bit939 Privacy Policy — How We Protect Your Data

1 Introduction

This Privacy Policy describes how bit939 ("we", "us", "our") collects, processes, stores, and protects the personal information of players and visitors who use the bit939 platform at bit939.app, the bit939 mobile application, and any related services.

We take data privacy seriously. The way we handle personal information is guided by the principles of transparency, purpose limitation, data minimisation, and security. This policy explains those principles in plain language so that every player — whether they are betting on a PSL match, spinning slots in the Casino, or just browsing the promotions — understands what is happening with their information.

By registering for a bit939 account or using the platform you confirm that you have read and understood this Privacy Policy. This policy should be read alongside our Terms and Conditions and our Responsible Gaming page.

2 What We Collect

bit939 collects different categories of information depending on how you interact with the platform. Below is a summary of the main types of data we hold:

We collect only the information that is necessary for the purpose stated. We do not collect sensitive categories of data such as health information, biometric data, or political opinions.

3 How We Use Your Data

The information we collect is used for specific, clearly defined purposes. We do not use your data in ways that would surprise you or that you would not reasonably expect given the nature of the platform. The main purposes are:

• Account Management: To create, maintain, and secure your bit939 account, process your login, and keep your settings and preferences up to date.
• Payment Processing: To process deposits and withdrawals through JazzCash, Easypaisa, Raast, bank transfer, and cards, all settled in PKR, and to maintain a record of your transactions.
• Identity Verification: To confirm that you meet the eligibility requirements for using the platform, including age verification and anti-money-laundering checks.
• Platform Operation: To deliver the sports betting, live casino, casino games, and all other features of the platform correctly and reliably.
• Customer Support: To respond to your enquiries, resolve disputes, and investigate complaints.
• Fraud Prevention and Security: To detect and prevent fraudulent activity, multiple account creation, bonus abuse, and unauthorised access attempts.
• Responsible Gaming: To monitor for patterns that may indicate problem gambling behaviour, such as rapid increases in bet sizes or session lengths, and to enforce deposit limits or self-exclusions that you have set.
• Promotions and Communications: To send you information about bonuses, offers, and cricket or PS L promotions that we think may interest you, where you have not opted out of marketing communications.
• Platform Improvement: To analyse how players use the platform so that we can improve navigation, fix issues, and develop better features.

4 Legal Basis for Processing

Every time we process your personal data, we do so on one of the following legal grounds:

• Contract Performance: Processing that is necessary to provide the service you have signed up for — including running your account, processing bets, and handling payments.
• Legal Obligation: Processing required to comply with anti-money-laundering rules, fraud prevention obligations, and identity verification requirements.
• Legitimate Interests: Processing that is in bit939's legitimate interest and does not override your rights — such as security monitoring, fraud detection, and general platform analytics.
• Consent: Where we send you marketing communications or use non-essential cookies, we rely on your consent. You can withdraw consent at any time through your account settings or by contacting support.

5 Sharing Your Data

bit939 does not sell your personal data to any third party. We do share limited data with carefully selected service partners where it is necessary for them to provide their service to us. In every case, those partners are contractually required to keep your data secure and to use it only for the purpose for which it was shared.

The categories of third parties with whom data may be shared include:

• Payment Processors: JazzCash, Easypaisa, Raast, and bank and card processing partners receive the transaction information needed to process your deposits and withdrawals in PKR.
• Identity Verification Providers: Third-party KYC services that help us confirm the authenticity of identity documents submitted during account verification.
• Game Providers: Casino and Live Casino game studios receive a player session token to deliver their games. They do not receive your personal registration details.
• Analytics Providers: Anonymised or aggregated usage data may be shared with analytics platforms to help us understand how the platform is used. No personally identifiable information is included in these datasets.
• Legal and Regulatory Authorities: If we are required by law or a valid legal process to disclose information, we will do so. We will notify you where we are legally permitted to do so.

6 Payment Information

bit939 handles all transactions in Pakistani Rupees (PKR). Payment methods supported on the platform include JazzCash, Easypaisa, Raast, standard bank transfers, debit and credit cards, and approved mobile wallets.

We take the following approach to payment data security:

• Full card numbers, CVV codes, and mobile wallet PINs are never stored on bit939's servers.
• Card payments are tokenised by our payment gateway partner. We store only the last four digits of a card number and the card type for reference purposes.
• Mobile payment references (such as JazzCash or Easypaisa transaction IDs) are stored in our transaction logs for reconciliation and dispute resolution purposes.
• All payment communication between your device and our servers is encrypted using TLS.

