939bat Privacy Policy

1. Who We Are

939bat is an online gaming and sports betting platform operated for users in Pakistan and other eligible markets. The platform provides access to casino games, slots, live casino, sports betting (including cricket, PSL, T20, football, and esports), and a tiered VIP programme. All transactions on the platform are denominated in PKR.

For the purposes of this Privacy Policy, references to "939bat", "we", "us", or "the platform" refer to the operator of the 939bat service. References to "you" or "the user" refer to any individual who has registered an account on 939bat or is accessing the platform.

If you have questions about data handling or wish to exercise your data rights, you can contact us through the support channel on the platform or by writing to [email protected].

2. Data We Collect

The categories of personal data 939bat may hold about you depend on how you interact with the platform. The table below summarises the main categories:

We do not collect sensitive personal data such as biometric information, medical records, or political opinions. We also do not collect data relating to minors — the platform is strictly for users aged 18 and above.

3. How We Collect Your Data

939bat collects personal data through several channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or update your account settings, you provide data to us directly.
• Automatically during platform use: Technical data — including IP addresses, device information, session logs, and cookie data — is collected automatically each time you access the platform.
• From payment providers: When you use JazzCash, Easypaisa, Raast, bank transfer, or card payments, the payment provider shares transaction reference data with us to confirm the status of deposits and withdrawals. We do not receive your full card or wallet credentials from these providers.
• From identity verification services: Where we use a third-party KYC provider to assist with document verification, that provider may share a verification result and associated identity data with us.
• From cookies and similar technologies: See Section 7 below for full details on cookie use.

4. Why We Use Your Data

939bat uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your 939bat account, including processing login sessions and account preference settings.
• Identity verification and fraud prevention: To verify your age, identity, and payment source as required. This is also how we prevent underage access, duplicate accounts, and fraudulent activity on the platform.
• Processing transactions: To handle deposits and withdrawals in PKR via JazzCash, Easypaisa, Raast, bank transfer, and cards — and to maintain accurate financial records for your account.
• Providing gaming and betting services: To allow you to place bets on cricket, PSL, T20, football, esports markets, and access casino games, slots, and live casino.
• Customer support: To respond to your queries, resolve complaints, and provide account assistance.
• Responsible gaming: To monitor account activity for signs of problematic gambling behaviour and to enforce self-exclusion and deposit limits you have set on your account.
• Platform security: To detect and prevent unauthorised access, cheating, collusion, and technical abuse of the platform.
• Legal and regulatory compliance: To retain records as required and respond to lawful requests from competent authorities.
• Communications: To send account-related notifications such as deposit confirmations, withdrawal updates, and security alerts. Where you have opted in, we may also send promotional communications — you can opt out of these at any time from your account settings.

5. Third-Party Sharing

939bat does not sell your personal data to third parties. We share data only in the following circumstances, and only to the extent necessary for each purpose:

• Payment providers: JazzCash, Easypaisa, Raast, and card/bank processing partners receive the transaction data necessary to process your deposits and withdrawals. Each provider operates under their own privacy terms.
• Identity verification providers: Where a third-party KYC service is used to assist with document checks, your identity data is shared with that provider for the sole purpose of completing verification.
• Platform infrastructure providers: Cloud hosting, database, and content delivery providers who process data on our behalf under data processing agreements that restrict their use of your data.
• Analytics and security services: Technical data (including IP addresses and device information) may be shared with fraud detection and platform analytics services to identify security threats and improve platform performance.
• Legal and regulatory authorities: Where we receive a lawful request from a competent authority, or where disclosure is required by applicable law, we will share data as required. We will not disclose more than is legally required.

All third parties who process personal data on 939bat's behalf are contractually required to handle that data securely and only for the purpose for which it was shared. We do not permit third-party processors to use your data for their own unrelated purposes.

6. Payment Data

When you make a deposit or request a withdrawal on 939bat, the transaction is processed through your chosen payment method — JazzCash, Easypaisa, Raast, bank transfer, or card. The data you enter with the payment provider is handled by that provider under their own terms and privacy policy. 939bat receives transaction reference numbers and status confirmations from payment providers, but does not store your full card numbers, JazzCash/Easypaisa PINs, or bank account credentials on our servers.

All deposits and withdrawals on 939bat are denominated in PKR. Transaction records — including amounts, dates, methods used, and balance changes — are retained on your account for the period described in Section 8.

