Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by r769 ("r769", "we", "us" or "our") and applies to all personal data collected from individuals ("you", "your", "Data Subject") who access or use the r769 platform at https://r769.cam ("Platform"), including visitors who browse without registering and registered Account holders.

r769 is committed to processing your personal data in a lawful, fair and transparent manner, in accordance with the data protection principles applicable under the laws of the jurisdiction governing the operator's licence. We designed this Policy to be readable — not buried in jargon — so that players across Pakistan, from Karachi to Peshawar, can understand precisely how their information is handled.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, which together form the complete framework of your agreement with r769.

2. Definitions

The following terms have the meanings assigned below wherever they appear in this Policy:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, contact details, financial data, device identifiers and behavioural data collected through the Platform.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure and deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, r769 acts as the Data Controller.
• "Data Processor" — a third party that processes Personal Data on behalf of r769 under a contractual data processing agreement.
• "Cookies" — small text files placed on your device by the Platform to support functionality, analytics and, where consented to, personalised marketing.
• "KYC Data" — identity and address verification documents collected during Know Your Customer procedures, including government-issued identification, proof of address and source-of-funds documentation.
• "Special Category Data" — Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, trade-union membership, biometric data, health data or data concerning sexual orientation. r769 does not intentionally collect Special Category Data except where strictly required by responsible-gambling obligations (e.g., self-exclusion requests).

3. Data Controller Identity

r769 is the Data Controller responsible for your Personal Data collected through the Platform. Our data protection contact for enquiries, complaints and rights requests is reachable at:

4. Personal Data We Collect

r769 collects Personal Data through multiple channels — directly from you during registration and Account use, automatically via your device and browser, and from third-party sources where required for KYC and fraud prevention.

5. Lawful Basis for Processing

Every instance of processing your Personal Data is conducted on one or more of the following lawful bases, as applicable under data protection law:

1. Contractual Necessity — Processing required to perform our contract with you (the Terms & Conditions), including account creation, processing deposits and withdrawals, and delivering game services.
2. Legal Obligation — Processing required to comply with applicable legal and regulatory requirements, including anti-money-laundering (AML) obligations, KYC verification requirements and responsible-gambling regulations under the operator's licence.
3. Legitimate Interests — Processing carried out in pursuit of r769's or a third party's legitimate interests, where those interests are not overridden by your fundamental rights and freedoms. This includes fraud prevention, platform security, service improvement and internal analytics.
4. Consent — Processing based on your freely given, specific, informed and unambiguous consent. This applies primarily to direct marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

r769 uses your Personal Data for the following purposes:

• Account Management — Creating, maintaining and securing your Account; processing deposits and withdrawals; applying bonuses and promotions to your Balance.
• Identity & Age Verification — Confirming that you meet minimum age requirements (18+, or higher where the operator/licence jurisdiction requires) and verifying your identity for KYC and AML compliance purposes.
• Fraud & Security — Detecting and preventing fraudulent activity, account takeovers, multi-accounting, money laundering and other prohibited conduct.
• Responsible Gambling Obligations — Monitoring gambling patterns to identify indicators of potential problem gambling; applying player-set limits; processing self-exclusion requests; communicating safer-gambling information where appropriate.
• Customer Support — Resolving support queries, processing complaints and providing assistance via live chat and email.
• Payment Processing — Facilitating PKR deposits and withdrawals through available payment methods, including familiar Pakistani payment rails such as Easypaisa, JazzCash, Raast and bank transfers, subject to their availability in the cashier.
• Direct Marketing — Sending promotional communications about bonuses, new games and platform features — only to players who have consented to receiving them. Consent can be withdrawn at any time.
• Legal Compliance — Fulfilling obligations under the operator's licence conditions, applicable financial crime legislation and any other legal requirements.
• Platform Improvement — Analysing anonymised and aggregated data to improve user experience, performance and product offerings.

7. Data Sharing & Third Parties

r769 does not sell, rent or trade your Personal Data to third parties for their own marketing purposes under any circumstances. We share data only in the following limited circumstances:

7.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process your data on our behalf, strictly according to our instructions and under contractual data processing agreements. Categories of processors include:

• Payment processors and gateway providers (for deposit and withdrawal services)
• Identity verification and KYC providers (for document and biometric verification)
• Fraud prevention and risk-scoring providers
• Customer support platform providers
• Cloud hosting and data storage providers
• Email and communication delivery services
• Analytics platform providers (using anonymised or pseudonymised data where possible)

7.2 Regulatory and Legal Disclosure

r769 may be required to disclose your Personal Data to regulatory authorities, law enforcement agencies, licensing bodies or courts in response to lawful orders, warrants or regulatory requirements. We will notify you of any such disclosure where legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, sale of assets or other business restructuring, your Personal Data may be transferred to the successor entity. We will notify you of any such transfer and the privacy terms applicable to your data under the new entity.

