Privacy Policy

This Privacy Policy ("Policy") is issued by dat939 ("we", "us", "our", "the Platform") and applies to all personal data collected from users ("you", "your") of the dat939 website accessible at https://dat939.cam and all associated services, betting markets, casino games, promotional features and communications (collectively "the Services").

We are committed to protecting your personal data and processing it lawfully, fairly and transparently in accordance with applicable data protection legislation. This Policy explains what data we collect, why we collect it, how we use it, with whom we may share it, how long we retain it, and what rights you hold in relation to your personal information.

By accessing the Platform, registering an account or otherwise using the Services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree to this Policy, you must cease using the Platform immediately.

For the purposes of this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure and deletion.
• "Data Subject" means the identified or identifiable natural person to whom personal data relates — in this context, you as a user of the Platform.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, dat939.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller.
• "KYC" means Know Your Customer — the identity, age and source-of-funds verification process required for account compliance.
• "AML" means Anti-Money Laundering — legal and regulatory obligations relating to the prevention of financial crime.
• "Cookies" means small text files placed on your device by a website to record information about your visit and preferences.
• "Third Party" means any entity other than you and dat939.

We may collect and process the following categories of personal data about you:

Identity Data

Full legal name, date of birth, nationality, CNIC (Computerised National Identity Card) number or passport number, and photographs submitted as part of identity verification.

Contact Data

Email address, mobile telephone number, and city or country of residence (for example, Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar).

KYC and Verification Documents

Copies of government-issued identity documents (CNIC, passport), proof of address documents (utility bills, bank statements), and liveness check photographs or video.

Financial and Transaction Data

Deposit and withdrawal history, payment method references (e.g., wallet identifiers or masked bank account numbers associated with methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah where applicable), transaction amounts in PKR and any applicable currency, and transaction timestamps. Payment method references are collected solely to process transactions and verify ownership — not to imply that any provider endorses gambling services.

Technical and Device Data

IP address, device type and model, operating system, browser type and version, device identifiers, screen resolution, time zone settings (Pakistan Standard Time, UTC+5), and connection metadata.

Usage and Behavioural Data

Betting and gaming history, session durations, pages visited, game preferences, wagering patterns, bonus activation records, and in-app navigation behaviour.

Communication Records

Records of correspondence you send to us via live chat, email or any support channel, including the content of messages and timestamps.

Responsible Gambling Data

Deposit limits, loss limits, session time limits, cooling-off periods, self-exclusion status and any communications relating to responsible gambling tool activation or support requests.

We collect personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC, making deposits or withdrawals, contacting support, activating responsible gambling tools, or participating in promotions.
• Automated technical collection: Data collected automatically when you access the Platform, including IP addresses, device data, cookies, session logs and analytical telemetry.
• Third-party KYC and compliance providers: Identity and document verification data returned by third-party KYC service providers engaged to assist with our compliance obligations.
• Payment processors: Transaction confirmation and status data returned by payment processing partners.
• Fraud and security monitoring systems: Behavioural and technical signals processed by automated risk-management systems to detect suspicious activity.

We process your personal data on one or more of the following lawful bases:

• Contract performance: Processing necessary to deliver the Services under our Terms & Conditions, including account management, transaction processing and customer support.
• Legal obligation: Processing required to comply with KYC, AML, fraud prevention and other applicable legal and regulatory obligations.
• Legitimate interests: Processing carried out in pursuit of our legitimate business interests — including platform security, fraud detection, responsible gambling monitoring and service improvement — where those interests are not overridden by your rights.
• Consent: Where we rely on your consent (for example, for certain cookies or marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

We use your personal data for the following purposes:

1. To create, verify and manage your Account, including KYC identity and age verification;
2. To process deposits, withdrawals and other financial transactions;
3. To deliver and improve the betting and gaming Services;
4. To communicate with you regarding your Account, transactions and support queries;
5. To detect, investigate and prevent fraud, money laundering and other financial crime;
6. To enforce our Terms & Conditions and other applicable policies;
7. To monitor and support responsible gambling, including the operation of deposit limits, loss limits, self-exclusion and cooling-off tools;
8. To comply with applicable legal, regulatory and reporting obligations;
9. To analyse Platform usage, identify bugs and improve overall user experience;
10. To send service-related communications (not marketing) as required by your account status or regulatory requirements.

We do not sell, rent or trade your personal data. We may share your data with third parties only in the following circumstances and only to the extent necessary:

• KYC and identity verification providers: To fulfil legal identity, age and document verification obligations;
• Payment processors: To facilitate deposits, withdrawals and associated fraud-screening checks;
• Technology and infrastructure providers: Cloud hosting, data storage, security and analytics providers operating as Data Processors under binding data protection agreements;
• Fraud and AML screening services: To detect suspicious transactions and prevent financial crime;
• Legal and regulatory authorities: Where required by applicable law, court order, regulatory direction or law enforcement request;
• Professional advisers: Legal counsel, auditors and insurers, subject to professional confidentiality obligations;
• Business successors: In the event of a merger, acquisition or asset sale, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party Data Processors are bound by contractual obligations to process your data only for the specified purpose, to maintain confidentiality and to apply security standards no less rigorous than our own.

