bat939 Privacy Policy

1. Who We Are & How to Contact Us

bat939 is the operator of the online sports betting and casino platform accessible at bat939.app ("Platform"). For the purposes of this Privacy Policy, bat939 acts as the data controller in respect of personal data collected from users of the Platform. bat939 is committed to operating in compliance with applicable data protection laws and international best practices in data privacy.

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to report a privacy concern, you may contact bat939's data privacy team at the support email address displayed in the footer of this page. bat939 aims to respond to all privacy-related enquiries within ten (10) business days.

2. Personal Data We Collect

bat939 collects personal data from you in the following categories, depending on how you interact with the Platform:

• Registration Data: When you create a bat939 account, we collect your full name, date of birth, mobile number, email address, and a password (stored as an irreversible hash). This data is necessary to create and operate your account.
• Identity Verification (KYC) Data: To comply with anti-money-laundering obligations and to verify your age (minimum 18 years), bat939 collects a copy of your CNIC (Computerised National Identity Card) and may request a selfie photograph or other supporting identification documents. This data is processed solely for KYC verification purposes.
• Financial Data: bat939 collects transaction records including deposit amounts, withdrawal requests, payment method identifiers (e.g., JazzCash mobile number, Easypaisa account reference, or bank account name), and transaction timestamps. bat939 does not store full payment card numbers or mobile banking PINs.
• Betting & Gaming Activity Data: bat939 maintains records of all bets placed, games played, wager amounts, outcomes, and balance history associated with your account. This data is used for account management, dispute resolution, and responsible gaming monitoring.
• Device & Technical Data: bat939 automatically collects certain technical data when you access the Platform, including IP address, device type, operating system, browser type, session duration, and referring URL. This data is used for security, fraud prevention, and platform performance analysis.
• Communications Data: If you contact bat939 customer support via live chat, email, or any other channel, we retain records of those communications for quality assurance and dispute resolution purposes.

3. How We Use Your Personal Data

bat939 uses the personal data described above for the following purposes:

• To create, verify, operate, and maintain your bat939 account.
• To process deposits, withdrawals, and other financial transactions in PKR via supported Pakistani payment methods including JazzCash, Easypaisa, HBL, UBL, Meezan Bank, and Bank Alfalah.
• To fulfil our KYC and anti-money-laundering obligations, including verifying your identity and age (minimum 18 years) before processing withdrawal requests.
• To detect, investigate, and prevent fraud, collusion, money laundering, underage gambling, and any other prohibited conduct as defined in the bat939 Terms & Conditions.
• To operate bat939's responsible gaming programme, including monitoring betting patterns, applying deposit limits, and facilitating self-exclusion where requested.
• To respond to your customer support enquiries and to resolve disputes relating to your bat939 account or any bet or game.
• To send you service communications relating to your account, including security alerts, withdrawal confirmations, and material changes to bat939's Terms or this Privacy Policy.
• To improve the bat939 platform and user experience through aggregated, anonymised analysis of usage patterns. bat939 does not use individually identifiable data for this purpose.

4. Legal Basis for Processing

bat939 processes your personal data on the following legal bases:

• Contractual Necessity: Processing of registration data, financial data, and betting activity data is necessary for the performance of the contract between you and bat939 (your account and these Terms & Conditions).
• Legal Obligation: KYC processing, AML record-keeping, and age verification are necessary for bat939 to comply with legal and regulatory obligations imposed by the jurisdictions in which bat939 operates.
• Legitimate Interests: Processing of device and technical data for fraud prevention, security, and platform stability is undertaken on the basis of bat939's legitimate interest in protecting the integrity of the Platform and the safety of all users.
• Consent: Where bat939 sends you optional marketing communications about promotions, bonuses, or new features, such communications are sent only with your express prior consent. You may withdraw this consent at any time through your bat939 account settings or by contacting customer support.

5. Cookies & Tracking Technologies

bat939 uses cookies and similar tracking technologies on the Platform to deliver and improve the service. Cookies are small text files placed on your device when you access the bat939 website. bat939 uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are required for the bat939 Login session management, security token handling, and core Platform functionality. They cannot be disabled without impairing your ability to use the Platform.
• Performance Cookies: These cookies collect anonymised data about how users navigate and use the bat939 Platform to help us identify and fix performance issues and improve usability.
• Functional Cookies: These cookies remember your preferences such as language, display settings, and responsible gaming tool configurations so you do not need to re-enter them each session.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the bat939 Platform, including session persistence after login.

