939bat Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 939bat ("939bat," "we," "us," "our") collects, uses, stores, shares, and protects the personal information of users ("you," "your," "the User") who access or register on the 939bat online gaming platform (the "Platform").

939bat is committed to safeguarding the privacy and personal data of every Pakistani player on our platform — whether you are registering from Karachi, Lahore, Faisalabad, Islamabad, or anywhere else across Pakistan. We handle all personal data with the highest standards of care and in accordance with applicable data protection principles.

By registering an account on 939bat or by continuing to use the Platform, you confirm that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform and contact us to close your account.

2. Data Controller

For the purposes of applicable data protection law, 939bat is the data controller responsible for the personal information collected through the Platform. As data controller, 939bat determines the purposes for which and the means by which your personal data is processed.

Where 939bat engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification partners, or analytics providers — those third parties act as data processors and are bound by written data processing agreements that restrict how they may use your data and require them to implement appropriate security measures.

3. Personal Data We Collect

939bat collects personal data through multiple channels during your use of the Platform. The categories of data collected are set out below.

3.1 Registration Data

When you create a 939bat account, we collect:

• Full legal name (as it appears on your CNIC);
• Date of birth (to verify you are 21 years of age or older);
• CNIC number (Computerised National Identity Card, issued by NADRA);
• Pakistani mobile phone number;
• Password (stored in encrypted, hashed format — never in plain text);
• City of residence (e.g., Karachi, Lahore, Islamabad, Faisalabad).

3.2 Identity Verification (KYC) Data

To comply with anti-money laundering (AML) and Know Your Customer (KYC) requirements, 939bat may collect the following additional verification documents:

• A scanned copy or photograph of your CNIC (front and back);
• A recent proof of address (utility bill, bank statement — no older than 3 months);
• A selfie photograph for biometric identity matching where required;
• Evidence of ownership of a payment method used on the account.

3.3 Financial Data

When you make deposits or request withdrawals, 939bat collects transaction data including payment method identifiers (such as your JazzCash or EasyPaisa mobile wallet number, or bank account details for HBL, UBL, Meezan Bank, Raast, or 1LINK transfers), transaction amounts in PKR, timestamps, and transaction reference numbers. Full card or bank account numbers are never stored on 939bat servers — payment processing is handled by our certified payment partners.

3.4 Gaming & Behavioural Data

939bat automatically records data about your activity on the Platform, including: login timestamps and session durations, bet history (sports, casino, slots), game preferences, wagering amounts and outcomes, responsible gaming tool usage, and any self-imposed limits or exclusions you have set.

3.5 Technical Data

We collect standard technical information from your device and browser, including IP address, device type, operating system, browser type and version, referring URLs, pages visited, and click-path data. This data is used for security purposes, fraud detection, and platform optimisation.

3.6 Communications Data

When you contact 939bat support via live chat, email, or any other channel, we retain records of those communications — including the content of messages, timestamps, and the resolution outcome — for quality assurance, training, and dispute resolution purposes.

4. How We Use Your Personal Data

939bat uses your personal data strictly for the purposes for which it was collected. The primary uses of your data are as follows:

1. Account Management: To create, maintain, and administer your 939bat account, including processing login requests and enforcing account security measures.
2. Identity Verification: To verify your identity and age (21+) in compliance with KYC obligations, and to prevent the creation of duplicate or fraudulent accounts.
3. Payment Processing: To process your PKR deposits and withdrawals via supported payment methods including JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, 1LINK, and Cash OTC.
4. Service Delivery: To provide you with access to sports betting markets, live casino games, slot titles, and all other Platform features.
5. Regulatory Compliance: To comply with anti-money laundering (AML), counter-terrorism financing (CTF), and other applicable legal and regulatory obligations, including maintaining transaction records for required retention periods.
6. Fraud & Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, bonus abuse, money laundering, and other prohibited conduct.
7. Responsible Gaming: To monitor gaming behaviour, implement player protection tools (deposit limits, self-exclusion), and identify patterns that may indicate problem gambling requiring intervention.
8. Customer Support: To respond to your queries, resolve disputes, and improve the quality of our support services.
9. Platform Improvement: To analyse aggregated, anonymised usage data to improve the performance, design, and feature set of the 939bat Platform.
10. Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have given consent (see Section 13).

