Privacy Policy — bt939 Pakistan Gaming Platform

1Who This Policy Applies To

This Privacy Policy applies to all individuals who interact with bt939 — including registered players, visitors to bt939.win who have not yet created an account, and anyone who contacts bt939 via support channels. By accessing bt939.win or creating an account, you confirm that you have read and understood this policy.

This policy applies specifically to players accessing bt939 from Pakistan. It covers all bt939 services including the main website at bt939 .win, the bt939 mobile app available on Android and iOS, all game categories including slots, fish games, and live casino, and the sports betting section covering cricket, PSL, T20, football, and esports.

2What Data We Collect

bt939 collects personal information through different points of interaction. Below is a clear breakdown of the categories of data we collect and when we collect them.

We do not collect sensitive data such as biometric information, political opinions, or religious beliefs. Where identity documents are collected for KYC purposes, they are handled with additional security controls and retained only for as long as legally required.

3How We Use Your Data

Every piece of data bt939 collects is used for a specific, legitimate purpose. We do not use your data for anything other than what is described here without informing you first.

• Account creation and management: Your identity and contact data allow us to create your bt939 account, keep it secure, and communicate with you about your account status.
• Identity verification (KYC): Pakistani regulations and responsible gaming best practices require us to verify player identity before processing withdrawals. This is standard procedure across the industry and protects both you and the platform.
• Processing PKR deposits and withdrawals: Financial data is used solely to process your transactions via JazzCash, Easypaisa, Raast, bank transfer, and other supported payment methods.
• Game and betting services: Your gaming activity data is used to deliver game results, settle bets on cricket, PSL, and other sports, and maintain accurate balance records.
• Fraud prevention and security: Device and activity data helps us detect unusual patterns, prevent unauthorised account access, and protect against bonus abuse or money laundering activity.
• Customer support: Communication data is used to resolve your queries efficiently and improve support quality.
• Platform improvement: Aggregated, anonymised usage data helps bt939 understand which features players use most, where the app experience can be improved, and which game categories are most popular among Pakistan players.
• Responsible gaming tools: Gaming activity data informs deposit limit calculations, session time tracking, and reality check features. This data is used to protect player wellbeing, not for commercial profiling.

4Payment Data & PKR Transactions

bt939 processes all transactions in Pakistani Rupees (PKR). When you make a deposit or request a withdrawal, your payment details are transmitted directly to our certified payment processing partners — bt939 does not store your full JazzCash number, Easypaisa wallet credentials, raw card data, or bank account passwords on its own servers.

Payment processors used by bt939 are required to meet strict data security standards. They are contractually prohibited from using your financial data for any purpose other than processing transactions on bt939's behalf.

Transaction records — including deposit amounts, withdrawal amounts, and dates — are retained as part of your account history. You can view your complete transaction history at any time from within your bt939 account. These records are also retained for the period required by financial record-keeping obligations.

5Cookies & Device Data

bt939 uses cookies and similar technologies to make the platform work correctly, remember your preferences, and understand how players interact with the site and app. Cookies are small text files stored on your device.

• Essential cookies: Required for the platform to function. These manage your login session, maintain your account state, and enable secure payment processing. You cannot opt out of essential cookies without stopping use of the platform.
• Functional cookies: Remember your preferences such as language settings, game view options, and recent bets so that your next session picks up where you left off.
• Analytics cookies: Collect anonymised data about how players navigate the platform, which pages are visited most often, and where users encounter problems. This data is aggregated and cannot be used to identify you individually.
• Security cookies: Help detect and prevent fraudulent activity, bot access, and account takeover attempts.

When using the bt939 mobile app, device data including your device model, operating system version, and app version is collected automatically. This is used for compatibility troubleshooting and to ensure the app functions correctly across different Pakistan Android and iOS devices.

You can manage cookie preferences through your browser settings. Note that disabling non-essential cookies will not affect your ability to play games or make transactions on bt939.

6Who We Share Data With

bt939 does not share your personal data with third parties for commercial gain. Sharing occurs only in the following specific, controlled circumstances:

• Payment processors: Financial data is shared with payment partners — such as JazzCash and Easypaisa infrastructure providers — solely to process your PKR deposits and withdrawals.
• Identity verification providers: CNIC and identity document data may be shared with third-party KYC verification services to confirm your identity before withdrawals. These providers are bound by strict data processing agreements.
• Game content providers: Certified game studios providing slots, fish games, and live casino content receive anonymised game session data necessary to deliver the game experience. They do not receive your personal identity or financial information.
• Fraud and security services: Device and activity data may be shared with anti-fraud technology partners to protect the platform and all players from unauthorised activity.
• Legal obligations: bt939 will disclose personal data where required by applicable law or in response to a valid, lawful request from a competent authority.

All third-party data processors used by bt939 are required to sign data processing agreements that prohibit them from using your data for any purpose beyond what bt939 has authorised. bt939 remains responsible for your data even when it is processed by third parties on our behalf.