The nature of an international online platform means that your personal data may be processed in countries other than your country of residence, including countries that may not have data protection laws equivalent to those in your jurisdiction.

Where we transfer personal data internationally, we implement appropriate safeguards to protect your data, which may include standard contractual clauses approved under applicable data protection frameworks, binding corporate rules, or reliance on adequacy decisions where applicable.

By using the Platform and providing your personal data, you acknowledge that your data may be transferred, stored and processed in other jurisdictions as described in this Policy.

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including for the duration of your Account and for as long as required by applicable law, regulation and legitimate business need.

In particular:

• Account and KYC data is typically retained for a minimum of five (5) years following account closure to comply with AML and regulatory record-keeping obligations;
• Transaction records are retained for a minimum of five (5) years to satisfy financial reporting and anti-money-laundering requirements;
• Responsible gambling records (including self-exclusion data) are retained for the duration of the exclusion period and for a reasonable period thereafter to prevent re-registration;
• Communication records are retained for up to two (2) years or longer where subject to an ongoing dispute or legal proceeding;
• Technical and device data generated through cookies and analytics is retained in accordance with the cookie lifetimes described in Section 11.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data deletion procedures.

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction or alteration. Measures include, but are not limited to:

• TLS/SSL encryption across all Platform pages and API endpoints;
• Encrypted storage of sensitive personal data including KYC documents;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Two-factor authentication options for user accounts;
• Automated fraud and anomaly detection monitoring;
• Regular security assessments and vulnerability reviews;
• Incident response procedures to detect, contain and notify affected parties of data breaches within applicable timescales.

Notwithstanding the above, no security system is impenetrable. You are responsible for maintaining the confidentiality of your login credentials and for notifying us immediately if you suspect any unauthorised access to your Account.

The Platform uses cookies and similar tracking technologies to ensure essential functionality, analyse usage patterns and improve the user experience. The following categories of cookies may be used:

• Strictly Necessary Cookies: Required for the Platform to function. These cannot be disabled without preventing access to core features, including session management and login state.
• Performance and Analytics Cookies: Collect anonymised information about how users interact with the Platform — pages visited, session duration and error events — to help us improve performance.
• Functional Cookies: Store your preferences such as language settings, PKR currency display preferences and responsible gambling tool status.
• Security Cookies: Support fraud prevention and anomaly detection by assigning session tokens and detecting repeated failed login attempts.

You may configure your browser to block or delete cookies; however, doing so may affect your ability to use certain features of the Platform. Strictly necessary cookies cannot be opted out of without ceasing use of the Platform.

As part of our legal obligations to prevent identity fraud, underage gambling, money laundering and terrorist financing, we are required to collect and verify identity documentation. For Pakistani users, this typically includes a valid CNIC or passport, and may include proof of address and a liveness verification photograph.

KYC documents submitted to the Platform must be genuine and unaltered. Documents are processed through our secure HTTPS verification portal — you must never send identity documents via unencrypted email, WhatsApp or social media.

KYC data is processed on the lawful bases of legal obligation and contract performance. It is shared only with authorised KYC verification service providers under binding data processing agreements, and with regulatory or law enforcement authorities as legally required.

The Platform is strictly for adults aged 18 or above — or the higher minimum age required by the applicable license jurisdiction. We do not knowingly collect personal data from individuals under the minimum eligible age.

If we become aware, or have reasonable grounds to suspect, that personal data has been collected from a minor, we will take immediate steps to verify the individual's age and, if confirmed as underage, to delete the associated data and close the Account in accordance with our Terms & Conditions.

If you believe that a minor has registered on the Platform or that we hold personal data relating to a minor, please contact us immediately using the details in Section 17.

Subject to applicable law and certain exceptions, you hold the following rights in respect of your personal data:

To exercise any of the above rights, please contact us at the details provided in Section 17. We will respond within the timeframe required by applicable law. We may need to verify your identity before processing a rights request.

We will not apply any charge for exercising your rights unless a request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply or we may refuse the request, with reasons given.

Personal data relating to your responsible gambling settings — including deposit limits, loss limits, session time limits, self-exclusion status and cooling-off periods — is treated with particular care given its sensitive nature.

This data is processed solely for the purpose of operating responsible gambling controls and ensuring that your stated restrictions are enforced across all access points to your Account. It is not used for profiling, marketing or any purpose beyond the direct operation of player protection tools.

Self-exclusion records are retained beyond Account closure to prevent re-registration during an active exclusion period. This retention is carried out on the basis of legal obligation and legitimate interest in player protection.

For full details of the responsible gambling tools available on the Platform, please visit our Responsible Gambling page.

We reserve the right to update or amend this Privacy Policy at any time. The date of the most recent revision is shown at the top of this page. Where a material change is made to this Policy, we will endeavour to provide reasonable notice via email or a prominent notice on the Platform prior to the change taking effect.

Your continued use of the Platform following the publication of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed of how we protect your personal data.

If you have any questions, concerns or requests relating to this Privacy Policy or our handling of your personal data — including requests to exercise your data subject rights — please contact us using the details below. We are committed to responding promptly and transparently.

Please allow us a reasonable period to verify your identity before processing any data subject rights request. For responsible gambling tool requests, account closure or self-exclusion, please also contact us using the address above or visit our Responsible Gambling page.