8. International Data Transfers

r769 operates internationally and may transfer your Personal Data to countries outside your country of residence, including jurisdictions that may have different data protection standards to those in Pakistan. Where such transfers occur, r769 ensures that appropriate safeguards are in place, which may include:

• Standard contractual clauses approved by the relevant data protection authority
• Processing by providers certified under recognised privacy frameworks
• Transfers to jurisdictions that offer an adequate level of data protection as determined by applicable law

If you have questions about the specific safeguards applicable to your data transfers, you may submit a written request to our privacy team at [email protected].

9. Data Retention

r769 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or to comply with applicable legal, regulatory and anti-money-laundering obligations. The following indicative retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that renders it permanently incapable of identification.

10. Cookies & Tracking Technologies

The Platform uses cookies and similar tracking technologies to operate core functionality, improve performance and, where you have consented, to deliver personalised content. The categories of cookies we use are as follows:

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will prevent the Platform from functioning correctly. For detailed guidance on managing cookies in your specific browser, refer to your browser's help documentation.

11. Security Measures

r769 implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction or disclosure. These measures include, but are not limited to:

• Transport Layer Security (TLS) encryption for all data in transit between your device and our servers
• Encryption of sensitive data at rest, including KYC documents and financial records
• Role-based access controls limiting staff access to Personal Data on a need-to-know basis
• Regular security testing, including vulnerability assessments and penetration testing
• Hashed and salted storage of passwords — r769 never stores plain-text passwords
• Fraud monitoring systems that flag anomalous account activity for review
• Contractual data security obligations imposed on all Data Processors

Despite these measures, no data transmission over the internet is 100% secure. r769 cannot guarantee absolute security, and players are encouraged to use strong, unique passwords and to enable two-factor authentication where available.

12. Your Data Protection Rights

Subject to applicable law and any regulatory exceptions (including AML retention obligations), you have the following rights over your Personal Data held by r769:

To exercise any of these rights, please submit a written request to [email protected] with the subject line "Privacy Rights Request" and include your registered email address or Account ID for identification purposes. We will respond within 30 calendar days. In complex cases, this period may be extended by a further 60 days with notice.

We may need to verify your identity before processing your request to prevent unauthorised access to another person's data.

13. Minors

The Platform is strictly for adults who are 18 years of age or older, or who meet the higher minimum age required by the operator's licence jurisdiction. r769 does not knowingly collect Personal Data from individuals under the minimum eligible age.

If you are a parent or guardian and believe that your minor child has registered on the Platform or provided us with Personal Data, please contact us immediately at [email protected]. We will take prompt steps to delete the data and close the Account.

14. Note for Pakistani Players

Pakistan does not currently have a comprehensive dedicated data protection statute equivalent to GDPR. r769 processes the Personal Data of Pakistani players in accordance with the data protection principles applicable under the laws of the jurisdiction governing the operator's licence, and in accordance with any applicable provisions of Pakistani law.

Pakistani players should be aware of the following:

• The Prevention of Electronic Crimes Act 2016 (PECA) contains provisions relevant to unauthorised access to data and electronic fraud, which inform our security obligations.
• The Payment Systems and Electronic Fund Transfers Act 2007 and State Bank of Pakistan regulations govern financial transaction data. r769 complies with applicable requirements relating to payment data in connection with Pakistani payment methods.
• r769 does not share your Personal Data with Pakistani government authorities except where required by a lawful legal obligation, court order or regulatory direction.
• r769 is not affiliated with, endorsed by or regulated by the Government of Pakistan, PTA, the State Bank of Pakistan or any Pakistani financial institution.

15. Changes to This Policy

r769 may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, our data processing activities or business practices. Where changes are material, we will notify registered Account holders via email or a prominent notice on the Platform at least 14 days before the updated Policy takes effect, unless a shorter notice period is required by applicable law.

The "Last updated" date at the top of this Policy reflects the most recent version. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree with the changes, you should contact us to close your Account before the revised Policy comes into effect.

16. Contact Us

For any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data, please contact our Privacy Team:

r769 takes all privacy requests seriously. Please include sufficient detail in your request to allow us to identify your Account and respond accurately. We may need to verify your identity before processing any data rights request.