Privacy Policy – How 939bat Protects Your Data

This Privacy Policy describes how 939bat ("the platform", "we", "us") collects, uses, stores and protects the personal information of players who register and use the platform. It applies to all players accessing 939bat through the website at 939bat.win or through the Android or iOS mobile apps.

By registering an account on 939bat, you confirm that you have read this policy and consent to the collection and use of your personal data as described here. This policy forms part of your agreement with 939bat alongside the Terms and Conditions.

If you have questions about anything in this policy or want to exercise any of your data rights, contact the support team through live chat or at the email address listed in Section 13. We aim to respond to data-related queries within a reasonable timeframe.

939bat collects personal data in three ways: information you provide directly, data generated automatically through your use of the platform, and information from third-party payment providers involved in processing your transactions.

We do not collect sensitive categories of data beyond identity documents required for account verification. We do not collect biometric data other than where a player chooses to use biometric device authentication (fingerprint or face ID) available in the mobile app – this biometric data is processed entirely on your own device and is never transmitted to 939bat's servers.

Your personal data is used for the following purposes:

• Account operation: Creating and maintaining your 939bat account, processing logins and verifying your identity.
• Transaction processing: Handling deposits and withdrawals in PKR through your chosen payment method.
• Identity verification: Verifying that you are aged 18 or above and that you are the legitimate account holder before processing withdrawals.
• Security and fraud prevention: Detecting unusual account activity, preventing unauthorised access and investigating suspected fraud or breach of the Terms and Conditions.
• Customer support: Responding to your queries, resolving disputes and maintaining records of support interactions.
• Responsible gaming: Monitoring account activity patterns to identify potential indicators of problem gambling and providing access to responsible gaming tools.
• Platform improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection and user experience.
• Marketing communications: Sending promotional offers and updates, where you have consented. You can opt out at any time from account settings.

Data is not used for purposes beyond those listed here without your explicit consent or a legitimate legal basis.

939bat processes personal data on the following legal grounds depending on the specific use:

• Contractual necessity: Processing required to operate your account and fulfil the service described in the Terms and Conditions – such as processing deposits, withdrawals and bet settlement.
• Legitimate interests: Security monitoring, fraud prevention, platform integrity and responsible gaming oversight, where these interests do not override your rights.
• Legal obligation: Identity verification and transaction record-keeping required under applicable financial standards.
• Consent: Marketing communications and any optional data uses where you have given explicit consent. Consent can be withdrawn at any time without affecting your ability to use the platform.

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

• Payment processors: Transaction data is shared with JazzCash, Easypaisa, Raast and banking partners solely to process your deposits and withdrawals. These providers process data only as required to execute the transaction.
• Game providers: Slot and casino game studios receive a session token to validate your game session. They do not receive your personal identity data, financial details or contact information.
• Identity verification services: CNIC verification may be processed through a third-party identity verification service. This service is bound by confidentiality obligations and does not retain your document data beyond the verification process.
• Legal and law enforcement: Where required by applicable law or in response to a valid legal order, 939bat may disclose account data to competent authorities. We will inform you where legally permitted to do so.

All third-party service providers who process data on behalf of 939bat are bound by data processing agreements that restrict their use of your information to the specific purpose for which it was shared.

Payment processing on 939bat is handled through certified third-party processors including JazzCash, Easypaisa and banking networks. 939bat does not store full mobile wallet credentials, full bank account numbers or card details on its own servers. Transaction references and amounts are retained as part of your account's transaction history for record-keeping purposes.

When you make a deposit or request a withdrawal, the relevant payment data is transmitted directly to the payment processor over an encrypted connection. 939bat's role is to initiate and confirm the transaction; the actual processing of your payment credentials takes place within the payment provider's secure environment.

All payment channels used on 939bat are established, widely-used Pakistani payment services. Your JazzCash or Easypaisa account is not exposed beyond what is required to process the specific transaction you initiate.

939bat applies technical and organisational security measures appropriate for the type of data held. These include:

• TLS encryption on all connections between your device and 939bat servers, covering both the website and mobile apps.
• Encrypted storage for sensitive account data including passwords (stored as hashed values, never in plain text) and identity verification documents.
• Access controls restricting which internal team members can access personally identifiable data, limited to those with a legitimate need.
• Session management that expires login sessions after periods of inactivity and flags anomalous login patterns.
• Two-factor authentication available on accounts as an optional additional security layer.
• Regular security reviews of platform infrastructure and third-party integrations.

No digital system can guarantee absolute security. In the event of a data breach that poses a material risk to your rights, 939bat will notify affected players as promptly as possible and take immediate steps to contain the incident.

You are responsible for the security of your own account credentials. Do not share your password with anyone. 939bat will never ask you for your password through any channel.

939bat retains personal data for as long as it is necessary for the purposes described in this policy. The following general retention periods apply:

• Active accounts: Data is retained for the full duration your account is active.
• Following account closure: Core account and identity data is retained for a period of five years after account closure for financial record-keeping and fraud prevention purposes. This period may be extended where an ongoing legal or regulatory matter requires it.
• Transaction records: Deposit and withdrawal records are retained for a minimum of five years following the transaction date.
• Customer support communications: Support chat and email records are retained for up to two years from the date of the interaction.
• Marketing data: Where you have opted in to marketing, your preferences are retained until you withdraw consent or close your account.

When the retention period expires, data is securely deleted or anonymised. Anonymised, aggregated data (such as platform usage statistics that cannot identify any individual) may be retained indefinitely for platform improvement purposes.

The 939bat website uses cookies and similar tracking technologies to maintain your session, remember your preferences and measure platform performance. The mobile apps use equivalent in-app identifiers for session management.

The categories of cookies used include:

• Essential cookies: Required for the platform to function. These maintain your logged-in session and cannot be disabled without affecting your ability to use the site.
• Performance cookies: Collect anonymised data about how pages are accessed and which features are used. This information is used to improve the platform. No individually identifying data is involved.
• Preference cookies: Remember settings such as language preference and display options so you don't have to re-enter them on each visit.

Most web browsers allow you to manage cookie settings through the browser's privacy controls. Blocking essential cookies will prevent you from logging in or using core platform features. Blocking performance and preference cookies will not affect your ability to place bets or access games.

You have the following rights in relation to the personal data 939bat holds about you. To exercise any of these rights, contact support through live chat or email.

939bat is strictly for adults aged 18 and above. The platform does not knowingly collect personal data from individuals under 18 years of age. If it is discovered that an account has been registered by a minor, the account will be closed immediately and any associated data will be deleted in accordance with this policy.

If you believe that a minor may have registered on 939bat, contact support immediately with the relevant details so the account can be reviewed and closed.

939bat may update this Privacy Policy from time to time to reflect changes in how the platform operates, the services it offers or applicable data handling standards. The "Last Updated" date at the top of this page will be revised whenever changes are made.

For significant changes that affect how your personal data is used, registered players will be notified through email or an in-platform notification before the changes take effect. For minor updates that do not materially affect your rights or how data is processed, the policy page will be updated without individual notification.

Continued use of 939bat after any policy update constitutes your acceptance of the revised version.

If you have questions about this Privacy Policy, want to exercise any of your data rights, or have a concern about how your personal data is being handled, you can reach 939bat through the following channels:

• Live Chat: Available 24/7 directly through the platform website and mobile app. Fastest response for most queries.
• Email: [email protected] – for formal written data requests where a documented record is preferred.

For data access, correction or deletion requests, please include your registered mobile number or email address and a clear description of the request. Identity verification may be required before data-related requests are processed to confirm you are the legitimate account holder.