939bat Privacy Policy

This Privacy Policy is published by 939bat ("939bat", "the Platform", "we", "us", "our"), the operator of the online casino and sports betting platform accessible at 939bat.net. 939bat operates under an international gaming licence and provides services to registered players located in Pakistan and other permitted jurisdictions.

For the purposes of data protection, 939bat acts as the data controller in respect of personal data collected directly from players via the platform's registration process, account management interface, payment flows, customer support interactions, and general site usage. Where 939bat engages licensed third-party game studios or payment service providers who process data on our behalf, those parties act as data processors under written data processing agreements.

By registering an account with 939bat, you acknowledge that you have read and understood this Privacy Policy and you consent to the collection and processing of your personal data as described herein. If you do not consent to any aspect of this policy, you should not register an account or continue to use the platform.

939bat collects personal data across several categories, depending on how you interact with the platform. The following table sets out the main data categories, specific data points, and the context in which each is collected.

939bat uses collected personal data for the following purposes, each of which is tied to a specific operational or legal necessity:

• Account Management: To create, maintain, and secure your player account, including processing login authentication and managing account preferences and limits.
• Identity Verification (KYC): To verify that you are who you say you are, that you meet the minimum age requirement of 21 years, and that your account is not being used for fraudulent purposes. This is both an operational requirement and a regulatory obligation under our gaming licence conditions.
• Payment Processing: To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, Bitcoin, and USDT (TRC-20). Your financial data is shared with payment service providers only to the extent necessary to execute each transaction.
• Anti-Money Laundering (AML) Compliance: To monitor transaction patterns, flag unusual activity, and fulfil our obligations under applicable AML and counter-terrorism financing frameworks. This may include sharing data with regulatory authorities where legally required.
• Responsible Gaming: To operate deposit limits, session reminders, cooling-off periods, and self-exclusion tools. Usage data helps 939bat identify signs of problematic gambling patterns so that proactive support can be offered.
• Customer Support: To respond to queries, resolve disputes, investigate complaints, and maintain records of communications for quality assurance and compliance purposes.
• Platform Improvement: Aggregated and anonymised usage data is analysed to improve platform performance, game selection, user interface design, and overall player experience.
• Security and Fraud Prevention: Technical data including IP addresses and session identifiers is used to detect and prevent unauthorised access, account takeovers, bot activity, and other security threats.
• Marketing Communications: Where you have opted in to receive promotional communications, 939bat may send you offers, bonus notifications, and platform updates via email or SMS. You may withdraw this consent at any time by contacting support or using the unsubscribe function in any marketing email.

939bat does not use automated decision-making or profiling processes that produce legal or similarly significant effects on players without human review. Where automated systems flag an account for review — for example, for suspected bonus abuse or AML purposes — a member of the 939bat compliance team reviews the case before any account action is taken.

939bat processes personal data on the following legal bases:

• Contractual Necessity: The majority of data processing — including account management, KYC, and payment processing — is necessary for the performance of the contract between 939bat and the player (i.e., the Terms and Conditions). Without this processing, 939bat cannot fulfil its contractual obligations to you.
• Legal Obligation: Certain processing activities — particularly KYC identity verification, AML transaction monitoring, and data retention for audit purposes — are required by the conditions of 939bat's international gaming licence and by applicable financial crime prevention frameworks.
• Legitimate Interests: Security monitoring, fraud prevention, and platform improvement analytics are carried out on the basis of 939bat's legitimate interests as a platform operator. In each case, 939bat has assessed that these interests are not overridden by players' rights and freedoms.
• Consent: Marketing communications are sent only where you have provided explicit consent. Consent is requested at the point of registration and can be withdrawn at any time. Withdrawal of marketing consent does not affect the lawfulness of any processing carried out prior to withdrawal.

