01Introduction
This Privacy Policy applies to all services provided by 939 Bat through the website https://939bat.app and any associated mobile interfaces, apps or communications. It applies to every person who registers an account, visits the website without registering, or interacts with 939 Bat's customer support channels.
939 Bat operates as an online betting and casino platform serving players in Pakistan. By creating an account or using any part of the platform, you confirm that you have read this Privacy Policy and that you consent to the collection and use of your personal data as described here.
We collect only the data we actually need to run the platform, verify your identity and comply with our legal obligations. We don't build profiles for advertising networks. We don't sell your data. We don't share it with organisations that have no legitimate reason to receive it. If those three things are all you take from this policy, you're already understanding the most important parts — but reading the full document is worthwhile because the details matter.
Plain language summary: This policy tells you what information 939 Bat has about you, why we have it and what we do with it. It also explains your rights — including how to ask us to delete your data.
02Personal Data We Collect
The personal data 939 Bat collects about you falls into four broad categories:
Registration & Identity Data
- Full name as it appears on your CNIC
- Date of birth (to verify you are 18 or over)
- Pakistani CNIC number (collected during KYC verification)
- Email address
- Mobile phone number (used for account authentication and transaction notifications)
- City and province of residence
Financial & Transaction Data
- Payment method details — mobile wallet number (Easypaisa, JazzCash, NayaPay, SadaPay), bank account IBAN for IBFT, or masked card number for Visa/Mastercard transactions
- Deposit and withdrawal history including amounts, timestamps and method used
- Betting and gaming transaction history
- Account balance history
Usage & Technical Data
- IP address at time of login and transactions
- Device type, operating system and browser version
- Pages visited on 939 Bat and time spent on each section
- Session timestamps — when you logged in and logged out
- Game and betting activity logs
Communication Data
- Records of support tickets, live chat transcripts and email correspondence you have with 939 Bat
- Survey responses if you participate in any player feedback exercise
- Complaints and dispute records
939 Bat does not store full card numbers, CVV codes or card PINs. Card payment data is processed through a PCI-DSS compliant payment gateway and is never stored on 939 Bat servers.
03How We Collect Your Data
Data is collected through the following channels:
- Directly from you — when you fill in the registration form, complete KYC verification, make a deposit, submit a support request or respond to any communication from 939 Bat.
- Automatically during platform use — your device's IP address, browser type and session behaviour are recorded automatically when you access 939 Bat, regardless of whether you are logged in.
- From payment providers — when you initiate a deposit or withdrawal, 939 Bat receives a transaction confirmation from the payment provider (Easypaisa, JazzCash etc.) that includes the transaction reference, amount and the mobile number or account associated with the transaction.
- From identity verification services — if 939 Bat uses a third-party KYC verification provider to check CNIC authenticity, that provider may return a verified/not-verified result along with the data points checked.
- Through cookies and tracking technologies — see Section 9 for full details on how cookies are used on 939 Bat.
04Why We Use Your Personal Data
Every piece of data 939 Bat holds has a specific purpose. Here is the complete list of what we do with your data and why:
| Purpose |
Data Used |
Why It's Needed |
| Account creation |
Name, email, mobile number, DOB |
To create and maintain your 939 Bat account |
| Identity verification (KYC) |
CNIC number, full name, DOB |
Legal obligation — verify age and identity before withdrawals |
| Processing deposits |
Payment account details, amount |
To receive and credit your PKR deposits |
| Processing withdrawals |
Payment account details, verified identity |
To send PKR to your verified payment account |
| Fraud prevention |
IP address, device data, transaction patterns |
To detect and block fraudulent account or payment activity |
| Customer support |
Account data, communication history |
To resolve queries, disputes and technical issues |
| Responsible gaming |
Betting history, session data, deposit patterns |
To identify problem gambling indicators and apply limits where appropriate |
| Platform improvement |
Anonymised usage data |
To understand how the platform is used and improve it |
| Marketing communications |
Email, mobile number (opt-in only) |
To send promotions, bonus offers and product updates where you have consented |
05Legal Basis for Processing
939 Bat processes your personal data on the following legal grounds:
- Contractual necessity: When you create an account and agree to our Terms and Conditions, a contract is formed. Processing your identity, payment and betting data is necessary to fulfil our obligations under that contract — you cannot receive deposits, place bets or receive withdrawals without this processing.
