up786 Privacy Policy

01 Introduction

up786 is Pakistan's premier online casino and sports betting platform, built from the ground up for Pakistani players. We understand that when you share personal information with us — whether during registration, identity verification, or a JazzCash deposit — you are placing your trust in us to handle that information responsibly. This Privacy Policy is our formal commitment to honour that trust.

This Policy applies to all personal data collected through the up786 website at https://up786.bio, including any mobile-optimised versions of the site, customer support communications, and marketing interactions. It covers data collected from registered players, prospective players, and all other visitors to the Platform.

We have written this Policy in clear, straightforward English — the kind you can actually read and understand — because we believe privacy documentation should be accessible to every player in Karachi, Lahore, Islamabad, Faisalabad, and across Pakistan, not just legal professionals.

02 Data Controller

For the purposes of applicable data protection legislation, up786 acts as the Data Controller for all personal data collected through the Platform. As Data Controller, up786 determines the purposes for which and the means by which personal data is processed. Where up786 engages third-party service providers to process data on its behalf (for example, payment processors or identity verification providers), those parties act as Data Processors under binding contractual terms that restrict their use of your data strictly to the services they provide to up786.

If you have any questions or concerns about how up786 processes your personal data, or wish to exercise any of your data rights, you may contact our Data Protection team directly via the contact details provided in Section 15 of this Policy.

03 Data We Collect

up786 collects the following categories of personal data from players and Platform visitors:

3.1 Identity Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (for mandatory 21+ age verification)
• CNIC (Computerised National Identity Card) number or passport number
• A copy of the front and back of your CNIC or passport where required for KYC verification
• Selfie or live photograph submitted for identity confirmation purposes

3.2 Contact Data

• Pakistani mobile phone number (used as your primary account identifier)
• Email address registered to your up786 account
• Residential address (city, province, postal code) for verification purposes

3.3 Financial Data

• JazzCash or EasyPaisa mobile wallet number linked to your account for deposits and withdrawals
• Bank account details (HBL, UBL, Meezan Bank, or other) where bank transfer is your chosen payment method
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment references
• Proof of source of funds documentation where requested under AML compliance procedures

3.4 Technical & Usage Data

• IP address and approximate geolocation derived from IP at the time of access
• Device type, operating system, browser type and version
• Session logs including login times, session duration, and logout events
• Game history: games played, stakes placed, outcomes, and winnings
• Betting history: markets accessed, odds accepted, results, and settlement records
• Clickstream data and in-platform navigation behaviour for performance analytics purposes

3.5 Communications Data

• Records of all live chat conversations with up786 support agents
• Email correspondence sent to or received from [email protected]
• Responses to surveys, feedback requests, or promotional competitions where you have voluntarily participated

04 How We Collect Your Data

up786 collects personal data through the following channels:

• Direct Registration: Data you provide when creating your up786 account, including your name, mobile number, email address, and date of birth.
• Identity Verification: Documents and photographs submitted during the KYC/AML verification process mandated for all accounts.
• Deposits & Withdrawals: Financial data captured automatically when you initiate a transaction via JazzCash, EasyPaisa, or bank transfer.
• Platform Use: Technical and usage data collected automatically by our servers and analytics infrastructure whenever you access and interact with up786.
• Cookies & Tracking Technologies: Session and analytics data collected via browser cookies and similar technologies as described in Section 10.
• Support Interactions: Communications data captured when you contact up786 via live chat, email, or any other support channel.
• Third-Party Verification Providers: Identity and fraud-check data returned by our third-party KYC and AML service providers where we engage them to assist in verifying your identity.

05 How We Use Your Data

up786 processes your personal data for the following purposes:

up786 does not use your personal data for automated decision-making that produces legal or similarly significant effects on you without human oversight. Where automated tools flag an account for review (for example, during fraud detection), a qualified member of our compliance team reviews the matter before any consequential action is taken against your account.

06 Legal Basis for Processing

up786 processes your personal data under the following legal bases:

• Contractual Necessity: Processing required to fulfil our obligations under the account agreement with you — including registration, payment processing, and customer support.
• Legal Obligation: Processing required to comply with applicable anti-money laundering laws, KYC regulations, and other binding compliance obligations.
• Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and internal analytics — where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and optional analytics cookies, where you have provided explicit, freely given, and withdrawable consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

07 Data Sharing & Third Parties

up786 does not sell, rent, or trade your personal data. We share data only where strictly necessary and only with the following categories of recipients, each bound by data processing agreements or equivalent safeguards:

• Payment Processors: JazzCash, EasyPaisa, Raast, 1LINK, HBL, UBL, Meezan Bank, and Cash OTC — solely for the purpose of processing your deposit or withdrawal transaction.
• Identity Verification Providers: Third-party KYC and AML service providers engaged to verify your CNIC, confirm your age, and screen your details against applicable watchlists in compliance with our regulatory obligations.
• Game Providers: Licensed game software providers whose games are integrated into the up786 platform. Game outcome data is shared with providers only to the extent necessary for game function and audit purposes.
• Cloud & Infrastructure Providers: Secure cloud hosting and data storage providers who process data strictly on our instructions under binding data processing agreements.
• Regulatory Authorities: Government bodies, law enforcement agencies, or financial intelligence units where up786 is legally compelled to disclose data — for example, under a valid court order or AML reporting obligation.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by up786, all of whom are bound by professional confidentiality obligations.

08 Data Retention

up786 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply as a general guide:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction and Financial Data: Retained for a minimum of five (5) years from the date of the relevant transaction, in line with financial compliance obligations.
• Game and Betting History: Retained for a minimum of two (2) years from the date of the relevant gaming session, for dispute resolution and audit purposes.
• Support Communications: Retained for two (2) years from the date of the interaction, or longer if the communication relates to an ongoing dispute or compliance matter.
• Marketing Consent Records: Retained until you withdraw consent, and for one (1) year thereafter as evidence of the consent having been given and withdrawn.
• Technical and Usage Data: Retained in aggregate, anonymised form for analytics purposes for up to three (3) years.

