bt939 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how bt939 ("bt939", "we", "us", "our") collects, processes, uses, stores, and protects the personal information of individuals ("you", "Player", "User") who access and use the bt939 platform at bt939.net, including all associated gaming, betting, account management, and payment services.

By registering for a bt939 account or by continuing to use the bt939 platform, you acknowledge that you have read, understood, and accepted the data practices described in this Policy. This Policy should be read together with the bt939 Terms & Conditions.

This Policy applies to all personal data processed in connection with the bt939 platform regardless of the device or browser used to access it. It does not apply to third-party websites or services that may be referenced within the bt939 platform.

2. Data Controller Information

bt939 operates as the data controller in respect of personal data collected through the bt939 platform. For all privacy-related enquiries, data subject access requests, or complaints, please contact bt939 using the details provided in Section 13 of this Policy.

3. Personal Data We Collect

3.1 Registration Data

When you create a bt939 account, we collect the following information:

• Full legal name;
• Date of birth (to verify the 18+ age requirement);
• Email address;
• Mobile telephone number;
• Residential address;
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

To comply with our Know Your Customer obligations and to verify the age and identity of players, bt939 may collect:

• A copy of a government-issued photo identity document (CNIC, passport, or other accepted document);
• A selfie photograph holding the identity document (where required);
• Proof of address documentation (utility bill, bank statement, or equivalent).

3.3 Financial Data

When you make deposits or withdrawals via bt939, we collect transaction-related information including payment method identifiers (e.g. masked JazzCash or Easypaisa account details), transaction amounts, timestamps, and processing references. bt939 does not store complete payment card numbers or full mobile wallet credentials.

3.4 Usage and Technical Data

bt939 automatically collects certain technical data when you access the platform, including: IP address, device type and operating system, browser type and version, session timestamps, pages visited, bets placed, games accessed, and login history. This data is used for security monitoring, fraud prevention, and platform improvement.

3.5 Communications Data

If you contact bt939 support — including via email to [email protected] — we retain records of those communications including the content of your message and any attachments you provide.

4. How We Use Your Personal Data

bt939 uses personal data collected from Pakistani players and other users for the following purposes:

• Account Management: To create, maintain, and secure your bt939 account;
• Identity and Age Verification: To confirm you meet the 18+ age requirement and to verify your identity in accordance with our KYC procedures;
• Payment Processing: To process deposits and withdrawals via JazzCash, Easypaisa, and other supported payment methods;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, and other prohibited conduct;
• Responsible Gaming: To monitor gaming patterns for signs of problem gambling and to administer self-exclusion requests and deposit limits where applied;
• Customer Support: To respond to support enquiries, process complaints, and resolve disputes;
• Platform Improvement: To analyse usage patterns and improve the bt939 product, user experience, and content offering;
• Legal Compliance: To comply with applicable legal obligations and to respond to lawful requests from regulatory or law enforcement authorities.

5. Legal Basis for Processing

bt939 processes personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between bt939 and the Player (i.e., providing the platform and account services);
• Legal Obligation: Processing required to comply with applicable law, including identity verification and anti-fraud obligations;
• Legitimate Interests: Processing for fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by the Player's data protection rights;
• Consent: Where bt939 relies on consent as a legal basis (for example, for non-essential cookies or direct marketing), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

bt939 does not sell personal data. bt939 may share your personal data with third parties only in the following circumstances:

• Payment Processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, Visa, Mastercard, UnionPay, and cryptocurrency processing providers receive transaction data necessary to process your payments. These providers are subject to their own data protection obligations.
• Identity Verification Providers: bt939 may use third-party KYC and identity verification services to process identity documents you submit. These providers act as data processors under agreement with bt939.
• IT and Infrastructure Providers: bt939's hosting, security, and platform technology providers may process data as part of platform operations under contractual data processing agreements.
• Regulatory and Law Enforcement Authorities: bt939 may disclose personal data to regulatory authorities or law enforcement where required to do so by applicable law, court order, or lawful regulatory request.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of bt939's business, personal data may be transferred to the relevant acquiring entity, subject to equivalent privacy protections.