- Legal obligation: As an operator providing financial services, 939 Bat is required to conduct identity verification (KYC) and maintain transaction records. These requirements exist independently of the contract with you.
- Legitimate interests: 939 Bat has a legitimate interest in preventing fraud, maintaining platform security and conducting basic analytics to improve the service. This processing does not override your fundamental rights because it is proportionate to a genuine operational need.
- Consent: For marketing communications — promotional emails, bonus notifications and product updates — 939 Bat processes your data only where you have given clear consent. You can withdraw this consent at any time through your account settings or by contacting support.
06Who We Share Your Data With
939 Bat does not sell your personal data to any third party under any circumstances. Data may be shared with the following categories of recipients, and only to the extent necessary for the stated purpose:
- Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT networks and Visa/Mastercard processing gateways receive the transaction data necessary to process your deposit or withdrawal. Each provider operates under their own privacy policy and financial services regulations.
- KYC and identity verification providers: Third-party services used to verify CNIC authenticity may receive your name, CNIC number and date of birth solely for verification purposes. These providers are contractually bound to use the data only for verification and to maintain its security.
- Fraud prevention services: Device fingerprinting and fraud detection providers may receive technical data (IP address, device identifiers, behavioural data) to identify suspicious activity. No personal identity data is shared with these providers beyond what is technically necessary.
- Legal and regulatory authorities: Where required by applicable Pakistani law — including requests from the Financial Monitoring Unit (FMU) under anti-money laundering regulations — 939 Bat may be required to disclose player data without prior notice to the player. 939 Bat will only comply with such requests where they are lawful and properly made.
- Platform technology providers: Cloud hosting, database management and customer support software providers may process your data as part of delivering the technical infrastructure of the platform. These providers are contracted to handle data only on 939 Bat's instructions and to maintain appropriate security standards.
In every case where data is shared with a third party, 939 Bat ensures that a data processing agreement or equivalent contractual protection is in place. Data is shared to the minimum extent necessary for the specific purpose.
07How Long We Keep Your Data
939 Bat retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:
- Active account data: Retained for the duration of your account's active status plus a period of five years after account closure. This allows us to respond to any disputes, regulatory enquiries or legal claims that may arise after closure.
- Transaction records: Financial transaction records — deposits, withdrawals and betting history — are retained for a minimum of five years from the date of the transaction. This is consistent with standard financial record-keeping requirements.
- KYC identity documents: Copies of CNIC and any other identity documents submitted are retained for five years from the date of account closure. These records may be required for regulatory compliance purposes.
- Support and communication records: Customer support tickets, live chat logs and email correspondence are retained for three years from the date of the last communication, unless a longer period is required due to an ongoing dispute.
- Technical and usage data (anonymised): Aggregate anonymised usage data with no personal identifiers may be retained indefinitely for platform analytics purposes.
After the applicable retention period has elapsed, personal data is securely deleted or permanently anonymised. Anonymised data cannot be used to re-identify you and is not subject to the rights described in Section 10.
08How We Secure Your Data
939 Bat takes the security of player data seriously. The following technical and organisational measures are in place to protect personal data against unauthorised access, alteration, disclosure or destruction:
- SSL/TLS encryption in transit: All data transmitted between your device and 939 Bat servers is encrypted using 256-bit SSL/TLS. This applies to all pages of the platform including login, registration, deposit and withdrawal flows.
- Encryption at rest: Sensitive personal data stored in 939 Bat databases — including identity information and payment account references — is encrypted at rest using AES-256 or equivalent standard.
- Access controls: Internal access to player data is restricted to staff members who require it for their specific job function. Access is controlled by role-based permissions and all access is logged and auditable.
- Two-factor authentication: Available to players for account login and withdrawal requests. Strongly recommended. Internally, all staff with access to player data systems are required to use 2FA.
- Penetration testing and vulnerability management: 939 Bat conducts regular security assessments of its platform infrastructure to identify and remediate vulnerabilities before they can be exploited.
- Incident response: In the event of a data breach that poses a risk to players, 939 Bat will notify affected players as promptly as reasonably possible and take immediate steps to contain and remediate the breach.
