cr789 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how cr789 ("the Company", "we", "us", "our") collects, uses, stores, shares, and protects the personal data of individuals ("Player", "User", "you") who access or use the cr789 platform available at cr789.pro, including all associated subdomains and mobile interfaces ("the Platform").

cr789 is committed to handling your personal data responsibly, transparently, and in compliance with applicable data protection laws and international gaming regulatory standards. We have designed this Policy to be plain and readable — not to obscure how we handle your data, but to give you genuine clarity on our practices.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and cr789.

2 Data Controller

For the purposes of applicable data protection legislation, cr789 acts as the data controller in respect of the personal data it collects from players accessing the Platform. As data controller, cr789 is responsible for determining the purposes and means by which your personal data is processed.

If you have any questions about this Policy, wish to exercise your data rights, or need to report a data concern, you may contact our Data Protection team directly at:

• Email: [email protected] (subject line: "Data Privacy Request")
• Response Time: We aim to acknowledge all data-related enquiries within 48 hours and provide a substantive response within 30 calendar days.

3 Data We Collect

cr789 collects the following categories of personal data from players. We collect only what is necessary for the defined purpose associated with each category:

cr789 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or biometric data beyond what is present on a submitted CNIC document.

4 How We Collect Your Data

cr789 collects personal data through the following channels:

• Direct Collection: Data you provide when registering a cr789 account, completing KYC verification, making a deposit or withdrawal, contacting our support team, or completing any form on the Platform.
• Automated Collection: Technical and usage data collected automatically through cookies, web beacons, log files, and similar tracking technologies when you access and interact with the cr789 Platform.
• Third-Party Sources: Identity verification data returned by our KYC partner services; fraud risk scores from payment processor fraud prevention systems; and publicly available information used to verify the accuracy of data you have provided.
• Payment Providers: Transaction confirmation data from JazzCash, EasyPaisa, and banking partners, used to match deposits and withdrawals to your cr789 account.

5 How We Use Your Data

cr789 uses your personal data for the following purposes:

• Account Administration: Creating and maintaining your cr789 account, verifying your identity and age, and managing your account preferences and settings.
• Platform Delivery: Processing deposits and withdrawals in PKR, delivering gaming content, and ensuring the technical performance and availability of the cr789 Platform.
• Regulatory Compliance: Fulfilling our obligations under applicable anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and gaming licence conditions, including retaining records as required by law.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent transactions, duplicate accounts, bonus abuse, and unauthorised access to cr789 accounts.
• Responsible Gaming: Monitoring player behaviour patterns to identify potential problem gambling indicators and applying responsible gaming interventions, including self-exclusion, deposit limit enforcement, and mandatory cooling-off periods.
• Customer Support: Responding to your enquiries, resolving disputes, and investigating complaints relating to your cr789 account or gaming experience.
• Platform Improvement: Analysing aggregated usage data to improve the cr789 Platform's features, performance, and user experience for Pakistani players.
• Direct Marketing: Sending you promotional offers, bonus notifications, and cr789 news, but only where you have provided your explicit consent to receive such communications. You may withdraw this consent at any time.

6 Legal Basis for Processing

cr789 processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and cr789 — including account creation, payment processing, and game delivery — is carried out on the basis that it is necessary to fulfil our contractual obligations to you.
• Legal Obligation: Processing required to comply with our legal and regulatory obligations — including KYC verification, AML transaction monitoring, and record retention — is carried out on the basis of legal obligation.
• Legitimate Interests: Processing for fraud prevention, platform security, duplicate account detection, and responsible gaming monitoring is carried out on the basis of cr789's legitimate interests in operating a secure, fair, and legally compliant gaming platform, provided those interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications is carried out solely on the basis of your explicit, freely given consent. You may withdraw this consent at any time by contacting cr789 support or using the unsubscribe link in any marketing email.

7 Data Sharing & Disclosure

cr789 does not sell, rent, or otherwise commercialise your personal data. We share your data only in the following circumstances, and only to the minimum extent necessary:

• KYC & Identity Verification Partners: We share identity documents (CNIC, passport) with our regulated third-party KYC verification service providers to complete the age and identity verification process required before withdrawals can be processed.
• Payment Processors: We share the financial data necessary to execute your requested transactions with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, MCB, and other payment partners. These providers process your data under their own privacy policies and regulatory obligations.
• Game Software Providers: We share a pseudonymised player identifier (not your full personal details) with our game suppliers to facilitate game delivery, RNG certification audits, and game-level dispute resolution.
• Fraud Prevention Services: We share technical data (IP addresses, device fingerprints, transaction patterns) with fraud prevention and AML screening services used to protect the integrity of the cr789 Platform.
• Law Enforcement & Regulators: We will disclose your personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where we are legally required to do so, or where we reasonably believe disclosure is necessary to prevent fraud, money laundering, or other criminal activity.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of cr789's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

8 International Data Transfers

cr789 operates as an internationally licensed gaming platform, which means your personal data may be processed in countries outside Pakistan where our service providers, data centres, or affiliated entities are located. When we transfer your personal data internationally, we take the following steps to ensure it remains adequately protected:

• We only transfer data to service providers located in jurisdictions that maintain adequate data protection standards as recognised by international gaming regulatory frameworks.
• Where transfers are made to service providers in jurisdictions without a formal adequacy determination, we implement contractual safeguards — including standard data protection clauses — to ensure an equivalent level of protection is applied to your data.
• All third-party service providers who receive cr789 player data are required to sign data processing agreements that bind them to confidentiality, security, and purpose-limitation obligations consistent with this Policy.