7. Data Retention

bt939 retains personal data for as long as your account remains active and for a period thereafter as required for legal, regulatory, and dispute resolution purposes. Specifically:

• Account registration data is retained for the duration of the account and for a minimum of five (5) years following account closure;
• KYC identity documents are retained for the minimum period required by applicable compliance obligations from the date of submission;
• Financial transaction records are retained for a minimum of five (5) years in accordance with standard financial record-keeping requirements;
• Support communications are retained for a minimum of two (2) years from the date of the last communication.

Where retention is no longer necessary, bt939 will securely delete or anonymise personal data.

8. Cookies and Tracking Technologies

bt939 uses cookies and similar technologies including local storage and session identifiers on the bt939 platform. Cookies serve the following purposes:

• Essential Cookies: Required for the bt939 platform to function — including maintaining your logged-in session, remembering language preferences, and security tokens. These cannot be disabled without affecting platform functionality.
• Analytics Cookies: Used to understand how players use the bt939 platform — which pages are visited, how long sessions last, and which features are used most. This data is used in aggregate and is not linked to individual identities for marketing purposes.
• Security Cookies: Used to detect and prevent fraudulent login attempts and other suspicious activity on the bt939 platform.

You can manage your cookie preferences through your browser settings. Note that disabling essential cookies will affect your ability to use the bt939 platform, including the ability to remain logged in.

9. Data Security

bt939 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using TLS (Transport Layer Security);
• Encryption of sensitive data at rest;
• Access controls limiting personal data access to authorised personnel only;
• Login security measures including two-factor authentication options for player accounts;
• Regular security monitoring and audit procedures.

Despite these measures, no data transmission over the internet or electronic storage system is completely secure. bt939 cannot guarantee absolute security of your personal data. In the event of a data breach affecting your personal data, bt939 will take appropriate steps to notify affected players as required by applicable law.

10. Your Rights and Choices

Subject to applicable law, you have the following rights in respect of your personal data held by bt939:

• Right of Access: You may request a copy of the personal data bt939 holds about you;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data;
• Right to Erasure: In certain circumstances you may request deletion of your personal data — note that this right may be limited by legal retention obligations;
• Right to Restrict Processing: You may request that bt939 restricts processing of your data in certain circumstances;
• Right to Object: You may object to processing of your personal data where bt939 relies on legitimate interests as the legal basis;
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting prior processing.

To exercise any of the above rights, please contact bt939 at [email protected]. bt939 will respond to verified requests within a reasonable timeframe. Note that exercising certain rights (such as requesting erasure) may affect your ability to continue using the bt939 platform.

11. Children and Minors

bt939 is strictly prohibited for persons under the age of 18. bt939 does not knowingly collect personal data from persons under 18. If bt939 discovers that a person under 18 has registered an account or submitted personal data, the account will be immediately closed, any funds returned, and the associated personal data deleted as soon as practicable.

If you believe that a minor may be using or attempting to use the bt939 platform, please contact bt939 immediately at [email protected]. For general information on protecting minors from online gambling, we encourage the use of parental control tools available through internet service providers and device manufacturers.

12. Changes to This Policy

bt939 reserves the right to update or amend this Privacy Policy at any time. Updated versions will be published on this page with a revised "Last Updated" date. Your continued use of the bt939 platform following publication of an updated Policy constitutes acceptance of the revised terms. Where changes are materially significant, bt939 may notify active players by email to their registered address.

We recommend reviewing this Policy periodically to remain informed of how bt939 handles your personal data.

13. Contact Us

For all privacy-related questions, data subject access requests, or complaints regarding bt939's handling of personal data, please contact the bt939 privacy team using the details below.

Email: [email protected]

Please note that this email address is presented as plain text for informational purposes. Do not include sensitive identity documents or financial information in general enquiry emails — these should only be submitted through the secure verification process within your bt939 account.