When data is no longer required and no legal obligation requires its further retention, up786 securely deletes or anonymises it in a manner that prevents reconstruction of the original personal data.

09 Data Security

up786 implements a comprehensive, layered data security framework to protect your personal information against unauthorised access, loss, alteration, or disclosure. Our security measures include:

• TLS 1.3 Encryption: All data transmitted between your browser or device and our servers is encrypted using Transport Layer Security version 1.3 — the current industry gold standard.
• AES-256 Encryption at Rest: All personal and financial data stored in our databases is encrypted at rest using Advanced Encryption Standard 256-bit keys.
• Access Controls: Personal data is accessible only to up786 staff members who require it to perform their job functions. Access is governed by role-based permissions, multi-factor authentication, and comprehensive audit logging.
• Regular Security Audits: up786 undergoes regular independent security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response Plan: up786 maintains a documented data breach incident response plan. In the event of a breach affecting your personal data, we will notify you within 72 hours as described in the introduction to this Policy.

10 Cookies & Tracking Technologies

up786 uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device by your browser when you visit a website. We use cookies for the following purposes:

10.1 Essential Cookies

These cookies are strictly necessary for the Platform to function. They maintain your login session, remember your language preference, and enable secure navigation between pages. Essential cookies cannot be disabled without breaking core Platform functionality. No consent is required for their use.

10.2 Performance & Analytics Cookies

These cookies collect anonymised information about how visitors use the Platform — such as which pages are visited most frequently, where users drop off, and how long sessions last. This data helps us improve Platform performance and user experience. We use first-party analytics only; we do not use Google Analytics or other third-party analytics services that transmit your data to external advertising platforms.

10.3 Functional Cookies

These cookies remember choices you make on the Platform — such as your preferred display settings or notification preferences — so that you do not need to reset them every visit. They are not essential to basic functionality but improve your overall experience.

10.4 What We Do NOT Use

up786 does not use advertising or targeting cookies. We do not deploy third-party cookies that track your behaviour across other websites for the purpose of building advertising profiles or retargeting. You will never see up786 ads following you across the internet as a result of data collected during your time on our Platform.

You can manage or disable non-essential cookies at any time through your browser settings. Note that disabling essential cookies will prevent you from logging into your account or using key Platform features. For Chrome, Firefox, Safari, and Edge, cookie management options are found under Settings > Privacy & Security.

11 Your Data Rights

As a player on up786, you hold the following rights with respect to your personal data. To exercise any of these rights, please contact us via the details in Section 15. We will respond to all valid requests within 30 calendar days.

• Right of Access: You have the right to request a copy of all personal data up786 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you. For basic account details, you can update these directly from your account settings panel.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent, or where processing is unlawful. This right is subject to our legal obligation to retain certain data for AML compliance as described in Section 8.
• Right to Restriction: You have the right to request that we restrict the processing of your data in certain circumstances — for example, while you contest its accuracy or while an objection is under consideration.
• Right to Data Portability: You have the right to receive a copy of data you have provided to us in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller.
• Right to Object: You have the right to object to processing of your personal data carried out on the basis of legitimate interests. Where you object, up786 must cease that processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

12 Minors & Age Restriction

The up786 Platform is strictly intended for individuals aged 21 years and above. up786 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account, void all gaming activity, and securely delete the data in question.

Parents and guardians in Pakistan are strongly encouraged to use parental control software to prevent minors from accessing online gaming platforms. If you believe a minor in your care has registered an account on up786, please contact us immediately at [email protected] so that we can take swift action.

13 International Data Transfers

up786 may store or process your personal data on servers located outside of Pakistan — for example, in the jurisdiction where up786's cloud infrastructure or international gaming compliance framework operates. Where such transfers occur, up786 ensures that appropriate safeguards are in place to provide a level of protection for your personal data equivalent to that required under applicable data protection standards.

Safeguards used for international transfers include binding contractual clauses with data processors, encryption of all transferred data in transit and at rest, and access controls that restrict processing to authorised personnel only. up786 does not transfer data to jurisdictions with inadequate data protection frameworks without the express contractual protections described above.

14 Changes to This Privacy Policy

up786 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. When we make material changes — meaning changes that affect your rights or how your data is fundamentally used — we will notify you by email to your registered address and by displaying a prominent notice on the Platform at least seven (7) days before the changes take effect.

Minor updates, such as clarifications of existing language or corrections of typographical errors, may be made without advance notice. The "Last Reviewed" date at the top of this Policy will always reflect when the most recent update was made. We encourage you to review this Policy periodically to stay informed about how up786 is protecting your data.

Continued use of the up786 Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with a revised Policy, you should close your account before the updated Policy takes effect.

15 Contact Us

If you have any questions about this Privacy Policy, wish to exercise a data right, or have a concern about how up786 is handling your personal data, please reach out to us through any of the following channels:

• Live Chat: Available 24/7 directly from the Platform — Urdu & English agents, under 5-minute response time. This is the fastest route for any privacy query.
• Support Email: [email protected] — use subject line "Privacy Enquiry" for data-related matters. We respond to all emails within 48 hours during normal operating conditions.
• Formal Data Rights Requests: Email [email protected] with subject line "Data Rights Request". Include your registered mobile number and the nature of your request. We will action valid requests within 30 calendar days.

Whether you are writing from Karachi, Lahore, Islamabad, Peshawar, or anywhere else across Pakistan — our team speaks your language and is here to help. Your privacy matters to us, and we take every enquiry seriously.