dat939 Privacy Policy – How We Handle Your Data

1. Who We Are

This Privacy Policy applies to the dat939 platform, accessible at dat939.app, including the Android APK application and the iOS Progressive Web App (PWA). Throughout this policy, references to "dat939", "we", "us" or "the platform" refer to the operator of the dat939 service.

If you have questions about this Privacy Policy or how your data is handled, you can contact us via the in-app support channel or at the email address listed at the end of this document.

2. Information We Collect

dat939 collects personal information in the following ways:

Information you provide directly:

• Full name and date of birth (required at registration).
• Mobile phone number (used as your primary account identifier and for account communications).
• Email address (where provided; used for account communications and notifications).
• Identity documents such as a copy of your CNIC, which may be requested during identity verification before your first withdrawal or during an account review.
• Payment account details — for example, your JazzCash or Easypaisa wallet number, Raast ID, bank account number or card details used for deposits and withdrawals in PKR.

Information collected automatically when you use the platform:

• Device information — the type of device, operating system version, browser type and unique device identifiers.
• IP address and approximate geographic location derived from it.
• Session data — pages visited, games played, bets placed, time spent on the platform and interaction patterns.
• Log data — server access logs, error logs and technical diagnostic information.
• Cookie data and similar tracking technologies (described in detail in Section 8).

Information from third parties:

• Identity verification data from document verification service providers where used.
• Payment confirmation data from JazzCash, Easypaisa, Raast, banks and card payment processors.
• Fraud detection signals from security service providers.

3. How We Use Your Data

The table below summarises the main ways dat939 uses your personal information and the purpose behind each use:

dat939 does not use your personal data for automated decision-making that produces significant legal effects without human review. Gameplay and betting data may be reviewed for signs of problem gambling as part of our responsible gaming obligations.

4. Legal Basis for Processing

dat939 processes your personal data on the following bases:

• Contract performance: Processing necessary to provide the services you have registered for — account management, payment processing, bet settlement and customer support.
• Legitimate interests: Fraud prevention, platform security, abuse detection and improving the platform experience for all users.
• Legal obligation: Identity verification, age verification and any reporting obligations that may apply to the platform's operations.
• Consent: For optional communications such as promotional emails or push notifications, where you have explicitly opted in. You may withdraw this consent at any time through your account settings or by contacting support.

5. Payment Data and PKR Transactions

All financial transactions on dat939 are conducted in Pakistani Rupees (PKR) through the supported payment methods: JazzCash, Easypaisa, Raast, bank transfer and Pakistani-issued cards.

Payment processing is handled by third-party payment service providers. dat939 does not store full card numbers, card CVV codes, JazzCash PINs or Easypaisa PINs on its own servers. Payment data shared with payment providers is transmitted securely and handled in accordance with the security standards of those providers.

Transaction records — including deposit amounts, withdrawal amounts, dates and payment method types — are retained as part of your account history. This transaction history is visible to you in your account and is also used by dat939 for financial reconciliation, fraud investigation and account verification purposes.

6. Sharing Your Data with Third Parties

dat939 does not sell, rent or trade your personal information. Data is shared with third parties only in the following circumstances and only to the extent necessary:

• Payment processors: JazzCash, Easypaisa, Raast network operators, banks and card payment processors receive the payment details needed to process your PKR transactions.
• Identity verification providers: Where document verification services are used, your identity documents are shared with the verification provider to complete the check.
• Technical service providers: Companies that provide hosting, data storage, security monitoring or platform analytics may process data on dat939's behalf under appropriate data processing agreements.
• Game software providers: Casino game providers may receive pseudonymous gameplay data (not your full personal identity) to operate their games on the platform.
• Legal and regulatory requirements: dat939 may disclose personal data when required to do so by a valid legal obligation, court order or in response to a lawful request from a competent authority.

All third parties who process data on dat939's behalf are required to handle that data securely and only for the purposes for which it was shared.

7. Data Retention

dat939 retains personal data for as long as your account is active and for a period after closure to meet legal, financial and security obligations. Specific retention periods include:

• Account data (name, DOB, contact details): Retained for the lifetime of the account and for a period after closure in accordance with applicable record-keeping requirements.
• Transaction records (deposits, withdrawals, bet history): Retained for a minimum period consistent with financial record-keeping obligations.
• Identity verification documents: Retained for the period required by applicable identity verification and anti-fraud obligations.
• Session and gameplay logs: Retained in identifiable form for a defined operational period, after which they may be anonymised for analytics purposes.
• Support communications: Retained while relevant to an open issue and for a period after resolution for quality and audit purposes.