939bat does not sell your personal data. We share data only in the following limited and controlled circumstances:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and crypto payment processors receive only the data required to execute your specific transaction. These providers are bound by their own privacy and data security obligations and do not receive your full account data.
• KYC / Identity Verification Partners: Where 939bat uses a third-party identity verification service to assist with document authentication and age verification, that provider receives the specific identity documents and data points required for the verification task only. Verification results are returned to 939bat and the underlying documents are not retained by the verification provider beyond their stated retention period.
• Game Providers: Licensed third-party game studios (for live casino, slot, and fishing game titles) may receive a pseudonymised player identifier and session data necessary to run the game. They do not receive your full identity data, contact details, or financial information.
• Regulatory and Law Enforcement Authorities: 939bat will disclose personal data to relevant authorities where required to do so by law, court order, or the conditions of our gaming licence. We will only disclose the specific data required by the lawful request and will notify the player of such disclosure where legally permitted to do so.
• Group Companies and Successors: In the event of a merger, acquisition, or restructuring of the 939bat business, player data may be transferred to a successor entity as part of the transaction, subject to equivalent privacy protections being maintained.

All third parties with whom 939bat shares personal data are required to handle that data in accordance with applicable privacy standards and are prohibited from using it for any purpose beyond the specific task for which it was shared.

939bat uses cookies and similar tracking technologies to operate the platform, maintain session state, and understand how players interact with the site. The following categories of cookies are used:

• Strictly Necessary Cookies: These are essential to the operation of the 939bat platform. They enable core functions such as maintaining your logged-in session, storing your language preference, and managing your security token. The platform cannot function without these cookies and they cannot be disabled.
• Performance / Analytics Cookies: These cookies collect aggregated, anonymised data about how players navigate the platform — which pages are visited most often, where users encounter errors, and how long sessions last. This data is used to improve the platform. No personally identifiable information is collected by these cookies.
• Functional Cookies: These remember choices you have made — such as your deposit limit settings or responsible gaming preferences — to provide a more personalised experience on return visits.
• Marketing / Targeting Cookies: These are only placed with your consent. Where enabled, they help 939bat understand the effectiveness of its promotional content so that relevant offers can be communicated to players who have opted in.

You can manage cookie preferences via your browser settings. Disabling strictly necessary cookies will impair or prevent your ability to use the 939bat platform. Disabling performance or marketing cookies will not affect your ability to bet or play.

939bat retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by our gaming licence conditions and applicable legal obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of the active account relationship and for a minimum of 5 years following account closure, in accordance with AML record-keeping requirements under our licence conditions.
• Transaction and Financial Data: Retained for a minimum of 5 years from the date of each transaction for audit, compliance, and dispute resolution purposes.
• KYC Verification Documents: Retained for the duration of the account and for 5 years post-closure. Originals are stored in encrypted form; access is restricted to authorised compliance personnel only.
• Customer Support Records: Retained for 2 years from the date of the interaction, unless the interaction relates to an ongoing dispute or investigation, in which case records are retained until the matter is fully resolved.
• Technical and Usage Data: Retained in identifiable form for 12 months, after which it is aggregated and anonymised for analytics purposes with no defined retention limit.
• Marketing Consent Records: Retained for the duration of the account relationship and for 2 years post-closure as evidence of lawful processing.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where deletion is technically complex (for example, data stored in encrypted backup archives), the data will be quarantined from active use pending its scheduled deletion at the next backup cycle.

939bat implements a layered security architecture designed to protect personal data against unauthorised access, disclosure, alteration, and destruction. Key security measures include:

• Encryption: All data in transit between your device and 939bat's servers is encrypted using TLS 1.3. Data at rest is encrypted using AES-256. This applies to all personal data categories including identity documents, financial data, and communications records.
• Access Controls: Access to personal data within 939bat's internal systems is restricted on a strict need-to-know basis. Role-based access controls ensure that individual staff members can only access the specific data categories required for their job function. All internal access is logged and auditable.
• Two-Factor Authentication: All 939bat staff with access to systems containing personal data are required to use multi-factor authentication. Players are strongly encouraged to enable two-factor authentication on their own accounts via the account security settings.
• Infrastructure Security: 939bat's platform infrastructure is hosted in data centres with physical access controls, environmental monitoring, and ISO 27001-aligned security practices. Infrastructure-level security patching is applied on a regular schedule.
• Penetration Testing: 939bat's platform is subject to periodic security assessments, including penetration testing by qualified third-party security professionals. Identified vulnerabilities are remediated in accordance with their risk rating within defined timescales.
• Incident Response: 939bat maintains a documented data security incident response plan. In the event of a confirmed breach affecting player data, 939bat will notify affected players without undue delay and will provide clear guidance on any steps players should take to protect themselves.

