Privacy Policy

This Privacy Policy ("Policy") describes how up786 ("Company", "we", "us", "our"), the operator of the online gaming information platform accessible at up786.cam ("Platform", "Site"), collects, processes, uses, stores, and protects personal information about users ("you", "your") who access or use the Platform.

up786 is an English-language online gaming information platform serving Pakistani users across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar, and beyond. We take your privacy seriously. This Policy is written in plain, accessible English so that every user can clearly understand what data we hold and why.

By accessing, registering on, or using the Platform in any capacity, you acknowledge that you have read this Policy in full and consent to the data practices described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, device identifiers, IP address, payment details, and behavioural data.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "Data Controller" means up786, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of up786 under a written agreement.
• "Cookies" means small text files placed on your device by the Platform to store and retrieve information about your browsing session and preferences.
• "KYC" means Know Your Customer — the identity verification procedures we are required to conduct to comply with anti-money laundering (AML) and responsible gambling obligations.
• "Third Party" means any entity other than you and up786, including payment processors, analytics providers, and regulatory authorities.
• "Sensitive Data" means a category of Personal Data that warrants higher protection, including financial account details and government-issued identity documentation.

We collect Personal Data through several channels — directly from you when you register or use the Platform, automatically through your device and browser, and in limited circumstances from third-party sources. The categories of data we collect are set out below.

3.1 Data You Provide Directly

• Registration Data: Full name, date of birth, email address, username, password (stored in hashed form), and country of residence.
• KYC Documentation: Government-issued photographic identification (e.g., CNIC, passport, driving licence), proof of address, and payment method verification documents where required.
• Financial Data: Payment method details (e.g., references to methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah, BTC/USDT wallet addresses) — note that full payment credentials are processed by our payment processor partners, not stored directly by up786.
• Support Communications: Content of messages, emails, or live chat conversations you initiate with our Support team.
• Responsible Gambling Data: Deposit limits, loss limits, self-exclusion elections, and cooling-off period requests you submit through the Platform.

3.2 Data Collected Automatically

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and language settings.
• Usage Data: Pages visited, features accessed, time spent on each section, bet history, game history, session duration, and navigation paths within the Platform.
• Cookie Data: Session identifiers, preference cookies, and analytics data as described in Section 7.
• Geolocation Data: Approximate location derived from your IP address to support compliance and fraud detection. We do not collect precise GPS coordinates.

3.3 Data from Third-Party Sources

• Identity verification results from licensed KYC and AML screening providers.
• Fraud risk signals from payment processors and industry fraud-prevention networks.
• Self-exclusion register data from applicable responsible gambling schemes, where we are required to cross-reference registrations.

We use your Personal Data only for clearly defined and legitimate purposes. The table below summarises the primary purposes for which we process your data and the corresponding data categories involved.

We do not use your Personal Data for automated profiling that produces legal or similarly significant effects without human oversight, except where expressly required for fraud prevention or AML compliance and subject to appropriate safeguards.

We process your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and up786 — for example, creating your Account, processing financial transactions, and delivering the Services you have requested.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML legislation, KYC requirements, responsible gambling obligations, and lawful requests from competent authorities.
• Legitimate Interests: Processing carried out for our legitimate business interests, including fraud prevention, platform security, service improvement, and analytics, provided these interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent — for example, for marketing communications or the use of non-essential cookies — you may withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

We do not sell your Personal Data. We share data only where necessary, with appropriate safeguards, and strictly on a need-to-know basis. The categories of recipients with whom we may share your data are as follows:

• Payment Processors: Third-party payment service providers who facilitate deposits and withdrawals. These providers handle financial data under their own privacy and security standards. References to payment methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah, and cryptocurrency processors are for user context only — up786 does not claim endorsement or affiliation with any of these providers.
• KYC & AML Providers: Licensed identity verification and anti-money laundering screening services engaged to conduct mandatory checks on our behalf, under binding data processing agreements.
• Technology Partners: Hosting providers, content delivery networks, platform infrastructure providers, and customer support technology vendors who process data solely on our instructions.
• Analytics Providers: Service providers that help us understand Platform usage patterns and improve user experience, using aggregated or pseudonymised data where practicable.
• Regulatory Authorities: Where legally required, we may disclose Personal Data to regulatory, licensing, law enforcement, or financial intelligence authorities. Such disclosures are made strictly in accordance with applicable legal requirements.
• Responsible Gambling Schemes: Where required by the operator's licence jurisdiction, self-exclusion and problem gambling data may be shared with designated responsible gambling bodies.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all of our assets, Personal Data may be transferred as part of that transaction, subject to the incoming entity honouring this Privacy Policy or providing equivalent protections.

All third-party Data Processors engaged by up786 are required to process data only on our documented instructions, maintain appropriate technical and organisational security measures, and comply with applicable data protection obligations.

up786 uses cookies and similar tracking technologies (including local storage objects and pixel tags) to operate the Platform, remember your preferences, and improve our Services. Below is a summary of the cookie categories we use.

You can manage your cookie preferences at any time through the cookie settings panel available on the Platform, or by adjusting your browser settings. Please note that disabling strictly necessary cookies will impair Platform functionality. Withdrawing consent for optional cookies does not affect your Account or access to core Services.

We do not use third-party advertising cookies to build profiles of you for sale to advertisers or to serve behavioural advertising outside the up786 Platform.

