dat939 Privacy Policy

1Introduction

dat939 ("we", "us", "our") is committed to protecting the privacy and personal data of every individual who visits, registers, or otherwise interacts with the dat939 platform at dat939.com. This Privacy Policy has been prepared in accordance with internationally recognised data protection principles and is intended to provide you – our valued Pakistani players and website visitors – with a clear, honest account of how we handle your information.

By registering an account on dat939 or by continuing to use the dat939 platform, you confirm that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of the platform immediately and may contact us to request closure of your account.

This policy applies to all personal data collected by dat939 through the dat939.com website, any mobile-optimised version of the platform, communications sent to and from dat939 customer support, and data provided voluntarily during registration or KYC verification. It applies to players located across Pakistan – including Karachi, Lahore, Faisalabad, Islamabad, Rawalpindi, and all other cities and regions.

2Personal Data We Collect

dat939 collects personal data in several categories depending on the nature of your interaction with the platform. The categories below describe the types of personal information dat939 may hold about you:

2.1 Identity Data

• Full legal name as appearing on your Pakistani National Identity Card (CNIC)
• Date of birth (to verify you are 21 years of age or older)
• Gender (where provided during registration)
• CNIC number and scanned copies of identity documents submitted during KYC verification
• Selfie or photograph submitted for identity matching purposes

2.2 Contact Data

• Email address registered to your dat939 account
• Pakistani mobile phone number (including JazzCash or EasyPaisa registered numbers)
• Residential address in Pakistan, including city, district, and postal code

2.3 Financial Data

• JazzCash or EasyPaisa account number or mobile wallet identifier
• HBL, UBL, or Meezan Bank account details provided for deposit or withdrawal
• Transaction history including deposit amounts, withdrawal requests, and PKR balances
• Source of funds documentation where required under anti-money-laundering procedures

2.4 Gaming and Behavioural Data

• Betting history, wagering amounts, game preferences, and session durations
• Win and loss records across all dat939 gaming products
• Bonus claims, wagering requirement progress, and promotional participation records
• Responsible gaming settings such as deposit limits, session limits, or self-exclusion status

2.5 Technical Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser type and version
• Log data including pages visited, links clicked, and time spent on each section
• Cookie identifiers and session tokens

2.6 Communications Data

• Contents of live chat conversations with dat939 customer support agents
• Email correspondence submitted to dat939's support team
• Feedback, complaint, or dispute submissions

3How We Collect Your Data

dat939 collects personal data through the following means:

3.1 Direct Interactions

When you register a dat939 account, complete KYC verification, make a deposit or withdrawal request, contact customer support, or participate in any promotion, you directly provide us with personal data. This is the primary source of identity, contact, and financial data held by dat939.

3.2 Automated Technologies

When you browse or use the dat939 platform, we automatically collect certain technical data through cookies, server logs, and similar tracking technologies. This includes your IP address, device information, and browsing behaviour on the dat939 platform. See Section 8 for full details on our use of cookies.

3.3 Third-Party Sources

dat939 may receive limited personal data from third-party sources including:

• Payment processors such as JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, who may confirm transaction completion and account ownership
• Identity verification service providers used during KYC processing
• Fraud detection and anti-money-laundering screening services
• Analytics providers who supply aggregated, anonymised behavioural data

4How We Use Your Personal Data

dat939 uses the personal data we collect for specific, legitimate purposes only. We do not use your data for purposes that are incompatible with those originally disclosed to you. The primary purposes for which we process your data are as follows:

5Legal Basis for Processing

dat939 processes your personal data under the following legal bases, consistent with internationally recognised data protection frameworks:

• Contractual Necessity: Processing required to fulfil our obligations to you under the dat939 Terms and Conditions — including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable anti-money-laundering (AML) regulations, Know Your Customer (KYC) requirements, and other regulatory obligations applicable to dat939's licensed operations.
• Legitimate Interests: Processing carried out to pursue the legitimate interests of dat939, such as fraud prevention, platform security, responsible gaming monitoring, and improving user experience — provided such interests are not overridden by your fundamental rights.
• Consent: Processing based on your freely given, specific, and informed consent — such as the receipt of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

6Data Sharing & Disclosure

dat939 does not sell, rent, or trade your personal information to any third party. We may, however, share your personal data in the following limited circumstances:

6.1 Service Providers

dat939 engages carefully selected third-party service providers who process personal data on our behalf in order to deliver specific services. These include identity verification providers, payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank), IT infrastructure providers, customer support platform vendors, and analytics service providers. All such providers are bound by strict data processing agreements and are prohibited from using your data for any purpose beyond the specific service they provide to dat939.

6.2 Regulatory and Legal Authorities

dat939 may disclose personal data to regulatory bodies, law enforcement agencies, courts, or other government authorities where we are legally obligated to do so — for example, in response to a lawful court order, a regulatory investigation, or an AML reporting obligation. In such cases, dat939 will disclose only the minimum data necessary to fulfil the legal requirement.

6.3 Business Transfers

In the event that dat939 undergoes a merger, acquisition, restructuring, or sale of assets, personal data held by dat939 may be transferred to the acquiring entity as part of that transaction. You will be notified via email or a prominent platform notice before your personal data becomes subject to a materially different privacy policy as a result of any such transfer.