No security system is completely impenetrable. While 939 Bat takes all reasonable precautions, players are also responsible for keeping their own login credentials secure and reporting any suspected unauthorised access promptly.
09Cookies & Tracking Technologies
939 Bat uses cookies and similar tracking technologies to operate the platform, improve performance, maintain session security and understand how players use the service. The following categories of cookies are used:
Essential Cookies
Required for login sessions, security tokens and core platform functionality. Cannot be disabled.
Always On
Functional Cookies
Remember your preferences such as language, display settings and last-used payment method.
On by Default
Analytics Cookies
Track which pages are visited and how long players spend on each section. Data is anonymised and used only to improve the platform.
On by Default
Marketing Cookies
Track referral sources to attribute registrations to the correct affiliate or Refer a Friend link. No third-party advertising network cookies are used.
Opt-In Only
You can manage cookie preferences through your browser settings at any time. Disabling essential cookies will prevent the platform from functioning correctly — you will not be able to log in or process transactions. Disabling other cookie categories does not affect core platform access.
939 Bat does not use third-party advertising cookies or share tracking data with advertising networks. The only third-party cookies present on the platform are those associated with the payment gateway interfaces and any approved analytics service operating under a data processing agreement.
10Your Rights Over Your Personal Data
As a 939 Bat player, you have the following rights in relation to your personal data. These rights can be exercised by contacting support@939bat.app with your registered account details and a clear description of the request.
Right of Access
You can request a copy of all personal data 939 Bat holds about you. We will provide this within 30 days of receiving a verified request. The data will be provided in a readable format — typically a structured document delivered to your registered email address.
Right to Rectification
If any personal data we hold about you is inaccurate or incomplete, you have the right to request a correction. Contact support with the correct information and we will update our records promptly. Note that changes to identity data (CNIC number, full name, date of birth) require supporting documentation.
Right to Erasure
You can request deletion of your personal data — commonly known as the "right to be forgotten." However, this right is not absolute. We are legally required to retain certain data (particularly financial transaction records and KYC documentation) for a minimum of five years. Where data must be retained for legal reasons, it will be restricted rather than deleted — meaning it will not be used for any purpose other than fulfilling the legal obligation.
Right to Restrict Processing
You can ask 939 Bat to restrict the processing of your data in certain circumstances — for example, while a dispute about data accuracy is being resolved. During the restriction period, your data will be stored but not actively used for any purpose.
Right to Data Portability
You can request your personal data in a structured, machine-readable format (such as CSV or JSON) that allows you to transfer it to another service. This right applies to data you provided directly to 939 Bat and which was processed by automated means.
Right to Withdraw Consent
Where 939 Bat processes your data based on your consent — for example, for marketing emails — you can withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of processing that occurred before the withdrawal. To opt out of marketing communications, use the unsubscribe link in any email or update your preferences in account settings.
We aim to respond to all data rights requests within 30 calendar days. Complex requests may take up to 60 days, in which case we will notify you of the extension and the reason for it. Requests will be processed at no charge in the vast majority of cases.
11Children and Minors
939 Bat is strictly for adults aged 18 and over. The platform does not knowingly collect personal data from anyone under the age of 18. Age is verified during the KYC process, and any account found to belong to a minor will be closed immediately and all associated personal data will be deleted, with the exception of records required to demonstrate compliance with the age verification obligation.
If you are a parent or guardian and you believe that a minor has created an account on 939 Bat without your knowledge, please contact support@939bat.app immediately with the account details. We will investigate and close the account as a priority and will confirm the closure and data deletion to you once complete.
12Changes to This Privacy Policy
939 Bat may update this Privacy Policy from time to time to reflect changes in the platform, applicable law or our data processing practices. The "Last updated" date at the top of this page will always reflect the most recent revision.
For material changes — those that significantly affect how your data is used or your rights over it — 939 Bat will notify registered players by email to the address on file at least 14 days before the changes take effect. For minor or administrative changes, the updated policy takes effect immediately upon publication and your continued use of 939 Bat constitutes acceptance.
We encourage you to review this policy periodically. If you disagree with any changes to the Privacy Policy, you have the right to close your account before the changes take effect.