6. Sharing Your Personal Data

bat939 does not sell, rent, or trade your personal data to third parties. bat939 may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment Processors: bat939 shares your payment method identifiers and transaction data with the payment service providers required to complete your PKR deposit or withdrawal (e.g., JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah). These providers are contractually bound to process your data solely for payment execution.
• KYC Verification Providers: bat939 may use third-party identity verification service providers to process CNIC data. These providers operate under strict data processing agreements and are not permitted to use your KYC data for any purpose other than identity verification.
• Regulatory Authorities: bat939 may be required to disclose personal data, including KYC records and transaction history, to regulatory authorities, law enforcement bodies, or courts of competent jurisdiction, where required by applicable law or a valid legal order.
• IT Service Providers: bat939's Platform is hosted on third-party cloud infrastructure. Server infrastructure providers may have technical access to data stored on their systems, subject to strict data processing and security agreements with bat939.

7. International Data Transfers

As an international online platform, bat939 may process or store personal data on servers located outside Pakistan. Where personal data is transferred internationally, bat939 ensures that such transfers are conducted in accordance with applicable data protection standards, including the use of contractual safeguards where required. bat939 will not transfer personal data to jurisdictions that do not offer adequate data protection without implementing appropriate protective measures.

8. Data Retention

bat939 retains personal data for no longer than is necessary for the purposes described in this Privacy Policy, or as required by applicable law. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a period of five (5) years after account closure, consistent with anti-money-laundering regulatory requirements.
• KYC Data: Retained for a minimum of five (5) years after account closure, or longer if required by applicable AML regulations.
• Transaction Records: Retained for five (5) years from the date of each transaction.
• Customer Support Communications: Retained for three (3) years from the date of the last communication in a support thread.
• Technical/Device Data: Retained for twelve (12) months from collection for fraud prevention and security analysis purposes, then deleted or anonymised.

After the applicable retention period, personal data is securely deleted or irreversibly anonymised.

9. Your Data Rights

Subject to applicable law and certain legitimate exceptions (including legal retention obligations and AML requirements), bat939 users have the following rights in relation to their personal data:

• Right of Access: You have the right to request a copy of the personal data bat939 holds about you.
• Right to Rectification: You have the right to request correction of inaccurate personal data held by bat939.
• Right to Erasure: You may request deletion of your personal data. bat939 will fulfil erasure requests to the extent permitted by legal retention obligations.
• Right to Restriction: You may request that bat939 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data.
• Right to Object: You may object to processing of your personal data based on legitimate interests, including processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw your consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact bat939 customer support via the email address in the footer of this page. bat939 will respond to data rights requests within thirty (30) days of receipt.

10. Security of Personal Data

bat939 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include 256-bit SSL/TLS encryption for all data transmitted between your device and bat939's servers, encryption of sensitive data at rest, access controls limiting data access to authorised bat939 personnel, regular security reviews, and two-factor authentication availability for all bat939 accounts.

While bat939 takes all commercially reasonable precautions to protect your data, no online platform can guarantee absolute security. If you become aware of any security vulnerability or suspect that your bat939 account has been compromised, please notify bat939's security team immediately via the support contact in the footer of this page.

11. Children & Minors

The bat939 Platform is strictly for adults aged 18 years and above. bat939 does not knowingly collect or process personal data from individuals under the age of 18. Age is verified as part of the mandatory KYC process that all account holders must complete before withdrawing funds. If bat939 discovers that personal data has been collected from a person under 18, that account will be suspended immediately, all data associated with the account will be deleted to the extent permitted by legal obligations, and any deposits may be returned.

If you believe that bat939 holds personal data relating to a minor, please contact bat939 customer support immediately so the matter can be investigated and remedied without delay.

12. Changes to This Privacy Policy

bat939 may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or Platform features. When material changes are made, bat939 will notify registered users via their registered email address and will publish the updated Privacy Policy on this page with a revised "Last Updated" date.

Your continued use of the bat939 Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to a material change, you must cease using the Platform and may request closure of your account in accordance with the bat939 Terms & Conditions.