Privacy Policy

1. Introduction

939bit ("939bit", "we", "us" or "our") operates the online sports betting and casino platform accessible at 939bit.cam (the "Platform"). We are committed to protecting the privacy of every individual who accesses, registers on or interacts with the Platform.

This Privacy Policy ("Policy") describes the categories of personal data we collect, the purposes for which we use that data, how long we retain it, the circumstances in which we may share it with third parties, and the rights available to you in relation to your personal data. This Policy applies to all services provided through the Platform, including sports betting markets, live casino, slots, table games, virtual sports, esports, account management and customer support interactions.

By registering an Account or continuing to use the Platform following the effective date of this Policy, you confirm that you have read and understood its contents. If you do not agree with any aspect of this Policy, you should discontinue your use of the Platform immediately.

2. Definitions

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Account" — the registered user account created by a Data Subject on the Platform.
• "Controller" — the entity that determines the purposes and means of processing personal data; in this context, 939bit.
• "Data Subject" — any identified or identifiable natural person whose personal data is processed by 939bit; in most cases, this is you, the Platform user.
• "Personal Data" — any information that relates to an identified or identifiable natural person, including but not limited to name, email address, date of birth, device identifiers and financial transaction records.
• "Processing" — any operation or set of operations performed on Personal Data, including collection, storage, use, disclosure and deletion.
• "Processor" — a third party that processes Personal Data on behalf of 939bit under contractual instruction.
• "Sensitive Data" — a subset of Personal Data that requires heightened protection, including financial account details, identity document numbers and data relating to potential problem gambling.
• "Third Party" — any person or entity other than the Data Subject, 939bit and its Processors.

3. Data We Collect

3.1 Registration & Account Data

When you create an Account on the Platform, we collect:

• Full legal name;
• Date of birth;
• Residential address (including city, such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar, and postal code);
• Email address;
• Username and encrypted password;
• Phone number (where provided or required for verification);
• Nationality and country of residence.

3.2 Identity Verification (KYC) Data

To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, we may collect:

• Government-issued photo identification (e.g., Pakistani CNIC, passport or driving licence);
• Proof of address documentation;
• Source of funds documentation (for large transactions or at our discretion);
• Photographs or selfies where required for identity matching purposes.

3.3 Financial & Transaction Data

We collect data relating to all financial activity on your Account, including:

• Deposit and withdrawal amounts in PKR or equivalent currency;
• Payment method identifiers (e.g., last four digits of a card, or reference associated with a transfer); note that we do not store full payment card numbers;
• Transaction timestamps, reference numbers and processing status;
• Bonus claims, wagering activity and balance history.

3.4 Technical & Device Data

When you access the Platform, our servers and analytics tools automatically collect:

• IP address and approximate geolocation derived from it;
• Device type, operating system and browser;
• Session start and end timestamps;
• Pages visited, features accessed and click-path data;
• Error logs and performance data.

3.5 Communications Data

If you contact our support team via live chat or email, we retain records of those communications, including the content of messages, the date and time of contact, and any resolution notes.

4. How We Collect Data

We collect Personal Data through the following mechanisms:

• Direct provision — information you submit during registration, KYC verification, payment processing or when contacting support;
• Automated technical collection — server logs, cookies, session tracking and analytics tools that operate when you access the Platform (see Section 9 on Cookies);
• Third-party verification providers — KYC, AML and fraud-detection service providers engaged by 939bit may supply or cross-reference data about you as part of verification workflows;
• Payment processors — transaction confirmation data returned to us by payment gateways when you deposit or request a withdrawal.

5. Data Processing & Purpose

The table below summarises the primary purposes for which we process your Personal Data:

6. Legal Basis for Processing

939bit processes Personal Data on the following legal bases:

• Contractual necessity — processing required to perform the services described in the Terms & Conditions, such as operating your Account and processing transactions;
• Legal obligation — processing required to comply with applicable KYC, AML, fraud-prevention and regulatory obligations;
• Legitimate interest — processing undertaken for platform security, fraud detection, analytics and responsible gambling monitoring, where those interests are not overridden by your rights;
• Consent — processing for opt-in marketing communications, where you have provided explicit consent. You may withdraw consent for marketing at any time by contacting support or using the unsubscribe mechanism in any marketing email.