Payment methods linked to your account must be in your own name. We may cross-reference payment details against identity documents during KYC to confirm this. Third-party payment sources are not permitted and will result in the transaction being returned and the account reviewed.

7. Cookies and Tracking Technologies

939bat uses cookies and similar tracking technologies to operate the platform, remember your session, and understand how users interact with the site. The main types of cookies we use are:

• Essential cookies: Required for the platform to function. These include session cookies that keep you logged in during your visit and security tokens that protect against cross-site request forgery. These cannot be disabled without breaking the platform.
• Functional cookies: Remember your preferences — such as language settings and last-used payment method — to improve your experience across sessions.
• Analytics cookies: Used to understand which parts of the platform are used most, where users encounter problems, and how navigation flows work. This data is aggregated and does not directly identify you.
• Security and fraud detection cookies: Used to identify unusual login behaviour, detect bot activity, and flag suspicious patterns that may indicate account compromise or abuse.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will affect your ability to use the platform. Most modern browsers allow you to see which cookies are stored and delete them selectively.

8. Data Retention

939bat retains personal data for as long as your account is active and for a defined period after account closure. Retention periods vary by data type:

• Account and identity data: Retained for the duration of your account and for a minimum of five years after account closure, to support fraud prevention and legal compliance obligations.
• Transaction and financial records: Retained for a minimum of five years from the date of each transaction. This is standard practice for financial record-keeping.
• KYC documents: Retained for the duration of the account relationship and for a defined period following account closure, in line with anti-money laundering record-keeping requirements.
• Gaming and betting history: Retained on your account for the life of the account. Aggregated gaming data may be retained in anonymised form for longer periods for platform analytics purposes.
• Support communications: Retained for up to three years from the date of the communication, to support complaint resolution and service improvement.
• Technical and log data: Typically retained for up to 12 months, after which it is deleted or anonymised.

When data is no longer required for the purpose for which it was collected and the applicable retention period has passed, it is securely deleted or anonymised.

9. Data Security

939bat takes data security seriously and has implemented technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. Key security measures include:

• Encryption of data in transit between your device and the 939bat platform using TLS/SSL protocols.
• Access controls that restrict which staff can view personal data, based on role and necessity.
• Secure password storage — passwords are hashed and never stored in plain text.
• Regular security assessments of platform infrastructure and third-party integrations.
• Logging and monitoring of access to sensitive data systems to detect unusual activity.

While we take every reasonable step to protect your data, no online platform can guarantee absolute security. You also have a role to play — keeping your login credentials confidential, not sharing your account with others, and reporting any suspected unauthorised access to support promptly. See the Terms and Conditions for your account security responsibilities.

In the event of a personal data breach that is likely to result in a risk to your rights or interests, 939bat will take appropriate steps to address the breach and notify affected users as required.

10. Your Data Rights

As a user of 939bat, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] from the email address registered to your account.

Note that some rights are subject to limitations — for example, we cannot delete data that we are legally required to retain. Where we are unable to fulfil a request in full, we will explain the reason.

11. Children and Underage Users

939bat is strictly for adults aged 18 and above. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that a user is under 18, the account will be closed immediately, any deposits will be returned, and all data associated with the account will be deleted in line with our retention policy.

If you believe that a person under 18 has registered an account on 939bat, please contact us immediately at [email protected]. For more on the platform's approach to underage access and responsible gaming, see the Responsible Gaming page.

12. Changes to This Privacy Policy

939bat may update this Privacy Policy from time to time. When changes are made, the revised policy will be published on this page with an updated "last updated" date. Where changes are material — meaning they significantly affect how we use your personal data — registered users will be notified by email or via an in-platform notification.

Continued use of the 939bat platform after a revised Privacy Policy has been published and you have been notified constitutes your acceptance of the updated terms. If you do not accept the updated policy, you should stop using the platform and contact support to close your account and request data deletion in line with Section 10.

We recommend checking this page periodically, particularly if you receive a notification that the policy has been updated.

13. Contact Us

If you have any questions about this Privacy Policy, want to understand how your data is being used, or wish to exercise any of your data rights, please get in touch:

• Email: [email protected]
• Support channel: Available within your logged-in account dashboard.

When contacting us about a data rights request, please use the email address registered to your 939bat account so we can verify your identity before processing the request.

For related policies and information, see:

• Terms and Conditions — the full platform usage agreement.
• Responsible Gaming — tools and guidance for managing your gaming activity.
• FAQ — common questions about accounts, payments, and platform features.