939bat Privacy Policy

1 Introduction

This Privacy Policy ("Policy") sets out how 939bat ("we", "us", "our", "the Platform"), operating at https://939bat.cam, collects, uses, stores, shares and protects the personal data of individuals ("User", "you", "your") who access or register on the Platform.

We take privacy seriously. This Policy is designed to give you a clear, honest account of our data practices — written in plain English, not buried in impenetrable legalese. If you have any questions after reading this Policy, please contact us at [email protected].

By using 939bat, you acknowledge that you have read and understood this Policy. Please also review our Terms & Conditions, which are incorporated by reference and form part of the overall agreement governing your use of the Platform.

2 Definitions

3 Personal Data We Collect

939bat collects personal data across several categories, depending on how you interact with the Platform. We collect only the data that is necessary for the stated purpose.

3.1 Registration Data

When you create an Account, we collect:

• Full legal name
• Date of birth (to verify age eligibility)
• Email address
• Residential address (including city — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
• Username and encrypted password
• Phone number (where provided)

3.2 KYC & Verification Data

To comply with identity verification, anti-money-laundering (AML) obligations and responsible-gambling age checks, we may collect:

• Government-issued photo identification (e.g., CNIC, passport, driving licence)
• Proof of residential address (e.g., utility bill, bank statement dated within three months)
• Source-of-funds documentation where required by AML policy
• Photographs submitted for identity verification purposes

3.3 Financial Data

When you make a deposit or withdrawal, we collect payment-related data necessary to process the transaction. This may include bank account references, mobile wallet identifiers (such as those associated with Easypaisa or JazzCash accounts), and transaction records. We do not store full card numbers or sensitive authentication data on our servers — these are handled by regulated third-party payment processors.

3.4 Usage & Behavioural Data

We automatically collect data about how you use the Platform, including:

• Pages visited, time spent, navigation paths and feature interactions
• Betting history, game sessions played, deposit and withdrawal history
• Search queries and preferences within the Platform
• Responsible-gambling tool usage (e.g., deposit limit activations, self-exclusion requests)

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, browser type and version
• Session identifiers and authentication tokens
• Mobile network operator information (where applicable)

3.6 Communications Data

If you contact our support team, we retain records of your communications, including email content, subject matter and timestamps. We do not record telephone calls unless you are notified in advance.

4 How We Collect Personal Data

Personal data is collected through the following channels:

• Directly from you: Registration forms, KYC document uploads, support communications and account-settings updates.
• Automatically: Cookies, log files, analytics tools and session-tracking technologies when you browse or use the Platform.
• From third-party service providers: Payment processors (including mobile wallet providers), identity-verification services, fraud-detection systems and data-enrichment partners operating under data-processing agreements with 939bat.
• From KYC/AML partners: Identity and sanctions-screening results provided by third-party verification services as part of our compliance obligations.

5 Lawful Basis for Processing

Each category of personal data we process has a defined lawful basis. The primary bases applicable to 939bat's data processing activities are:

6 How We Use Your Personal Data

We use personal data collected from you for the following purposes:

• To create, verify, manage and maintain your Account.
• To process deposits, withdrawals and in-account financial transactions.
• To conduct identity verification, age checks and AML screening in compliance with applicable obligations.
• To provide customer support and respond to your queries in English or Urdu.
• To deliver and personalise your betting and gaming experience, including presenting relevant cricket markets (PSL, ICC, bilateral series) and sports categories.
• To administer promotional offers, bonuses and loyalty programmes applicable to your Account.
• To monitor and enforce compliance with our Terms & Conditions, responsible-gambling policies and applicable law.
• To detect, investigate and prevent fraud, cheating, multi-accounting, and other prohibited conduct.
• To analyse Platform usage and improve functionality, performance and user experience.
• To send you transactional notifications (account alerts, security notices, withdrawal confirmations) — these are not optional as they are required for Account operation.
• To send you promotional communications where you have opted in to receive them — you can withdraw consent at any time.

7 Data Sharing & Disclosure

939bat does not sell your personal data to third parties for their own commercial gain. We share personal data only in the following circumstances:

7.1 Service Providers (Data Processors)

We engage third-party vendors who process personal data on our behalf under written data-processing agreements. These include payment processors, identity-verification services, fraud-detection platforms, cloud hosting providers, customer-support tools and analytics services. These providers are contractually restricted to processing data only for the purposes we specify.

7.2 Payment Processing Partners

Where you use mobile wallet services (such as those associated with Easypaisa or JazzCash), bank transfers (such as those via HBL, UBL, Meezan Bank or Bank Alfalah), Raast, or other payment instruments, transaction data is shared with the relevant payment processor to the extent required to complete the transaction. These processors operate under their own privacy policies, which you should review independently. The mention of these payment providers does not imply their endorsement of 939bat or of gambling activity.