7Data Security

bt939 takes the security of your personal information seriously. The platform implements a range of technical and organisational measures to protect your data from unauthorised access, alteration, disclosure, or destruction.

• All data transmitted between your browser or app and bt939's servers is encrypted via TLS/SSL.
• Passwords are stored as salted cryptographic hashes — not in readable form. bt939 staff cannot see your password.
• Access to personal data within bt939 is restricted on a need-to-know basis. Only authorised staff with a legitimate operational need can access account-level data.
• Payment data is handled exclusively by PCI-compliant payment processors. Raw card or wallet credentials are never stored by bt939.
• Regular security audits and penetration testing are conducted to identify and address vulnerabilities before they can be exploited.
• Two-factor authentication is available for player accounts and is strongly recommended.

While bt939 applies industry-standard security practices, no online platform can guarantee absolute security against all threats. You play an important role in keeping your account secure by using a strong, unique password and not sharing your login credentials with anyone.

8How Long We Keep Your Data

bt939 retains personal data only for as long as it is needed for the purpose it was collected, or as required by applicable legal and financial record-keeping requirements. The general retention periods are as follows:

• Active account data: Retained for the full duration of your account being active on bt939.
• Transaction and financial records: Retained for a minimum of five years from the date of the transaction, in line with standard financial record-keeping requirements.
• Identity verification documents: Retained for five years after account closure or the last transaction, whichever is later.
• Support communications: Retained for two years from the date of the interaction, unless the matter is subject to ongoing dispute resolution.
• Device and analytics data: Retained in anonymised, aggregated form indefinitely for platform improvement; identifiable device data is deleted or anonymised after 12 months of account inactivity.

When data reaches the end of its retention period, it is securely deleted from bt939 systems or anonymised so that it can no longer be linked to you as an individual.

9Your Privacy Rights

As a bt939 player, you have the following rights in relation to your personal data. To exercise any of these rights, contact bt939 support with your registered account details.

• Right to access: Request a copy of the personal data bt939 holds about you. We will provide this within a reasonable timeframe.
• Right to correction: If any personal data bt939 holds about you is inaccurate or outdated, you can request that we correct it. For identity data, you may need to provide supporting documentation.
• Right to deletion: You can request that bt939 delete your personal data. Note that deletion may not be possible where data must be retained for legal, financial, or fraud prevention reasons. In such cases, we will explain which data must be kept and why.
• Right to restrict processing: You can ask bt939 to restrict how we use your data in certain circumstances — for example, if you dispute the accuracy of the data while a correction is being investigated.
• Right to data portability: You can request a copy of your personal data in a commonly used, machine-readable format.
• Right to object: You can object to bt939 using your data for direct marketing purposes at any time. You can also object to processing based on legitimate interests in certain circumstances.

10Children & Under-Age Players

bt939 is strictly for adults aged 18 and over. The platform does not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and believe that your child has registered an account or provided personal information to bt939, please contact support immediately.

Upon receiving a verified report of an under-age account, bt939 will close the account, delete all associated personal data to the extent legally permissible, and return any deposited funds in accordance with our standard verification procedures.

bt939 strongly recommends that parents and guardians use device-level parental controls and internet filtering tools to prevent minors from accessing online gaming and betting platforms.

11Marketing Communications

bt939 may send you promotional communications about new games, bonus offers, PSL betting promotions, and platform updates. These communications are sent only where you have given your consent during registration or at a later point via your account communication preferences.

• You can opt out of marketing communications at any time by updating your notification preferences in your bt939 account settings, or by contacting support.
• Opting out of marketing communications does not affect your ability to receive essential account communications — such as transaction confirmations, security alerts, or notifications about changes to these policies.
• bt939 does not share your contact details with external marketing companies for the purpose of sending you third-party promotional materials.

12Changes to This Privacy Policy

bt939 may update this Privacy Policy from time to time to reflect changes in how we operate, the services we offer, or applicable legal requirements. When material changes are made, registered players will be notified via email or an in-platform notification before the changes take effect.

The "Last updated" date at the top of this page reflects the most recent revision. We encourage you to review this policy periodically. If you continue using bt939 after an updated policy has taken effect, that constitutes your acceptance of the revised terms. If you disagree with any changes, you should contact support to discuss your options, including account closure.

13Contact & Data Requests

If you have any questions about this Privacy Policy, want to understand how bt939 uses a specific piece of your data, or wish to exercise any of your privacy rights, you can reach the bt939 data team via the following:

• Email: [email protected] — include "Privacy Request" in the subject line for faster routing.
• Live chat: Available 24/7 from within your logged-in bt939 account. Verified account holders can initiate data requests directly through chat.

Please include your registered email address and account username in any data-related request so that we can verify your identity and respond accurately. bt939 will not process data requests from unverified contacts to protect against fraudulent requests for account information.

For concerns about responsible gaming data — such as self-exclusion records, deposit limit history, or session time data — you can also access and manage these directly from the Responsible Gaming section within your bt939 account settings.