If a withdrawal request is submitted to a payment method that does not match your account registration, the request may be held for additional verification. This is an anti-fraud measure and not a restriction on your right to withdraw your balance.

7 Cookies and Tracking Technologies

bit939 uses cookies and similar technologies (such as local storage and session tokens) to make the platform work correctly and to improve your experience. There are three broad categories of cookie used on the platform:

• Essential Cookies: These are required for basic platform functionality — keeping you logged in during a session, remembering your language preference, and maintaining the security of your session. These cannot be disabled.
• Functional Cookies: These remember choices you have made, such as your preferred deposit method or notification settings, so you do not have to re-enter them every time you log in.
• Analytics Cookies: These help us understand how players navigate the platform — which pages are visited most, where players drop off, and how long sessions typically last. The data collected is aggregated and does not directly identify you. You can opt out of analytics cookies in your browser settings.

You can manage cookies in your browser's privacy or settings menu. Blocking essential cookies will affect the functionality of the platform and may prevent you from logging in or using key features.

8 Data Retention

We keep your personal data for as long as is necessary for the purposes described in this policy, or for as long as we are required to by applicable law. The key retention periods are:

• Active Account Data: Kept for as long as your account is open and for a period after closure to allow for dispute resolution and any required regulatory record-keeping.
• Transaction Records: Financial records including deposit and withdrawal history are retained for a minimum of five years from the date of the transaction in line with standard financial record-keeping practice.
• Identity Documents: KYC documents are retained for as long as the account is active and for a period after account closure. Documents are securely destroyed once the retention period expires.
• Support Communications: Chat logs and email correspondence with our support team are retained for up to three years from the date of the conversation.
• Technical and Log Data: Server logs and IP records are retained for up to 12 months for security monitoring purposes.

When data is no longer needed, it is securely deleted or anonymised so that it can no longer be linked to any individual.

9 Your Rights

As a bit939 player you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team through the platform with your request. We will respond within a reasonable timeframe.

• Right of Access: You can request a copy of the personal data we hold about you. We will provide this in a readable format.
• Right to Rectification: If any of the information we hold about you is inaccurate or incomplete, you can ask us to correct it.
• Right to Erasure: In certain circumstances you can ask us to delete your personal data. Note that we may be required to retain some data for legal or regulatory reasons even after an erasure request.
• Right to Restrict Processing: You can ask us to limit the way we use your data in specific circumstances — for example, while a correction request is being assessed.
• Right to Data Portability: You can ask for your data to be provided in a structured, commonly used, machine-readable format so that you can transfer it if you wish.
• Right to Object: You can object to data processing carried out on the basis of legitimate interests. We will review your objection and cease processing unless we can demonstrate compelling grounds to continue.
• Right to Withdraw Consent: Where processing is based on your consent — such as marketing emails — you can withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.

10 Security Measures

bit939 applies a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• All data in transit between your device and our servers is encrypted using TLS 1.2 or higher.
• Sensitive data at rest — including identity documents and account details — is encrypted using strong encryption algorithms.
• Access to personal data within our systems is restricted on a need-to-know basis. Staff who do not require access to player data as part of their role do not have it.
• We carry out regular security assessments and penetration testing of the platform.
• In the event of a data breach that is likely to result in a risk to your rights or freedoms, we will notify affected players without undue delay.

While we take every reasonable precaution on our end, you also play an important role in keeping your account secure. Use a strong, unique password, do not share your credentials with anyone, and contact support immediately if you notice any unusual activity on your account.

11 Minors

bit939 is strictly an adults-only platform. We do not knowingly collect personal data from anyone under the age of 18. Age verification is carried out during the registration process and as part of the KYC procedure.

If we become aware that personal data has been collected from a minor, we will delete that data immediately and close the associated account. If you believe a minor has accessed or registered on the platform, please contact our support team so the matter can be addressed promptly.

12 Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable requirements. When we make changes that materially affect how we handle your personal data, we will notify active account holders through the platform or via their registered contact details before those changes take effect.

The date at the top of this page always shows when the policy was last revised. We encourage you to check back periodically so that you are always aware of how your information is being used. Continued use of the platform after a policy update constitutes acceptance of the revised terms.

13 Contact Us

If you have any questions about this Privacy Policy, want to exercise any of your data rights, or have a concern about how your information is being handled, please get in touch with our support team. You can reach us through the live chat feature inside the platform after logging in, or by emailing us at the address shown in the footer of this page.

We aim to respond to all privacy-related enquiries within five business days. For data access or deletion requests, we will acknowledge your request promptly and complete it within 30 days, or inform you if a longer period is required.