As a 939bat player, you have the following rights in relation to your personal data. These rights can be exercised by contacting 939bat support at [email protected] with your registered username and a clear description of your request.

939bat will respond to all data rights requests within 14 calendar days. Where a request is complex or 939bat receives a high volume of requests simultaneously, this period may be extended by a further 14 days with written notice to the requestor explaining the reason for the extension.

939bat is strictly a 21+ platform. We do not knowingly collect personal data from any person under the age of 21. Age verification checks are applied at the point of registration, and accounts that cannot be verified as belonging to a person aged 21 or over will not be activated for real-money play.

If 939bat discovers that personal data has been collected from a person under the age of 21 — for example, as a result of a false date of birth being provided at registration — 939bat will immediately suspend the relevant account, void any transactions associated with it, and delete the personal data collected, subject to any minimum retention obligations arising from the regulated nature of the transaction.

Given 939bat's crypto-first approach to payments, the following specific considerations apply to the handling of cryptocurrency-related data:

• Wallet Addresses: Your USDT (TRC-20) and Bitcoin wallet addresses are collected solely for the purpose of processing deposits and withdrawals. Wallet addresses are treated as personal data under 939bat's data handling framework and are subject to the same security and retention standards as other financial data categories.
• Blockchain Transparency: Players should be aware that blockchain transactions are publicly recorded on distributed ledgers. While 939bat handles your wallet address data confidentially within the platform, the existence of a transaction on-chain is a feature of the blockchain itself, not of 939bat's data practices.
• JazzCash & EasyPaisa Numbers: Your registered JazzCash and EasyPaisa mobile numbers are stored in tokenised form. 939bat does not store raw mobile wallet credentials and has no access to your JazzCash or EasyPaisa account beyond the specific payment transaction initiated through the 939bat platform.
• Bank Account Details: For HBL, UBL, Meezan Bank, and Raast transfers, account reference details are collected to execute withdrawal transactions. These details are encrypted at rest and are not shared with any party beyond the specific payment instruction required to process your withdrawal.
• AML Monitoring: Transaction values, frequencies, and patterns are monitored for AML compliance purposes. Players making large or unusual transactions may be required to provide source-of-funds documentation before the transaction is processed.

939bat reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, changes to the platform, or changes in applicable legal or regulatory requirements. Where a material change is made to this policy, 939bat will notify registered players via email or via an in-platform notification prior to the change taking effect.

The effective date at the top of this Privacy Policy will be updated each time a new version is published. Your continued use of the 939bat platform after the effective date of a revised policy constitutes your acceptance of the revised terms. If you do not accept a material change to this policy, you should close your account and cease using the platform before the revised policy takes effect.

Minor updates — such as corrections of typographical errors, clarifications that do not alter the substance of the policy, or updates to contact information — may be made without advance notice, though the effective date will still be updated to reflect the revision.

All privacy-related enquiries, data rights requests, and concerns about 939bat's data handling practices should be directed to the 939bat support team. We aim to respond to all privacy-related correspondence within 14 calendar days.

To submit a data rights request, please contact us with the following information:

• Your registered 939bat username
• The email address associated with your account
• A clear description of your request (e.g., access, rectification, erasure)
• Any supporting documentation relevant to your request

Email: [email protected]

Please note that for security purposes, 939bat may need to verify your identity before processing a data rights request. This is to ensure that personal data is not disclosed to or altered by an unauthorised party. Identity verification for this purpose will be handled via your registered email address and may require you to answer security questions or provide a copy of your identity document.