9 Data Retention

cr789 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or for as long as is required by applicable law, gaming regulatory obligations, or AML record-keeping requirements. The following general retention periods apply:

• Active Account Data: Retained for the duration of your active cr789 account, plus five years following account closure, to comply with AML and gaming regulatory record-keeping requirements.
• KYC Documents: Retained for a minimum of five years following the completion of KYC verification, in accordance with AML regulatory requirements applicable to internationally licensed gaming operators.
• Transaction Records: Retained for a minimum of five years from the date of each transaction, for AML compliance and dispute resolution purposes.
• Marketing Consent Records: Retained for three years from the date consent was given, or until consent is withdrawn, whichever occurs first.
• Support Communications: Retained for three years from the date of the last communication in a support thread, for dispute resolution and quality assurance purposes.
• Technical & Usage Logs: Retained for twelve months from the date of collection, after which they are anonymised or deleted.

Once the applicable retention period has expired, cr789 will securely delete or irreversibly anonymise the relevant personal data in accordance with our data destruction procedures.

10 Cookies & Tracking Technologies

cr789 uses cookies and similar tracking technologies on the Platform to deliver a functional, secure, and personalised gaming experience. The following categories of cookies are used:

• Essential Cookies: Required for the Platform to function. These cookies manage your cr789 login session, maintain your account state across pages, and enable secure payment workflows. These cookies cannot be disabled without preventing you from using the Platform.
• Analytics Cookies: Used to collect anonymised data about how players navigate and use the cr789 Platform, helping us identify popular features, diagnose technical issues, and improve overall performance. This data is aggregated and does not identify you personally.
• Fraud Prevention Cookies: Used to generate a device fingerprint that helps us detect duplicate account registrations, identify bots, and prevent fraudulent transactions.
• Preference Cookies: Used to remember your language preferences, display settings, and responsible gaming configuration choices across sessions.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may impair the functionality of the cr789 Platform, including the ability to maintain a login session or process transactions.

11 Your Data Rights

As a cr789 player, you hold the following rights in respect of your personal data. To exercise any of these rights, contact our Data Protection team at [email protected] with the subject line "Data Privacy Request":

• Right of Access: You have the right to request a copy of all personal data that cr789 holds about you, along with information about how it is being used and with whom it has been shared.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held in your cr789 account. Minor corrections (such as contact details) can often be made directly through your account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where you believe the data has been processed unlawfully. This right is subject to our legal obligation to retain certain records for AML and regulatory compliance purposes.
• Right to Restriction: You have the right to request that cr789 restrict the processing of your personal data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to have it transferred to another service provider where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data where that processing is based on cr789's legitimate interests. You also have an absolute right to object to the use of your data for direct marketing at any time.
• Right to Withdraw Consent: Where cr789 processes your data on the basis of your consent (e.g. for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

12 Security Measures

cr789 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: All data transmitted between your device and cr789 servers is encrypted using 256-bit SSL/TLS encryption. Sensitive data fields in our database, including CNIC numbers and payment account identifiers, are encrypted at rest using AES-256.
• Access Controls: Personal data is accessible only to cr789 staff members who require it to perform their specific role. Access is granted on a least-privilege basis and is logged and audited regularly.
• Two-Factor Authentication: Administrative access to cr789's internal systems requires two-factor authentication. We also offer 2FA to players to protect their cr789 accounts.
• Penetration Testing: cr789's platform and infrastructure undergoes regular penetration testing and security audits conducted by qualified third-party security professionals.
• Incident Response: cr789 maintains a documented data breach response procedure. In the event of a data breach that poses a risk to your rights and freedoms, we will notify you without undue delay and take immediate remediation steps.

While cr789 maintains robust security controls, no online platform can guarantee absolute security. You also play an important role in protecting your account by using a strong, unique password and enabling two-factor authentication on your cr789 account.

13 Children & Minors

The cr789 Platform is strictly intended for individuals aged 21 years and above. cr789 does not knowingly collect, process, or retain personal data from any person under the age of 21.

cr789 implements multiple layers of age verification — including CNIC verification and automated age-check tools — to prevent minors from registering accounts. Any account found to have been created by a person under the age of 21 will be immediately closed, and any personal data associated with that account will be deleted in accordance with our data destruction procedures, subject only to minimum legal retention requirements.

If you believe that a minor has accessed the cr789 Platform or that cr789 has inadvertently collected personal data from a minor, please contact us immediately at [email protected] so that we can investigate and take appropriate action without delay.

14 Third-Party Links

The cr789 Platform may, on occasion, contain links to third-party websites, resources, or services — such as payment provider portals or game supplier information pages. This Privacy Policy applies solely to data collected and processed by cr789 on the cr789 Platform.

cr789 has no control over, and accepts no responsibility for, the privacy practices or content of third-party websites. We encourage you to review the privacy policy of any third-party website you visit before providing any personal information to that site. The inclusion of a link on the cr789 Platform does not constitute an endorsement of the linked site's data practices.

15 Policy Updates

cr789 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made to this Policy, cr789 will notify registered players through one or more of the following channels:

• An email notification sent to your registered cr789 email address.
• A prominent notice displayed upon cr789 login for a period of not less than 14 days following the update.
• An update to the "Last Updated" date displayed at the top of this page.

Your continued use of the cr789 Platform following the effective date of any amendment to this Policy constitutes your acknowledgement of the updated Policy. We recommend bookmarking this page and reviewing it periodically, particularly after receiving a notification of change.

16 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the manner in which cr789 handles your personal data, please do not hesitate to contact our Data Protection team using the details below:

• Email: [email protected] — please use the subject line "Data Privacy Request" for all data-related enquiries.
• Support Hours: 24 hours a day, 7 days a week, including Pakistani public holidays.
• Languages: Our support team handles data privacy enquiries in both English and Urdu.
• Response Commitment: We will acknowledge your enquiry within 48 hours and provide a full response within 30 calendar days.