Privacy Policy — 786app

This Privacy Policy ("Policy") sets out how 786app ("786app", "we", "us", "our") collects, processes, stores, shares and protects the personal data of users ("you", "your", "User") of the platform accessible at https://786app.cam ("the Platform").

786app is an English-language online betting and gaming information platform designed for Pakistani users. We are committed to handling all personal data responsibly, lawfully and transparently. This Policy applies to all personal data processed in connection with your use of the Platform, whether as a visitor, a registered account holder or a contact who has reached out to our support team.

This Policy should be read alongside our Terms & Conditions, which govern your overall use of the Platform. Where terms defined in the Terms & Conditions are used in this Policy, they carry the same meaning unless otherwise stated.

By accessing or using the Platform, you acknowledge that you have read and understood this Policy and that your personal data will be processed as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform.

In this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, identification number, location data, online identifiers or factors specific to that person's identity.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, 786app.
• "Data Processor" means any third party that processes Personal Data on behalf of 786app under a contractual arrangement.
• "Cookies" means small text files placed on your device when you visit the Platform, used to recognise your browser, store preferences and collect usage analytics.
• "KYC Data" means identity verification documents, including CNIC, passport, proof of address and biometric or liveness data, submitted as part of the Know Your Customer process.
• "Special Category Data" means sensitive personal data attracting heightened protection, such as health information, biometric data used for identification, or data revealing racial or ethnic origin.
• "Consent" means a freely given, specific, informed and unambiguous indication of the User's agreement to the processing of their Personal Data.

3.1 786app acts as the Data Controller in respect of Personal Data collected through the Platform. As Data Controller, we are responsible for ensuring that your Personal Data is processed in accordance with applicable data protection obligations.

3.2 Where 786app engages third-party Data Processors to perform functions on its behalf — such as payment processing, KYC verification or infrastructure hosting — those processors act under contractual obligations that require them to process data only in accordance with our documented instructions and applicable law.

3.3 For questions about how your data is handled, or to exercise your rights under Section 8, please use the contact details provided in Section 15.

4.1 786app collects Personal Data in the categories described below. We collect only data that is necessary for the specific purpose for which it is collected.

4.2 Data You Provide Voluntarily. Certain data is provided directly by you — for example, when you register an account, complete KYC verification, make a deposit, or contact our support team. Providing this data is necessary to use the relevant Platform features.

4.3 Data Collected Automatically. When you access the Platform, certain technical data is collected automatically, including your IP address, browser type, operating system, referring URL and pages visited. This data is used for security monitoring, fraud detection and Platform performance analysis.

4.4 Data from Third Parties. We may receive verification results or fraud signals from third-party KYC and AML service providers where you have consented to or initiated a verification check.

5.1 786app processes Personal Data only where a lawful basis for doing so exists. The primary legal bases and corresponding processing purposes are set out below:

• Performance of a Contract: Processing your registration data, account details and transaction records is necessary to provide the Platform services you have requested and to fulfil our contractual obligations to you.
• Legal Obligation: KYC and AML compliance obligations require us to collect, verify and retain certain identity and financial data in accordance with applicable licensing frameworks.
• Legitimate Interests: We process usage data and communications records for fraud prevention, security monitoring, Platform improvement and resolving support queries — all pursued in a manner proportionate to user privacy expectations.
• Consent: Where we rely on your consent — for example, for non-essential cookies or marketing communications — you may withdraw that consent at any time without affecting the lawfulness of prior processing.

5.2 Specific Processing Purposes. We process your Personal Data for the following defined purposes:

• Creating, managing and maintaining your Platform account;
• Verifying your identity and age for KYC and responsible gambling compliance;
• Processing deposits, withdrawals and transaction records;
• Providing customer support in English (and Urdu where available);
• Detecting, preventing and investigating fraud, money laundering and abuse;
• Complying with applicable legal and regulatory obligations;
• Analysing Platform performance and improving user experience;
• Sending service-related communications (account notifications, security alerts);
• Enforcing our Terms & Conditions and other platform policies.

5.3 We do not use Personal Data for automated decision-making that produces significant legal effects on users without human oversight, except where required for mandatory compliance functions such as age verification.

6.1 We do not sell your Personal Data. 786app does not sell, rent or trade your Personal Data to third parties for their own marketing or commercial purposes.

6.2 We may share Personal Data with the following categories of recipients where necessary and under appropriate safeguards:

• KYC & Identity Verification Providers: Third-party services that assist with document verification, liveness checks and AML screening, acting as Data Processors under contractual data processing agreements.
• Payment Processors: Financial service providers that handle deposit and withdrawal transactions. These providers are bound by their own compliance obligations and applicable financial regulation.
• Infrastructure & Hosting Providers: Cloud and server infrastructure providers that host Platform systems — processing data solely on our instructions under data processing agreements.
• Analytics Providers: Service providers that assist with Platform performance analytics and fraud detection, using aggregated or pseudonymised data where possible.
• Legal & Regulatory Authorities: We may disclose Personal Data to law enforcement, regulatory bodies or courts where we are required to do so by applicable law, court order or regulatory obligation.
• Professional Advisers: Legal counsel, auditors and compliance advisers acting under professional confidentiality obligations.