7.3 Legal and Regulatory Obligations

We may disclose personal data to competent authorities, regulators, law enforcement agencies or courts where required by applicable law, court order, regulatory instruction or to enforce our legal rights.

7.4 Business Transfers

In the event of a merger, acquisition, asset sale or restructuring involving 939bat, personal data held by the Platform may form part of the transferred assets. You will be notified if such a transfer results in a material change to the terms of this Policy.

8 International Data Transfers

Personal data collected from Pakistani users may be transferred to, and stored or processed in, jurisdictions outside Pakistan. This includes the jurisdiction in which 939bat's servers and infrastructure are hosted, and the countries in which our service providers operate.

Where personal data is transferred to jurisdictions that do not have a data-protection framework equivalent to the one under which the data was collected, we apply contractual safeguards — including standard data-processing clauses — to ensure that the data receives an appropriate level of protection.

By registering on the Platform, you acknowledge and accept that your personal data may be processed outside Pakistan as described in this section.

9 Data Retention

We retain personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable law. The following general retention principles apply:

• Account data: Retained for the duration of your active Account, plus a post-closure retention period required by AML and financial regulation (typically five to seven years, depending on jurisdiction).
• KYC documents: Retained for a period determined by AML compliance requirements applicable to the Platform's licensing jurisdiction, typically no less than five years from the date of the last transaction or Account closure.
• Transaction records: Retained in accordance with financial and AML record-keeping obligations.
• Communications: Support emails and communications retained for up to three years from the date of the last interaction, or longer where the communication relates to a dispute or legal matter.
• Analytics and usage data: Retained in aggregated or anonymised form for platform improvement purposes, with identifiable elements deleted or anonymised after a defined period.
• Marketing consent records: Retained for the duration of the consent and for a reasonable period thereafter to evidence compliance.

When personal data is no longer required and no legal obligation mandates its retention, it is securely deleted or irreversibly anonymised.

10 Cookies & Tracking Technologies

939bat uses cookies and similar technologies (including local storage and session identifiers) to operate the Platform, remember your preferences, maintain session security and understand how the Platform is used. The following cookie categories are in use:

You can manage or delete cookies through your browser settings. Disabling essential cookies will affect Platform functionality. For more information on cookie management, consult your browser's help documentation.

11 Your Data Rights

Subject to the applicable data-protection framework and any overriding legal obligations, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request".

12 Children's Privacy

The Platform is strictly for adults aged 18 and above — or the higher minimum age required by the applicable operator or licence jurisdiction. We do not knowingly collect personal data from individuals below the minimum eligible age. If we become aware that personal data has been collected from an individual below the minimum age, we will take immediate steps to delete that data and close the associated Account.

Age verification through KYC documentation is part of the Platform's standard compliance process. If you believe a minor has accessed the Platform or provided personal data, please notify us immediately at [email protected].

13 Security Measures

We implement a range of technical and organisational measures to protect your personal data against unauthorised access, loss, alteration or disclosure. These include:

• HTTPS/SSL encryption for all data in transit between your device and the Platform.
• Encrypted storage of sensitive data, including passwords (stored as cryptographic hashes, never in plain text) and KYC documents.
• Role-based access controls limiting which personnel can access personal data, restricted to those with a legitimate operational need.
• Regular security assessments and vulnerability management processes.
• Incident response procedures for data breaches, including notification processes in line with applicable legal requirements.

While we take data security seriously, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials. If you suspect your Account has been compromised, contact support immediately.

14 Third-Party Links & Services

The Platform may reference or contextually mention third-party services, including payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah, as familiar references for Pakistani users. These references do not constitute endorsements, and 939bat is not responsible for the privacy practices of third-party organisations.

Each third-party provider you interact with in connection with the Platform — including your bank, mobile wallet provider or payment gateway — operates under its own privacy policy, which you should review independently. 939bat's Privacy Policy applies only to data collected and processed by 939bat directly.

15 Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform functionality. Material changes — those that significantly affect how your personal data is used or your rights in relation to it — will be communicated to registered users via email or a prominent notice on the Platform, with a minimum of 14 days' advance notice where practicable.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the Platform after any update constitutes acceptance of the revised Policy. If you do not agree with a material change, you may request Account closure before the effective date of the change.

16 Contact Us

For any privacy-related queries, data rights requests or concerns about how 939bat processes your personal data, please contact our support team using the details below. All privacy enquiries are handled with care and in accordance with the response timelines stated in Section 11.

For questions unrelated to privacy, including bonus queries, account issues and responsible-gambling assistance, please visit our FAQ page or refer to our Terms & Conditions.