q89com
Privacy Policy

This Privacy Policy has been prepared to give users a clear and honest picture of how q89com handles personal data. We are an online casino and sports betting platform that serves Pakistani users, and our data practices reflect both our international gaming licence obligations and a genuine commitment to treating user data with care and respect.

Privacy at q89com is not an afterthought. Pakistani users share sensitive personal information with us when they register, complete KYC verification using their CNIC, deposit via JazzCash or EasyPaisa, and engage with our customer support team. We understand the trust that this involves, and we operate accordingly. Data collected by q89com is used only for the purposes described in this Policy — it is not sold to third parties for marketing purposes and is not shared beyond what is necessary for the operation of the Platform and compliance with our regulatory obligations.

q89com acts as the data controller in respect of personal data collected through the Platform. As data controller, q89com determines the purposes and means by which personal data is processed. For all data protection enquiries, correction requests, deletion requests, or complaints related to your personal data, please contact q89com using the details provided in Section 16 of this Policy.

Where q89com engages third-party service providers to process personal data on its behalf (for example, payment processors, identity verification services, or fraud detection partners), those providers act as data processors and are contractually bound to process data only in accordance with q89com's instructions and this Policy.

q89com collects the following categories of personal data from users of the Platform:

q89com collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting support, or responding to surveys.
• Automated technical collection: Technical and usage data collected automatically through your use of the Platform, including cookies, server logs, and session tracking technologies.
• Third-party identity verification: Data received from identity verification service providers when you submit CNIC documents for KYC review.
• Payment processors: Transaction reference data received from JazzCash, EasyPaisa, Raast, 1LINK, HBL, UBL, Meezan Bank, and card payment processors when you make deposits or receive withdrawals.
• Fraud prevention and anti-money laundering partners: Risk-related signals received from third-party fraud detection services that help q89com identify suspicious account activity.

q89com does not purchase personal data lists from third-party data brokers or marketing companies. All personal data held by q89com relates to individuals who have directly interacted with the Platform or whose data has been received through the specific third-party service channels described above.

q89com processes your personal data for the following purposes and on the following legal bases:

q89com will not process your personal data for any purpose other than those listed above without obtaining your explicit consent or unless otherwise permitted or required by applicable law.

q89com does not sell your personal data to any third party. We do not share your personal information with third-party marketers. We disclose personal data only in the following circumstances:

• Payment processors: Transaction data shared with JazzCash, EasyPaisa, Raast, 1LINK, HBL, UBL, Meezan Bank, Visa, and Mastercard solely for the purpose of processing your deposit and withdrawal transactions.
• Identity verification providers: CNIC documents and personal identification data shared with our approved KYC and AML verification partners for the purpose of age and identity verification as required by our gaming licence.
• Fraud prevention services: Technical and behavioural data shared with fraud detection partners to identify account abuse, bonus abuse, and money laundering risks.
• Casino game providers: Limited session data shared with certified game providers to enable delivery of casino game content. Game providers receive only the data necessary to run the game session — they do not receive CNIC data or full financial records.
• Regulatory authorities: Personal data, account records, and transaction data disclosed to gaming regulators, financial intelligence units, or law enforcement authorities when required by law or by our international gaming licence obligations.
• Legal proceedings: Personal data may be disclosed to courts, legal advisors, or opposing parties where required in connection with legal proceedings to which q89com is a party.
• Business transfers: In the event of a merger, acquisition, or sale of q89com's business or assets, user personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

q89com's Platform infrastructure and some third-party service providers operate outside Pakistan. As a result, personal data submitted through q89com may be transferred to, stored, and processed in countries outside Pakistan. Where such transfers occur, q89com takes appropriate steps to ensure that your personal data continues to be protected to a standard at least equivalent to that described in this Policy.

Protective measures for international transfers include contractual data processing agreements with third-party processors that impose data protection obligations, use of service providers who maintain internationally recognised security certifications, and limiting the scope of data transferred to the minimum necessary for the relevant processing purpose.

q89com retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the duration of the contractual relationship (account registration) and thereafter as required to comply with legal, regulatory, and contractual obligations. The following indicative retention periods apply:

Where data is retained beyond the duration of your account relationship, it is held in a restricted format and accessed only where legally required. Data held solely for analytics purposes is anonymised before retention beyond the account relationship period.

q89com uses cookies and similar tracking technologies to operate the Platform, maintain session security, remember user preferences, and analyse Platform performance. A cookie is a small data file stored on your device by your browser when you visit the Platform.

The following categories of cookies are used by q89com:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and anti-fraud signals. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, game lobby display preferences, and logged-in status. Disabling these may affect your experience.
• Analytics Cookies: Used to understand how users interact with the Platform — which pages are visited most, where users encounter friction, and how Platform performance can be improved. Data collected is aggregated and anonymised where possible.
• Session Replay / Heatmap Cookies: Used by q89com's internal product team to review Platform usability. These do not capture passwords, CNIC data, or payment credentials.

Most browsers allow you to control or disable cookies through browser settings. Note that disabling strictly necessary cookies will affect your ability to log in to and use the q89com Platform. q89com does not use advertising or third-party behavioural profiling cookies.