6.3 Any third party receiving Personal Data from 786app is required to process it only for the specified purpose, maintain appropriate security standards, and not disclose it further without authorisation.

7.1 786app retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations, whichever period is longer.

7.2 The following general retention principles apply:

• Account Data: Retained for the duration of the active account relationship and for a defined period thereafter, as required by applicable licensing and AML obligations.
• KYC & Identity Data: Retained in accordance with the requirements of applicable AML and know-your-customer regulations, which typically mandate retention for a minimum of five years following the end of the business relationship.
• Transaction Records: Retained for a period required under applicable financial compliance obligations, typically a minimum of five years.
• Support Communications: Retained for a period sufficient to resolve disputes and for quality assurance purposes, generally up to three years.
• Usage & Technical Data: Retained for a shorter period, typically up to 12 months, for security monitoring and fraud detection purposes.

7.3 Following the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual.

8.1 786app respects your rights in relation to your Personal Data. Subject to applicable law and certain exceptions, you may exercise the following rights:

8.2 To exercise any of the above rights, please contact us using the details in Section 15. We will respond to valid requests within a reasonable timeframe and in any event within 30 days, unless an extension is required and communicated to you.

8.3 Where we rely on consent as the legal basis for processing, you may withdraw consent at any time by contacting us. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

8.4 786app will not charge a fee for exercising data rights, unless requests are manifestly unfounded or excessive, in which case a reasonable fee may apply.

9.1 The Platform uses cookies and similar tracking technologies to operate core functions, remember your preferences, analyse usage patterns and support security controls.

9.2 The main categories of cookies used are:

• Strictly Necessary Cookies: Essential to the operation of the Platform. These cannot be disabled without breaking core functionality such as session management and security controls.
• Functional Cookies: Used to remember your preferences, such as your preferred odds format, language settings and session state.
• Analytics Cookies: Used to collect aggregated data about how Users interact with the Platform, helping us identify areas for improvement. Data is processed in a pseudonymised or aggregated form where possible.
• Security Cookies: Used for fraud detection, bot prevention and platform integrity monitoring.

9.3 Where applicable law requires it, we will seek your consent before placing non-essential cookies. You may adjust your cookie preferences at any time through your browser settings. Please note that disabling certain cookies may affect Platform functionality.

10.1 786app implements appropriate technical and organisational security measures designed to protect Personal Data against accidental loss, unauthorised access, disclosure, alteration or destruction.

10.2 Security measures in place include:

• HTTPS/TLS encryption for all data transmissions between your browser and the Platform;
• Secure, access-controlled server infrastructure with regular security reviews;
• Strong password requirements and optional two-factor authentication for user accounts;
• KYC document submission only via encrypted, secure upload channels — never via unencrypted email or chat;
• Regular internal security assessments and staff access controls;
• Data minimisation practices — only data necessary for the purpose is collected and retained.

10.3 While we take all reasonable steps to protect Personal Data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you as required by applicable law.

11.1 The Platform is strictly intended for adults aged 18 and above, or the higher minimum age required by the applicable operator or license jurisdiction. 786app does not knowingly collect or process Personal Data from persons under the applicable minimum age.

11.2 If you are a parent or guardian and believe that a minor has accessed the Platform and provided Personal Data, please contact us immediately using the details in Section 15. We will take prompt steps to delete such data and close any associated account.

11.3 Age verification is conducted as part of the KYC process. Users who cannot verify their age in accordance with our requirements will not be permitted to access full Platform functionality.

12.1 786app operates globally and may transfer Personal Data to, or process it in, countries other than Pakistan. Where such transfers occur, we take steps to ensure that an appropriate level of protection is applied, consistent with this Policy.

12.2 Transfer safeguards may include: contractual clauses requiring the recipient to maintain data protection standards equivalent to those applicable under this Policy; or other mechanisms recognised under applicable data protection frameworks.

12.3 By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in jurisdictions outside Pakistan.

13.1 The Platform may reference or provide information about third-party payment services, sports leagues or external resources for informational and contextual purposes. These references do not constitute links to third-party websites and do not involve sharing of your Personal Data with those parties unless you independently engage with them.

13.2 Where the Platform integrates third-party service providers — such as KYC verification tools, payment processors or analytics providers — those providers are engaged as Data Processors under binding contractual obligations and may only process data in accordance with our documented instructions.

13.3 786app is not responsible for the privacy practices of any third-party service you independently access. We encourage you to review the privacy policies of any external services you choose to use.

14.1 786app may update this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law, or operational practices. The effective date at the top of this page will be updated whenever material changes are made.

14.2 Where changes are significant, we may notify registered users via the Platform or by email to the address on file. For non-material changes, the updated Policy will be posted on this page without separate notification.

14.3 Your continued use of the Platform following any update constitutes your acknowledgement of the revised Policy. We encourage you to review this page periodically to stay informed of how your data is being handled.

15.1 If you have any questions, concerns or requests relating to this Privacy Policy or how your Personal Data is handled, please contact the 786app data team using the details below.

15.2 When submitting a data rights request, please include your full name, the email address registered on your account, and a clear description of your request. Proof of identity may be required before we can action certain requests.

15.3 We aim to acknowledge all data-related queries within 5 business days and to provide a substantive response within 30 days. If an extension is required, we will inform you of the reason and expected timeline.