7. Data Sharing & Disclosure

We do not sell your Personal Data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the stated purposes:

• KYC and identity verification providers — specialist third-party services used to verify identity documents and cross-check against watchlists and sanctions registers;
• Payment processors and gateways — entities that facilitate deposits and withdrawals on the Platform; each processor handles data in accordance with its own applicable policies and any applicable financial regulation;
• Fraud detection and cybersecurity services — providers engaged to protect the Platform against fraud, money laundering and technical attacks;
• Analytics and platform performance providers — services used to understand how the Platform is used; data shared with these providers is minimised and, where possible, anonymised or pseudonymised;
• Legal and regulatory authorities — we may disclose Personal Data to law enforcement agencies, courts, regulators or other governmental bodies where required to do so by law, court order or regulatory directive;
• Business successors — in the event of a merger, acquisition, asset sale or restructuring involving 939bit, Personal Data may be transferred to the relevant successor entity as part of that transaction, subject to equivalent data protection obligations.

8. International Data Transfers

The Platform is operated internationally and your Personal Data may be transferred to and stored on servers located outside your country of residence. Where such transfers occur, 939bit takes steps to ensure that appropriate contractual, technical and organisational safeguards are in place to protect your data to a standard comparable with applicable data protection frameworks.

Players accessing the Platform from Pakistan should be aware that applicable Pakistani data protection law — including any current or future personal data protection legislation — may apply to how their data is handled. 939bit does not represent that its data processing arrangements have been approved by any Pakistani regulatory authority.

9. Cookies & Tracking Technologies

The Platform uses cookies and similar tracking technologies (such as local storage and session tokens) to support core functionality, improve performance and, where consent has been given, deliver analytics insights. Cookies are small text files stored on your device by your browser.

You can manage or delete cookies through your browser settings. Please note that disabling essential cookies will affect Platform functionality, including the ability to log in and place bets.

10. Data Retention

We retain your Personal Data for as long as your Account is active and for a further period thereafter as required or permitted by applicable law. Retention periods vary by data category and purpose:

• Account and registration data — retained for the lifetime of the Account and for a minimum period following closure, as required by applicable regulatory obligations;
• KYC and identity documents — retained for the period required by applicable AML and financial regulation, typically a minimum of five years from the date of the relevant transaction or Account closure;
• Transaction records — retained for a minimum of five years from the date of each transaction, or longer where required by applicable law;
• Communications and support records — retained for up to three years from the date of the interaction, unless a longer period is required in connection with a complaint, dispute or legal proceeding;
• Analytics and technical data — retained in aggregated or pseudonymised form for up to two years from collection.

Following expiry of the applicable retention period, data is securely deleted or irreversibly anonymised. Where a legal hold or ongoing dispute requires longer retention, data will be preserved for the duration of that requirement.

11. User Rights

Subject to applicable law and any overriding legal obligations (including AML and regulatory retention requirements), you have the following rights in relation to your Personal Data:

To exercise any of these rights, contact us at [email protected]. We will respond to valid requests within a reasonable timeframe. We may need to verify your identity before processing a request.

12. Minors & Age Restriction

The Platform is strictly intended for adults aged 18 years or older, or such higher minimum age as required by the operator's license jurisdiction. We do not knowingly collect Personal Data from individuals under the applicable minimum age. Where we become aware that a minor has submitted data or created an Account, we will close the Account and delete associated data without delay.

Age verification is conducted as part of the KYC process. If age cannot be confirmed to the required standard, access to the Platform will be restricted until verification is complete.

13. Data Security

939bit implements appropriate technical and organisational security measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include:

• HTTPS/TLS encryption across all Platform pages and API endpoints;
• Encryption at rest for stored Sensitive Data, including identity document references;
• Role-based access controls limiting staff access to Personal Data to those with a legitimate operational need;
• Regular security assessments and monitoring of the Platform infrastructure;
• Incident response procedures to address any potential data breach promptly.

Despite these measures, no online platform can guarantee absolute security. You are responsible for keeping your Account credentials secure and for logging out of your Account when using shared devices. If you suspect your Account has been compromised, contact support immediately.

14. Third-Party Links & Services

The Platform may reference third-party services — including payment processors and game content providers — that operate under their own privacy policies. 939bit is not responsible for the data practices of third-party providers accessed through or in connection with the Platform. We recommend reviewing the privacy policies of any third-party service you interact with.

References to payment brands such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are for contextual purposes only. Interactions with those payment services are governed by the policies and terms of the respective providers.

15. Policy Amendments

We may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law or Platform functionality. Where material changes are made, we will provide advance notice through the Platform interface or by email to the address registered on your Account. The effective date at the top of this page will be updated accordingly.

Continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed about how your data is handled.

16. Contact & Data Requests

For all data protection enquiries, requests to exercise your rights under Section 11, or questions about this Privacy Policy, please contact the 939bit support team using the details below. Email addresses are displayed as plain text only and are not clickable links.

We aim to respond to all data rights requests within a reasonable timeframe. We may request proof of identity before processing your request to ensure we do not disclose or action data for the wrong individual.