5. Legal Basis for Processing

939bat processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and 939bat — including account creation, bet settlement, and payment processing — is carried out on the basis that it is necessary to fulfil our contractual obligations to you.
• Legal Obligation: Certain processing activities — particularly KYC verification, AML record-keeping, and regulatory reporting — are carried out because 939bat is legally required to do so under applicable law.
• Legitimate Interests: Processing for fraud detection, platform security, responsible gaming monitoring, and analytics is carried out on the basis of 939bat's legitimate interests in operating a safe, compliant, and high-quality platform, provided those interests are not overridden by your privacy rights.
• Consent: Where processing is based on your consent — such as marketing communications — you may withdraw that consent at any time by contacting 939bat support or updating your Account notification preferences.

6. Sharing of Personal Data

939bat does not sell, rent, or trade your personal data to any third party. We share your data only in the following limited and controlled circumstances:

6.1 Payment Service Providers

To process your PKR deposits and withdrawals, 939bat shares relevant transaction data with authorised payment service providers including JazzCash, EasyPaisa, Raast, and our banking partners (HBL, UBL, Meezan Bank). These providers receive only the minimum data necessary to execute the payment instruction.

6.2 Identity Verification Partners

939bat engages certified third-party identity verification providers to conduct CNIC validation and biometric checks. These providers are contractually bound to process your data solely for verification purposes and to maintain appropriate technical and organisational security measures.

6.3 Regulatory & Law Enforcement Authorities

939bat is required by law to disclose certain information to regulatory authorities, law enforcement agencies, or other government bodies where demanded by a valid legal order, warrant, or regulatory obligation. 939bat will, where permitted by law, notify you of such a disclosure request.

6.4 Technology & Infrastructure Partners

939bat uses trusted third-party providers for hosting, cloud infrastructure, cybersecurity monitoring, and customer support tooling. These providers access personal data only to the extent necessary to perform their contracted services and are prohibited from using that data for any other purpose.

6.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 939bat's business, your personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer and afforded the opportunity to close your account if you do not wish your data to be transferred.

7. International Data Transfers

Some of 939bat's service providers and technology partners operate servers or infrastructure outside of Pakistan. Where your personal data is transferred to or processed in a jurisdiction outside Pakistan, 939bat ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy.

Such safeguards include, but are not limited to, contractual data protection clauses incorporated into agreements with all international data processors, as well as requirements that recipient organisations maintain internationally recognised information security certifications.

By using the 939bat Platform, you acknowledge and consent to the transfer of your personal data to international service providers where such transfers are necessary for the delivery of the Platform's services, subject always to the protections described herein.

8. Data Security

939bat implements robust technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the 939bat Platform is encrypted using industry-standard SSL/TLS protocols.
• Password Hashing: Account passwords are stored using one-way cryptographic hashing algorithms. 939bat staff cannot read or retrieve your password in plain text.
• Access Controls: Access to personal data within 939bat is strictly limited to staff and systems that require it for their defined function, enforced through role-based access controls.
• Two-Factor Authentication: 939bat offers OTP-based two-factor authentication to protect your account login and sensitive account changes.
• Regular Security Audits: The Platform undergoes periodic third-party security assessments and penetration testing to identify and remediate vulnerabilities.
• Intrusion Detection: 939bat operates continuous intrusion detection and monitoring systems across its infrastructure to identify and respond to security incidents in real time.

9. Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites function correctly, to remember user preferences, and to provide website owners with analytical information about how their sites are used.