Subject to applicable law and the terms of q89com's gaming licence obligations, you have the following rights in respect of your personal data held by q89com:

• Right of Access: You may request a copy of the personal data q89com holds about you. q89com will respond to verified access requests within 30 days.
• Right to Rectification: If your personal data is inaccurate or incomplete, you may request that it be corrected. Note that corrections to KYC documents require submission of updated verified documentation.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may request deletion of your personal data. This right is limited where q89com is required to retain data by law or gaming licence obligation (see Section 8).
• Right to Restriction of Processing: You may request that q89com restrict processing of your personal data in certain circumstances, for example while a correction request is pending.
• Right to Data Portability: You may request a structured, machine-readable copy of personal data you have provided to q89com, where processing is based on your consent or a contractual relationship.
• Right to Object: You may object to processing based on q89com's legitimate interests. You may also withdraw consent to marketing communications at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, contact q89com support using the details in Section 16. q89com may require you to verify your identity before processing any data rights request. Requests will be handled within 30 days; complex requests may require up to 60 days with prior notification to you.

q89com implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the q89com Platform.
• Encrypted storage of sensitive personal data including CNIC information and payment details at rest.
• Two-factor authentication (2FA) available on all user accounts as an additional layer of login security.
• Role-based access controls within q89com's internal systems, ensuring that staff members access only the data necessary for their specific role.
• Regular security audits and penetration testing of the Platform infrastructure.
• Fraud monitoring systems that flag unusual account activity, login anomalies, and suspicious transaction patterns in real time.

Despite these measures, no data transmission over the internet is entirely secure. q89com cannot guarantee absolute security of data in transit. In the event of a data breach that is likely to result in a risk to your rights and freedoms, q89com will notify affected users and relevant regulatory authorities in accordance with applicable legal requirements.

You are responsible for maintaining the security of your account login credentials. Do not share your password with any third party. Use a strong, unique password for your q89com account. Enable 2FA where available.

q89com's responsible gaming obligations under our international gaming licence require us to monitor user behaviour for signs of problem gambling. This involves processing certain personal and transactional data for purposes that go beyond standard account operation. Specifically:

• q89com may analyse your betting patterns, deposit frequency, session duration, and account activity to identify potential indicators of problem gambling behaviour.
• Where such indicators are identified, q89com may contact you to offer responsible gaming support, apply account-level restrictions, or in serious cases, apply protective limits without prior request from you.
• Self-exclusion data — including the fact of your exclusion and its duration — is retained permanently to prevent re-registration during the exclusion period. This is a regulatory requirement and cannot be overridden by a data erasure request.
• Age verification data, including CNIC documents, is retained for the full period described in Section 8 as proof of compliance with q89com's 21+ age restriction policy.

This processing is conducted on the basis of q89com's legal obligations under its gaming licence and its legitimate interest in preventing harm to users. For full details of responsible gaming tools available to q89com users, please visit our Responsible Gaming page.

The q89com Platform may contain references to or integration with third-party services, including licensed game providers who deliver casino game content within the Platform environment. While q89com selects its third-party service providers carefully and requires them to maintain appropriate data protection standards, q89com is not responsible for the privacy practices of independently operated third-party services.

Casino game content delivered by third-party providers within the q89com Platform is subject to the data practices of those providers in respect of game session data. q89com ensures through its contractual agreements that game providers are prohibited from using game session data for any purpose other than delivering the game experience and fraud prevention.

q89com does not integrate with social media platforms for data sharing purposes and does not use social login functionality that would result in social media platforms receiving data about your q89com account activity.

q89com operates a strict 21+ age policy. The Platform is not directed at, and is not intended for use by, any person under the age of 21. q89com does not knowingly collect personal data from anyone under the age of 21.

CNIC-based age verification is mandatory before any withdrawal is processed, and q89com reserves the right to request age verification at any point during the account lifecycle. Where q89com discovers or reasonably suspects that an account is held by a person under 21, the account will be immediately suspended, all balances frozen pending review, and any net winnings forfeited. This is a non-negotiable regulatory requirement under q89com's international gaming licence.

q89com reserves the right to update or amend this Privacy Policy at any time. When material changes are made — changes that affect how your personal data is collected, used, shared, or protected — q89com will notify registered users via the email address on record or via a prominent in-Platform notification prior to the changes taking effect.

The effective date at the top of this Policy indicates when it was last reviewed and updated. We recommend that you review this Policy periodically to stay informed of how q89com handles your personal data. Your continued use of the Platform following notification of a material amendment constitutes your acceptance of the revised Policy.

For all privacy-related enquiries, including data access requests, correction requests, deletion requests, consent withdrawals, or complaints about how q89com has handled your personal data, please contact us through the following channels:

• Email: [email protected] — please use the subject line "Privacy Enquiry" and include your registered mobile number so we can verify your identity efficiently.
• Live Chat: Available 24/7 in both Urdu and English directly on the q89com Platform. For privacy requests that require identity verification, our live chat agents will guide you through the process.

q89com aims to acknowledge all privacy-related requests within 48 hours and to resolve them within 30 days. Complex requests, particularly those involving data subject access or erasure of long-standing accounts, may take up to 60 days, in which case q89com will provide you with a written explanation of the delay and a revised timeline.

If you are not satisfied with q89com's response to a privacy complaint, you may escalate the matter to the relevant regulatory authority under q89com's gaming licence jurisdiction. Details of the relevant authority are available on request.