6.4 Fraud Prevention Networks

dat939 participates in shared fraud prevention networks and may share limited data points — such as flagged IP addresses or device fingerprints — with other licensed operators for the purpose of detecting and preventing cross-platform fraud and multi-accounting. No personally identifying data such as your name, CNIC, or contact details is included in such exchanges without your consent or a specific legal obligation.

7Payments & Financial Transaction Privacy

dat939 processes all financial transactions in Pakistani Rupees (PKR) through regulated payment channels including JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank. The following privacy principles apply specifically to financial data:

• dat939 does not store full bank account numbers or mobile wallet credentials on its own servers beyond the minimum required for transaction reconciliation.
• Payment processing is handled via encrypted, tokenised connections to our payment partners — full financial credentials are transmitted directly to the payment provider and are not retained in readable form by dat939.
• Transaction histories are retained for a minimum of five (5) years in accordance with AML compliance obligations, even after account closure.
• All financial data is stored in encrypted form with access restricted to authorised dat939 compliance and finance personnel only.
• dat939 may request source-of-funds documentation for large transactions. Such documentation is treated as sensitive financial data and handled accordingly.

8Cookies & Tracking Technologies

dat939 uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and gather anonymised analytics about platform usage. The following categories of cookies may be set when you use dat939:

You can manage your cookie preferences through your browser settings or through the dat939 cookie consent manager. Please note that disabling essential or security cookies may impair your ability to use the dat939 platform effectively. dat939 does not use third-party advertising cookies or cross-site tracking cookies.

9Data Retention

dat939 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention guidelines apply:

• Active Account Data: Retained for the full duration of your account being open and active on the dat939 platform.
• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure, in line with AML regulatory requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Betting and Gaming History: Retained for a minimum of three (3) years from the date of each wagering event.
• Customer Support Communications: Retained for two (2) years from the date of the last communication in a support thread.
• Marketing Consent Records: Retained for three (3) years from the date consent was last given or withdrawn, as evidence of compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an individual player.

10Your Privacy Rights

As a dat939 player, you hold meaningful rights in relation to your personal data. dat939 is committed to honouring these rights promptly and transparently. The following rights are available to you:

• Right of Access: You may request a copy of the personal data dat939 holds about you at any time. We will provide this within 30 days of receiving a valid request.
• Right to Rectification: If any personal data held by dat939 is inaccurate or incomplete, you have the right to request that it be corrected. You can update most account details directly through your account settings.
• Right to Erasure: You may request that dat939 delete your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent. Note that certain data must be retained for legal and regulatory reasons even after account closure.
• Right to Restrict Processing: In certain circumstances, you may request that dat939 limit the ways in which your data is processed, for example while a dispute or correction request is being resolved.
• Right to Data Portability: You may request a structured, machine-readable copy of the personal data you have provided to dat939 for the purpose of transferring it to another service provider.
• Right to Object: You may object to dat939 processing your personal data where such processing is based on legitimate interests. You also have an unconditional right to object to your data being used for direct marketing purposes.
• Right to Withdraw Consent: Where dat939 processes your data on the basis of your consent, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

11Data Security

dat939 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:

• All data transmitted between your device and the dat939 platform is encrypted using Transport Layer Security (TLS) protocol.
• Personal data stored on dat939's servers is encrypted at rest using AES-256 encryption.
• Access to personal data is restricted on a strict need-to-know basis, with role-based access controls and regular access reviews.
• All dat939 employees and contractors who handle personal data are subject to confidentiality obligations and regular data protection training.
• dat939's infrastructure undergoes regular security assessments, vulnerability scans, and penetration testing by qualified security professionals.
• Multi-factor authentication is enforced for all dat939 staff accessing systems that contain personal data.

In the event of a personal data breach that poses a risk to your rights and freedoms, dat939 will notify affected players without undue delay and will take immediate steps to contain and remediate the breach.

12Children & Minors

The dat939 platform is strictly intended for adults aged 21 years and older. dat939 does not knowingly collect, store, or process any personal data relating to individuals under the age of 21. Age verification is a mandatory step in the dat939 registration and KYC process.

If dat939 discovers or has reason to believe that a registered account belongs to a person under the age of 21, the account will be immediately suspended, all funds will be frozen pending investigation, and the matter will be handled in accordance with dat939's minor protection policy. Any personal data relating to the minor will be securely deleted following resolution of the matter, except where retention is required for regulatory or legal purposes.

dat939 also recommends that parents and guardians in Pakistan make use of parental control software to restrict access to online gaming platforms on devices that may be used by minors. Responsible gaming resources and self-exclusion tools are available on our Responsible Gaming page.

13Changes to This Privacy Policy

dat939 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email and/or a prominent notice displayed on the dat939 platform at least seven (7) days before the changes take effect.

The effective date at the top of this page will always reflect when the current version of this policy was last updated. We encourage all dat939 players to review this Privacy Policy periodically — at least once every three months — to remain informed about how your personal data is being handled.

Your continued use of the dat939 platform after a revised Privacy Policy has been published constitutes your acceptance of the updated terms. If you disagree with any changes, you should cease using the platform and contact us to close your account before the revised policy takes effect.

14Contact & Data Enquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data dat939 holds about you, please get in touch with our data protection team through the following channels:

For matters relating to responsible gaming, self-exclusion, or player welfare, please visit our dedicated Responsible Gaming page where additional tools and resources are available.