9.2 How 939bat Uses Cookies

939bat uses the following categories of cookies on the Platform:

• Strictly Necessary Cookies: These are essential for the Platform to function. They keep your session active while you are logged in, remember your account state during gameplay, and maintain security tokens. These cookies cannot be disabled without breaking core Platform functionality.
• Performance & Analytics Cookies: These cookies collect anonymised data about how users interact with the Platform — such as which pages are visited most frequently and how long users spend on each section — allowing 939bat to identify areas for improvement. These cookies do not collect personally identifiable information.
• Functional Cookies: These remember your preferences — such as your chosen language or display settings — to provide a more personalised experience on return visits.
• Security Cookies: Used for fraud detection purposes, including identifying unusual login patterns, multiple account detection, and IP reputation scoring.

9.3 Managing Cookies

You can manage or delete cookies through your browser settings at any time. Most browsers allow you to refuse all cookies, accept only certain categories, or delete cookies that have already been set. Please note that disabling strictly necessary cookies will prevent you from logging in to your 939bat account and using core Platform features.

10. Data Retention

939bat retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is either securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

11. Your Data Rights

As a user of the 939bat Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact the 939bat support team via live chat or at [email protected]. 939bat will respond to all valid requests within 30 days.

• Right of Access: You have the right to request a copy of the personal data 939bat holds about you, along with information about how it is being used.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. You can update most account details directly from your account settings.
• Right to Erasure: You may 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 the data has been unlawfully processed. This right is subject to 939bat's legal retention obligations — we cannot delete data we are required by law to keep.
• Right to Restriction: You may request that 939bat restrict processing of your data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that 939bat provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing of your personal data where that processing is based on legitimate interests, including for direct marketing purposes. Where you object to marketing, 939bat will cease processing your data for that purpose immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

12. Children & Minors

The 939bat Platform is strictly intended for individuals aged 21 years and above. 939bat does not knowingly collect personal data from individuals under the age of 21. CNIC-based age verification is conducted at account registration to enforce this requirement.

Parents and guardians who believe their child may have accessed or registered on the 939bat Platform are urged to contact the support team immediately at [email protected] so that appropriate action can be taken without delay. 939bat also encourages the use of parental control software to prevent minors from accessing online gaming platforms.

13. Marketing Communications

939bat may send you promotional communications — including bonus offers, free bet notifications, deposit match promotions, and platform news — via SMS to your registered Pakistani mobile number or via in-Platform notification, where you have provided your consent to receive such communications during the registration process or at a later point through your Account preferences.

You may opt out of marketing communications at any time by:

• Updating your notification preferences in the Account settings section of the Platform;
• Replying "STOP" to any promotional SMS message received from 939bat;
• Contacting the 939bat support team and requesting removal from marketing lists.

Opting out of marketing communications will not affect the delivery of transactional or service-essential communications — such as deposit confirmations, withdrawal notifications, account security alerts, or responsible gaming notifications — which are sent regardless of marketing preferences.

14. Third-Party Links

The 939bat Platform may contain links to third-party content, game providers, or informational resources. 939bat does not control the privacy practices of external websites or services and is not responsible for their content or data handling practices.

Clicking on a third-party link from the 939bat Platform will take you away from 939bat's controlled environment. We encourage you to review the privacy policy of any external site you visit. This Privacy Policy applies solely to data processed by 939bat in connection with your use of the Platform.

15. Changes to This Privacy Policy

939bat reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or our data processing practices. Material changes to this Policy will be communicated to registered users via SMS notification to their registered Pakistani mobile number or via a prominent notice on the Platform, with a minimum of 7 days' advance notice before the updated Policy takes effect.

The "Last Updated" date at the top of this Policy will be revised to reflect the date on which any amendments become effective. We encourage you to review this Policy periodically. Your continued use of the 939bat Platform after the effective date of an updated Policy constitutes your acceptance of the revised terms.

16. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to 939bat's handling of your personal data, please reach out to the 939bat Data Protection team through any of the following channels:

If you are not satisfied with 939bat's response to a data-related request or complaint, you may escalate the matter to the relevant data protection or gaming regulatory authority as indicated in the Platform's licensing documentation. 939bat will co-operate fully with any regulatory investigation of its data processing practices.