Privacy Policy

RS89 ("we", "us", "the Platform", "the Operator") is committed to protecting and respecting the privacy of all individuals who access or use the RS89 online gaming platform at https://rs89.cam. This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed.

This Policy applies to all users of the RS89 Platform, including registered account holders, visitors who browse the platform without registering, and individuals who contact our support team. It covers data collected through the website, any associated mobile experiences and all communication channels operated under the RS89 brand.

RS89 has designed this Policy to be read and understood by users in Pakistan. All terms are written in plain English, and where technical or legal terms are unavoidable, we have defined them clearly in Section 2. If you are based in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar or any other city in Pakistan, this Policy applies to you in full.

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" — Any information that identifies or can reasonably identify a living individual, including name, email address, date of birth, payment details and IP address.
• "Processing" — Any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" — The entity that determines the purposes and means of processing personal data. For the purposes of this Policy, RS89 acts as the Data Controller in relation to user data collected through the Platform.
• "Data Processor" — A third party that processes personal data on behalf of the Data Controller under a contractual arrangement and in accordance with the Controller's instructions.
• "User" / "Data Subject" — The individual whose personal data is being collected, stored or otherwise processed — i.e., you, the platform user.
• "KYC" — Know Your Customer — the identity, age and payment verification process required to operate a compliant gaming account.
• "Cookies" — Small text files placed on your device by the Platform to store session preferences, facilitate security and support analytics functions.
• "Third Party" — Any person or entity other than you and RS89, including payment processors, game providers and analytics services.

RS89 collects only the categories of personal data necessary to provide the Platform's services, meet compliance obligations and maintain platform security. The specific data collected falls into the following categories:

RS89 collects personal data through the following channels and interactions:

4.1 Direct Collection

• Account Registration: When you create an RS89 account, you provide identity and contact information directly through the registration form.
• KYC Submission: When you submit identity documents to complete account verification, including CNIC, passport, proof of address and payment method documentation.
• Deposits & Withdrawals: When you initiate financial transactions, payment method information is collected and associated with your account record.
• Support Interactions: When you contact RS89 via live chat or email at [email protected], the content of your communications is stored for service and compliance purposes.
• Responsible Gambling Requests: When you request deposit limits, loss limits, self-exclusion or other responsible gambling tools, the relevant instructions and timestamps are recorded.

4.2 Automated Collection

• Platform Usage: RS89 automatically collects technical and behavioural data when you interact with the Platform, including pages visited, games accessed, session durations and in-play betting activity.
• Device & IP Data: Your IP address, device type, operating system, browser version and general geolocation are logged automatically for security monitoring, fraud prevention and access-control purposes.
• Cookies: Session cookies and persistent cookies are used to manage your login state, remember preferences and support platform analytics. See Section 8 for full cookie details.

4.3 Third-Party Sources

• RS89 may receive identity verification data from third-party KYC and anti-fraud services engaged to assist with compliance obligations.
• In some cases, financial transaction data may be received from payment processors (such as those operating Easypaisa, JazzCash, Raast integrations, or bank transfer rails via HBL, UBL, Meezan Bank or Bank Alfalah) in order to reconcile deposit and withdrawal records. These references are operational context only — RS89 does not claim any partnership or endorsement from these providers.

RS89 processes your personal data on one or more of the following legal grounds, depending on the specific processing activity:

• Contractual Necessity: Processing is necessary to perform the contract between you and RS89 — specifically, to operate your account, process your transactions and provide the gaming services you have registered for.
• Legal Obligation: Processing is required to comply with applicable legal and regulatory obligations, including anti-money laundering (AML) requirements, KYC obligations and responsible gambling regulations under the Operator's licensing framework.
• Legitimate Interests: Processing is in the legitimate interests of RS89 (and not overridden by your rights) for purposes including fraud prevention, platform security, abuse detection and the improvement of platform features.
• Consent: Where RS89 relies on your consent — for example, for optional marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

RS89 uses the personal data it collects for the following specific purposes:

• Account Management: Creating, maintaining and securing your RS89 account, including enabling login, managing preferences and processing account closure requests.
• Identity Verification (KYC): Verifying your identity, age and the ownership of payment methods you use, as required by the Operator's compliance framework.
• Transaction Processing: Processing deposits and withdrawals in PKR and other accepted currencies, reconciling account balances and maintaining accurate financial records.
• Fraud Prevention & Security: Detecting and preventing fraudulent activity, multi-accounting, money laundering and other prohibited conduct as described in the RS89 Terms & Conditions.
• Responsible Gambling: Monitoring account activity to identify patterns consistent with problem gambling, applying limits you have requested and processing self-exclusion instructions.
• Customer Support: Responding to queries, complaints and escalations submitted via live chat or email, and maintaining records of support interactions.
• Legal & Regulatory Compliance: Meeting obligations under applicable law, responding to lawful information requests from authorities and retaining records as required by the Operator's licensing terms.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the performance, design and content of the RS89 Platform.
• Marketing Communications: Sending you promotional offers, platform updates and relevant content, where you have consented to receive such communications and have not subsequently opted out.

RS89 does not sell, rent or trade your personal data to any third party. We may share personal data with carefully selected third parties only in the following circumstances:

7.1 Service Providers (Data Processors)

RS89 engages third-party service providers who process personal data on our behalf and under our instruction. These include KYC and identity verification services, payment processors, fraud detection providers, cloud hosting providers, analytics platforms and customer support tooling providers. All such providers are subject to contractual data processing agreements that require them to process data only as instructed by RS89 and to maintain appropriate security standards.

7.2 Regulatory & Legal Disclosure

RS89 may disclose personal data to regulatory authorities, law enforcement agencies or other competent bodies where required to do so by applicable law, court order, regulatory directive or in response to a lawful investigation. RS89 will disclose only the minimum data necessary to satisfy the legal obligation.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of RS89's business assets, personal data held by RS89 may be transferred to the acquiring entity as part of the transaction. Users will be notified of any such transfer and any material change to the privacy terms applicable to their data.

7.4 Consent-Based Sharing

RS89 will not share your personal data with any third party for purposes not described in this Policy without your prior explicit consent, except where required by law.

RS89 uses cookies and similar tracking technologies to support the operation of the Platform, enhance user experience and monitor security.

8.1 Types of Cookies Used

• Essential / Session Cookies: Required for the Platform to function. They manage your login session, maintain security state and enable core features. These cannot be disabled without significantly impairing platform functionality.
• Preference Cookies: Store your platform preferences, including language, display settings and notification preferences, so they are remembered across sessions.
• Analytics Cookies: Collect anonymised and aggregated data about how users interact with the Platform — including pages visited, session durations and navigation paths — to help RS89 improve the user experience.
• Security Cookies: Support fraud detection and abuse prevention systems by tracking anomalous login patterns, device fingerprints and session irregularities.

8.2 Cookie Control

You can manage or disable non-essential cookies through your browser settings. Note that disabling cookies may affect your ability to log in, maintain session state or access certain platform features. Consult your browser's help documentation for guidance on cookie management.

8.3 Do Not Track

RS89 currently does not alter its data collection practices in response to "Do Not Track" browser signals. If this position changes, this Policy will be updated accordingly.

RS89 operates internationally and your personal data may be processed and stored on servers located outside of Pakistan. When your data is transferred to a jurisdiction that may have different data protection standards from your country of residence, RS89 ensures that appropriate safeguards are in place to protect your data, which may include:

• Contractual data protection clauses binding the recipient to adequate protection standards
• Transfers to jurisdictions recognised by applicable regulatory frameworks as providing an adequate level of data protection
• Technical security controls (encryption, access controls, audit logging) regardless of the processing location

By using the RS89 Platform and providing your personal data, you acknowledge and consent to the transfer of your data to processing locations outside Pakistan for the purposes described in this Policy.