We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, and contractual obligations. The key retention periods we apply are as follows:

• Account and Registration Data: Retained for the lifetime of your Account and for a minimum of five (5) years following Account closure, to meet AML record-keeping requirements.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification, as required under applicable AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with standard financial record-keeping obligations.
• Support Communications: Retained for up to three (3) years from the date of the last communication, unless a longer period is required for unresolved disputes or regulatory investigations.
• Analytics and Usage Data: Retained for up to twenty-four (24) months in identifiable form, after which it is anonymised or deleted.
• Cookie Data: Session cookies expire at the end of your browser session. Persistent cookies expire as stated in the cookie settings panel, typically no longer than thirteen (13) months.
• Self-Exclusion Records: Retained for the duration of the exclusion period and for a minimum of five (5) years thereafter to prevent reactivation and to support responsible gambling obligations.

Where retention beyond the periods above is required by a court order, regulatory direction, or ongoing legal proceedings, we will retain the relevant data until such proceedings are concluded.

up786 implements a comprehensive set of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security framework includes:

• Encryption in Transit: All data transmitted between your device and the Platform is encrypted using TLS (Transport Layer Security) protocols.
• Encryption at Rest: Sensitive Personal Data, including KYC documentation and financial records, is stored in encrypted form on our servers.
• Password Security: User passwords are stored using strong, salted cryptographic hashing algorithms. We never store passwords in plain text.
• Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. Staff with access to Personal Data are subject to confidentiality obligations and regular data protection training.
• Security Monitoring: We maintain continuous monitoring systems to detect unusual access patterns, potential intrusions, and data breach indicators.
• Penetration Testing: Our infrastructure undergoes regular independent security assessments and penetration testing.
• Incident Response: We maintain a documented data breach response procedure. In the event of a data breach that is likely to result in a risk to your rights, we will notify affected users and relevant authorities in accordance with applicable legal requirements.

While we take every reasonable precaution to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and for notifying us immediately if you suspect any unauthorised access to your Account.

Depending on your jurisdiction, you may have the following rights in relation to your Personal Data held by up786. We are committed to honouring these rights promptly and without undue restriction.

To exercise any of the above rights, please contact our Support team at [email protected]. We will respond within thirty (30) days of receiving a verified request. In some cases, this period may be extended by a further two months for complex or numerous requests, in which case we will notify you of the extension and the reasons for it.

We may need to verify your identity before processing a rights request to ensure we do not disclose data to, or delete data at the request of, an unauthorised person. This verification step is carried out as quickly as possible and is not intended to create unnecessary barriers.

up786 operates globally and your Personal Data may be transferred to, stored in, or processed in countries other than Pakistan. These countries may have data protection laws that differ from those applicable in your jurisdiction.

Where we transfer Personal Data internationally, we implement appropriate safeguards to ensure that your data receives a level of protection consistent with this Privacy Policy. Such safeguards may include:

• Standard contractual clauses approved by relevant data protection authorities, incorporated into agreements with recipients of your data.
• Transfers to countries or territories that have been deemed to provide an adequate level of data protection by applicable regulatory bodies.
• Binding corporate rules where applicable to intra-group transfers.
• Derogations applicable to specific situations, such as where the transfer is necessary for the performance of a contract between you and up786.

You may request further information about the safeguards applied to international transfers by contacting our Support team. We will provide details of the relevant mechanisms within a reasonable time.

The up786 Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's licence jurisdiction, whichever is greater. We do not knowingly collect Personal Data from individuals under the required minimum age.

We take our obligations regarding underage access extremely seriously. Age verification is conducted as part of the KYC process for all registered users. Where we discover or are notified that we have inadvertently collected Personal Data from a minor, we will:

• Immediately suspend the Account in question.
• Delete all Personal Data associated with the Account as quickly as practicable.
• Return any funds deposited, subject to verification of a lawful recipient.
• Take appropriate steps to prevent further access by the minor.

Parents and guardians who believe a minor has registered on up786 should contact our Support team immediately at [email protected]. We will treat such reports as a priority and act promptly. 18+ only — local laws may restrict gambling.

up786 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will:

• Update the "Last updated" date displayed at the top of this page.
• Where practicable, notify registered users via their registered email address or a prominent notice within the Platform prior to the changes taking effect.
• For significant changes affecting how we use your Personal Data, seek fresh consent where required by applicable law.

Your continued use of the Platform following publication of an updated Privacy Policy constitutes your acknowledgement of, and where applicable your consent to, the updated practices described in the revised Policy. If you do not agree to a material change, you may request Account closure as described in our Terms & Conditions.

We encourage you to review this Privacy Policy periodically. Previous versions of this Policy are available on request from our Support team.

If you have any questions, concerns, or complaints regarding this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 10, please contact our Support team using the details below. All privacy-related correspondence should be submitted in English.

• Live Chat: Available 24/7 directly within the Platform — the fastest way to reach us for general queries.
• Help Centre: Available in-platform with guidance on account settings, privacy preferences, and data rights requests.
• Email: [email protected] — please allow up to 48 hours for a response. For formal data rights requests, please mark your subject line clearly as "Data Rights Request".
• Languages: English and Urdu support are available depending on agent availability.

We are committed to resolving all privacy-related enquiries and complaints promptly and in good faith. If you are not satisfied with our response to a complaint, you may have the right to escalate the matter to the relevant supervisory or regulatory authority in the operator's licence jurisdiction.