When personal data is no longer required and its retention period has expired, it is securely deleted or anonymised.

8. Cookies and Tracking Technologies

dat939 uses cookies — small text files stored on your device — and similar technologies to operate the platform effectively. Here is what they are used for:

• Essential cookies: Required for the platform to function. These keep you logged in during a session, maintain your account state and enable core functionality. These cookies cannot be disabled without disrupting your ability to use the platform.
• Preference cookies: Store your language settings, display preferences and other customisation choices so they are remembered between sessions.
• Analytics cookies: Collect anonymised information about how users interact with the platform — which pages are visited most, how navigation flows, where errors occur. This data is used to improve the platform experience.
• Security cookies: Help detect and prevent fraudulent activity, bot access and other security threats by verifying session legitimacy.

The dat939 mobile app uses similar local storage and session management technologies to maintain your logged-in state and app preferences.

9. Security Measures

dat939 takes the security of your personal data seriously. The measures in place include:

• SSL/TLS encryption for all data transmitted between your device and the platform.
• Secure, access-controlled storage systems for personal and financial data.
• Regular security reviews and monitoring for suspicious access or unusual activity.
• Restricted internal access to personal data — only staff with a legitimate operational need can access user account data.
• Two-factor authentication options available for account security (where enabled in account settings).

While dat939 takes appropriate technical and organisational measures to protect your data, no system is completely immune to security risks. In the event of a data breach that poses a risk to users, dat939 will take prompt action to contain the breach and notify affected users as appropriate.

You also play a role in keeping your account secure. Use a strong, unique password for your dat939 account, do not share your credentials with anyone, and contact support immediately if you suspect unauthorised access to your account.

10. Your Rights Over Your Personal Data

As a dat939 user, you have the following rights regarding your personal information:

• Right of access: You can request a copy of the personal data dat939 holds about you.
• Right to correction: If any personal information in your account is inaccurate or outdated, you can ask for it to be corrected. For basic details like your contact number, you can update these directly in your account settings.
• Right to deletion: You may request deletion of your personal data. Note that some data may need to be retained to comply with legal obligations (such as transaction records) even after an account closure request.
• Right to restrict processing: In certain circumstances, you can ask dat939 to limit how your data is used while a query or complaint is being resolved.
• Right to data portability: You can request your personal data in a structured, commonly used format.
• Right to withdraw consent: Where processing is based on your consent (such as for promotional communications), you can withdraw that consent at any time without affecting the legality of previous processing.

To exercise any of these rights, contact the dat939 support team through the in-app help channel or at [email protected] (plain text — not a clickable link). We will respond to requests within a reasonable timeframe.

11. Children's Privacy

dat939 is strictly an adults-only platform. The minimum age to register and use the platform is 18 years. dat939 does not knowingly collect personal information from individuals under 18 years of age.

If we become aware that a user under the age of 18 has registered an account, that account will be closed, access will be blocked and any deposits held pending investigation will be handled in accordance with our account closure procedures.

12. Updates to This Privacy Policy

dat939 may update this Privacy Policy from time to time to reflect changes in platform operations, applicable law or data processing practices. When updates are made, the revised policy will be published at dat939.app/privacy-policy with a new "Last Updated" date.

It is your responsibility to review this policy periodically. Continued use of the platform after an update constitutes acceptance of the revised policy. For significant changes, dat939 will make reasonable efforts to notify registered users via the contact details on their account.

13. Contact and Privacy Enquiries

For any questions about this Privacy Policy, requests to exercise your data rights, or to report a privacy concern, please contact the dat939 support team through:

• In-app support channel: Available after logging in to your dat939 account. This is the fastest way to reach us for account-specific enquiries.
• Email: [email protected] (plain text — not a clickable link). Include your registered mobile number in the subject line to help us locate your account.

For data access or deletion requests specifically, please include "Data Request" in your message subject along with your account mobile number so your request can be handled efficiently.

dat939 also links to related policies on this platform. You may find the following useful alongside this Privacy Policy:

• Terms and Conditions – the overall rules for using dat939.
• Responsible Gaming Policy – tools and guidance for managing your gaming activity.