RS89 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations and to resolve disputes. The following general retention principles apply:

• Active Account Data: Retained for the duration of the account relationship and for a period thereafter as required by applicable law (typically 5–7 years post-account closure, depending on the jurisdiction).
• KYC & Identity Documents: Retained in accordance with anti-money laundering regulations applicable to the Operator's licensing jurisdiction, typically a minimum of 5 years from the date of the last transaction or account closure.
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction for financial compliance purposes.
• Support Correspondence: Retained for a minimum of 2 years from the date of the last interaction for dispute resolution and service quality purposes.
• Analytics Data: Anonymised usage data may be retained indefinitely for platform improvement purposes, as it cannot be used to identify individual users.
• Marketing Preferences: Retained for as long as you remain a registered user, or until you withdraw consent for marketing communications.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

RS89 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration or disclosure:

• SSL/TLS Encryption: All data transmitted between your device and the RS89 Platform is encrypted using industry-standard TLS protocols.
• Access Controls: Access to personal data is restricted to authorised personnel on a need-to-know basis. Role-based access controls and audit trails are maintained.
• Password Security: Account passwords are stored using one-way hashing algorithms. RS89 staff cannot retrieve your plain-text password.
• Fraud Detection Systems: Automated systems monitor for unusual login patterns, multi-accounting indicators and suspicious transaction behaviour.
• Data Minimisation: RS89 does not retain sensitive payment card numbers or full financial credentials beyond what is required for transaction reconciliation.
• Incident Response: RS89 maintains a data breach response procedure. In the event of a significant data breach, affected users and relevant authorities will be notified in accordance with applicable requirements.

While RS89 takes security seriously, no online system can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying RS89 promptly if you suspect any unauthorised use of your account.

Subject to applicable law, you have the following rights in relation to your personal data held by RS89:

To exercise any of these rights, please contact the RS89 support team at the details provided in Section 17. RS89 will respond to verified requests within 30 days. We may request proof of identity before processing a rights request to prevent fraudulent or unauthorised access to account data.

The RS89 Platform is strictly for adults aged 18 and above — or the higher minimum age required by the operator or license jurisdiction. RS89 does not knowingly collect or process personal data relating to individuals under the minimum age.

If RS89 becomes aware that personal data has been collected from a person below the minimum age threshold, that Account will be immediately suspended, all data associated with the underage Account will be deleted in accordance with this Policy, and any Real Funds deposited will be returned. Parents or guardians who believe a minor has created an account on the Platform should contact RS89 immediately via the support details in Section 17.

RS89 encourages parents and guardians to use parental control software to restrict access to online gambling websites for minors. Being aged 18 does not make online gambling lawful under all applicable laws in Pakistan — players must understand their local legal obligations independently.

The RS89 Platform may contain links to or integrations with third-party websites, services or game providers. This Privacy Policy applies only to data collected and processed by RS89 directly. RS89 is not responsible for the privacy practices or data handling of any third-party service.

If you follow a link to a third-party website or interact with a third-party embedded service, you should read the privacy policy of that third party independently. RS89 has no control over and accepts no responsibility for third-party data handling.

RS89 is an English-language online gaming platform tailored for Pakistani users. The following specific points apply to users accessing the Platform from within Pakistan:

• Pakistan does not currently have a comprehensive standalone data protection law equivalent to the GDPR in force. RS89 applies data protection standards consistent with its licensing jurisdiction and international best practices in the interim.
• RS89 does not operate under any licence, authorisation or approval granted by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, or any provincial authority. No such endorsement is claimed or implied.
• Accessing the RS89 Platform from Pakistan is subject to applicable Pakistani law, including the Prevention of Gambling Act, 1977. RS89 does not provide legal advice on the lawfulness of access from any specific jurisdiction. Users must make that assessment independently.
• References to payment methods familiar to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are for operational context only. None of these providers have endorsed, supported or affiliated themselves with RS89 or with online gambling activity.

RS89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data processing practices or the services we provide. When material changes are made, RS89 will notify registered users through one or more of the following: an in-platform notification displayed upon login, an email to your registered address, or a notice on the RS89 homepage.

The "Effective Date" at the top of this Policy reflects the date on which the most recent version came into force. We encourage you to review this Policy periodically. Continued use of the RS89 Platform after the effective date of any updated version of this Policy constitutes your acceptance of the revised terms.

If you do not agree with the amended Privacy Policy, you must stop using the Platform and request account closure by contacting our support team.

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact the RS89 Data & Privacy team using the details below. All correspondence must be in English.