following bases apply:

• Contract Performance: Processing necessary to provide the services described in our Terms & Conditions — including account operation, transaction processing, KYC verification and customer support.
• Legal Obligation: Processing required to comply with applicable law, including anti-money laundering (AML) regulations, tax reporting obligations and responses to lawful authority requests.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gambling monitoring and service improvement — provided these interests are not overridden by your privacy rights.
• Consent: Processing for optional marketing communications and non-essential analytical cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

05 How We Use Your Data

p989 uses the Personal Data we collect for the following purposes:

5.1 Platform Operation

• Creating and managing your account, including password recovery and two-factor authentication.
• Processing deposits and withdrawals, including communicating with payment-method providers referenced as contextual options for Pakistani users (such as bank transfers, and payment references including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — used as context only, with no endorsement of gambling activity implied).
• Calculating and crediting bonus funds in accordance with applicable promotion terms.
• Delivering live sports markets covering Pakistan cricket, ICC tournaments, PSL fixtures, football, UFC and other events.

5.2 Identity Verification & Compliance

• Conducting KYC checks as required by our licensing and anti-money laundering obligations.
• Reporting to relevant regulatory and law enforcement authorities where required by applicable law.
• Age verification to ensure the Platform is accessed only by individuals aged 18 or above (or the higher minimum required by applicable jurisdiction).

5.3 Customer Support

• Responding to your queries, complaints and responsible-gambling requests via live chat or email, in English and Urdu where applicable.
• Maintaining records of support interactions for quality-assurance and dispute-resolution purposes.

5.4 Platform Improvement & Analytics

• Analysing aggregated, anonymised usage patterns to improve site performance, navigation and game-lobby organisation.
• Testing new features and evaluating platform stability across different devices and connection speeds commonly used in Pakistan.

5.5 Marketing Communications

Where you have provided consent, p989 may send you promotional emails or push notifications about new offers, bonuses and platform updates. You may withdraw this consent at any time by using the unsubscribe link in any marketing email or by contacting support. Withdrawing marketing consent does not affect your access to the Platform or to non-marketing service communications.

06 Data Sharing & Disclosure

p989 does not sell, rent or trade your Personal Data to third parties for their independent marketing purposes. Personal Data is shared only in the following limited circumstances:

• Payment Processors: Necessary transaction data is shared with payment-processing partners to facilitate deposits and withdrawals. These partners act as Data Processors under contractual data-protection agreements.
• KYC & Identity Verification Partners: Identity documents and verification data are transmitted to third-party KYC providers to fulfil regulatory identity-verification requirements.
• Fraud Prevention & AML Services: Transaction and behavioural data may be shared with fraud-prevention and anti-money laundering screening providers to detect suspicious activity.
• Legal & Regulatory Authorities: p989 will disclose Personal Data to competent authorities — including law enforcement, regulatory bodies or courts — when required to do so by applicable law, court order or regulatory demand.
• Business Successors: In the event of a merger, acquisition or sale of all or part of p989's business, Personal Data may be transferred to the acquiring entity subject to equivalent data-protection safeguards.

07 Data Retention

p989 retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, tax or accounting obligations. Indicative retention periods are set out below:

• Account and Transaction Data: Retained for a minimum of five years following account closure or the last account transaction, as typically required by anti-money laundering regulations.
• KYC Documentation: Retained for a minimum of five years following the completion of the business relationship, unless a longer period is required by applicable law.
• Support Communications: Retained for three years from the date of the last interaction, unless required for an ongoing dispute or legal proceeding.
• Marketing Consent Records: Retained until consent is withdrawn, plus a period of three years for audit purposes.
• Technical and Analytical Data: Retained in anonymised or aggregated form for up to two years from collection.

Following the expiry of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised.

08 Security Measures

p989 implements appropriate technical and organisational measures to protect Personal Data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your browser or device and the p989 Platform.
• Encryption of sensitive data at rest, including KYC documents and financial records.
• Two-factor authentication (2FA) available to all registered users and mandatory for certain account operations.
• Role-based access controls limiting employee access to Personal Data on a need-to-know basis.
• Regular security assessments and vulnerability testing of the Platform infrastructure.
• Incident response procedures to detect, report and respond to suspected data breaches within required regulatory timeframes.

09 Your Rights

Subject to applicable data-protection law, you have the following rights in relation to the Personal Data we hold about you:

To exercise any of the rights above, please contact p989 at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within two business days and respond substantively within 30 calendar days. We may request additional information to verify your identity before fulfilling a rights request.

10 Cookies & Tracking

p989 uses cookies and similar tracking technologies to operate the Platform, remember your preferences and understand how users interact with the site. The following cookie categories are used:

• Essential Cookies: Required for the Platform to function. These include session authentication cookies, security tokens and shopping-cart functionality equivalents for the Cashier. These cookies cannot be disabled without rendering the Platform non-functional.
• Analytical Cookies: Used to collect anonymised data on page views, navigation paths, device types and connection characteristics. This data helps p989 identify performance issues and optimise the experience for users across Pakistan's varied network conditions. These cookies are optional.
• Preference Cookies: Store your language, display and notification settings across sessions. Optional but improve your experience.

You can manage or disable optional cookies at any time through your browser settings. Note that disabling certain cookies may affect the functionality of parts of the Platform. p989 does not use third-party advertising or retargeting cookies.

11 Children's Privacy

p989 is strictly an adults-only platform. The Platform is not directed at, and does not knowingly collect Personal Data from, any individual under the age of 18 — or the higher minimum age required by applicable law or the operator's licence jurisdiction. If we become aware that Personal Data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

12 International Transfers

p989 may transfer Personal Data to processors and sub-processors located outside Pakistan or the jurisdiction in which p989 is licensed. Where such transfers occur, p989 ensures that appropriate safeguards are in place — such as standard contractual clauses or adequacy decisions — to protect Personal Data in accordance with applicable data-protection standards.

By using the Platform, you acknowledge that your Personal Data may be processed in countries outside Pakistan whose data-protection laws may differ from those applicable in Pakistan. p989 takes steps to ensure that cross-border data transfers are made in compliance with applicable law and with equivalent privacy protections in place.

13 Policy Amendments

p989 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, platform features or business practices. Material changes will be communicated to registered Users via a notification on the Platform or by email to the registered address at least 14 days before taking effect, where practicable.

Your continued use of the Platform following the publication of an updated Policy constitutes acceptance of the revised terms. The date of the most recent revision is displayed prominently at the top of this document. We encourage you to review this Policy periodically.

14 Contact Us

If you have questions, concerns or formal complaints regarding this Privacy Policy or p989's data-processing practices, please contact our support team. All data-related enquiries should be submitted in writing in English.

If you are not satisfied with our response to a formal complaint, you may have the right to lodge a complaint with a competent supervisory authority in the jurisdiction applicable to you. p989 is not regulated by any Pakistani authority and cannot advise on the specific supervisory bodies available to Pakistani users — please seek independent legal advice if required.