bit939 Privacy Policy

1.1 bit939 ("we", "us", "our") is the operator of the online casino and sports betting platform accessible at bit939.org. bit939 is operated under an international gaming license and serves players primarily based in Pakistan, offering services denominated in Pakistani Rupees (PKR).

1.2 For the purposes of data protection, bit939 acts as the data controller in respect of all personal data collected through the bit939.org Platform. This means bit939 is responsible for determining the purposes and means by which your personal data is processed.

1.3 If you have any questions, requests, or concerns regarding your personal data, our dedicated Data Protection contact can be reached at the email address provided in Section 12 of this Privacy Policy.

2.1 bit939 collects the minimum personal data necessary to operate the Platform lawfully and effectively. The categories of personal data we collect are described below:

2.2 bit939 does not collect or store full card numbers or CVV codes. Payment instrument details are handled directly by our licensed payment processor partners, who maintain their own PCI-DSS compliance obligations.

2.3 We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data. If any such information is incidentally disclosed to us during a support interaction, it will not be stored or processed for any purpose other than resolving the immediate support matter.

3.1 Directly from you. The majority of personal data bit939 holds is provided by you directly — during registration, when completing KYC verification, when making a deposit or withdrawal request, when contacting our support team, or when updating your account profile settings.

3.2 Automatically. When you visit bit939.org, our servers and analytics tools automatically record certain technical data, including your IP address, device identifiers, browser type and version, referring URL, pages accessed, and session duration. This data is collected via server logs, cookies, and similar tracking technologies (see Section 6 for full details).

3.3 From third parties. In limited circumstances, bit939 may receive data about you from third-party sources, including:

• Identity verification service providers used to fulfil our KYC obligations;
• Payment processors who confirm the status of your deposit or withdrawal transactions;
• Fraud detection services that provide risk scores or flags linked to your IP address or device;
• Responsible gaming databases, where you have previously registered a self-exclusion or where we are required to check against a national exclusion register.

3.4 bit939 does not purchase personal data from data brokers or third-party marketing lists.

4.1 bit939 processes your personal data only where there is a lawful basis for doing so. The primary purposes for which we process personal data, together with the corresponding legal basis, are set out in the table below:

4.2 Where we rely on consent as a legal basis — such as for marketing communications — you may withdraw that consent at any time by updating your notification preferences in your account settings or by contacting support. Withdrawal of consent will not affect the lawfulness of any processing carried out before the withdrawal.

5.1 We do not sell your personal data. bit939 will never sell, rent, or trade your personal information to any third party for commercial purposes. Full stop.

5.2 Service providers. bit939 shares personal data with a limited number of carefully selected third-party service providers who assist us in operating the Platform. These include:

• Payment processors — JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT TRC20 providers, for the purpose of processing your transactions;
• Identity verification providers — to perform automated or assisted KYC checks on your submitted documents;
• Fraud and risk management tools — to detect suspicious login patterns, unusual betting activity, or potential money laundering;
• Cloud hosting and infrastructure providers — to store and process your data securely on servers maintained in accordance with international data security standards;
• Customer support platforms — to facilitate live chat and email support interactions in English and Urdu;
• Analytics providers — to help us understand how players use bit939.org and improve the Platform experience.

5.3 All service providers engaged by bit939 are bound by contractual data processing agreements that prohibit them from using your data for any purpose other than the specific service they provide to bit939. They are not permitted to share, sell, or retain your data beyond the contracted scope.

5.4 Legal disclosures. bit939 may disclose your personal data to regulatory authorities, law enforcement agencies, financial intelligence units, or courts where we are legally required to do so — including in connection with AML investigations, gaming license compliance audits, or court orders. In such circumstances, bit939 will disclose only the minimum data necessary and, where legally permissible, will notify you of the disclosure.

5.5 Business transfers. In the event of a merger, acquisition, or sale of all or substantially all of bit939's assets, your personal data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer via email or a prominent notice on the Platform prior to the effective date of the change.

6.1 bit939 uses cookies and similar tracking technologies on bit939.org to operate the Platform, maintain your session, detect fraud, and measure site performance. A cookie is a small text file placed on your device by our web server when you visit the site.

6.2 The following categories of cookies are used on bit939.org:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication tokens, CSRF protection cookies, and load-balancing identifiers. These cookies cannot be disabled without breaking core Platform functionality.
• Functional cookies: Remember your preferences — such as language settings and responsible gaming limits — so you do not need to re-enter them on each visit.
• Analytics cookies: Collect anonymised or pseudonymised data about how you navigate bit939.org, which pages are most visited, and where users exit the funnel. This data is used to improve the Platform.
• Security cookies: Help detect and prevent suspicious activity, including bot traffic, credential stuffing, and session hijacking attempts.

6.3 bit939 does not use third-party advertising cookies or behavioural retargeting pixels on the Platform. We do not share cookie data with advertising networks.

6.4 You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may prevent you from logging into your bit939 account or using core Platform features. The specific steps for managing cookies vary by browser — refer to your browser's help documentation for guidance.

7.1 bit939 retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, and in any event for no longer than is required by applicable law or our gaming license obligations.

7.2 The following general retention periods apply:

• Account data (name, contact details, account history): Retained for the duration of your account, plus five (5) years after closure to comply with AML and gaming regulatory requirements;
• KYC and identity verification documents: Retained for five (5) years from the date of your most recent transaction, in accordance with anti-money laundering obligations;
• Financial transaction records: Retained for seven (7) years to comply with financial record-keeping requirements;
• Support communications: Retained for three (3) years from the date of each interaction;
• Technical and log data: Retained for twelve (12) months from the date of collection, unless flagged for a security investigation;
• Marketing consent records: Retained for three (3) years from the date of consent or until withdrawn, whichever is earlier.

7.3 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data destruction procedures. Anonymised data that can no longer be linked to an individual may be retained indefinitely for aggregated analytics purposes.

8.1 bit939 implements industry-standard technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and bit939.org;
• AES-256 encryption for personal data stored in our databases at rest;
• Multi-factor authentication options for your bit939 account login;
• Role-based access controls ensuring that only authorised bit939 personnel can access personal data, and only to the extent required for their specific role;
• Regular penetration testing and vulnerability assessments conducted by independent third-party security specialists;
• Intrusion detection systems monitoring for anomalous access patterns in real time;
• Segregated network architecture isolating payment and identity data from general Platform data.

8.2 Data breach response. In the event of a personal data breach that is likely to result in a risk to your rights or freedoms, bit939 will notify affected users without undue delay, and in any event within seventy-two (72) hours of becoming aware of the breach. Notification will be provided by email to the address registered on your account, and where appropriate, by a prominent notice on bit939.org.

8.3 While bit939 takes every reasonable precaution to protect your data, no internet-based platform can guarantee absolute security. You are also responsible for keeping your account credentials confidential and for logging out of your account when using shared devices.

9.1 Depending on applicable data protection law, you may have the following rights in relation to the personal data bit939 holds about you:

• Right of access: You may request a copy of all personal data bit939 holds about you, along with information about how it is being processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data. Most profile data can be updated directly in your account settings.
• Right to erasure: You may request deletion of your personal data where there is no longer a lawful basis for us to retain it. Please note that we may be required to retain certain data to comply with AML and gaming license obligations even after account closure.
• Right to restrict processing: You may request that bit939 temporarily suspend processing of your data while the accuracy of that data or the lawfulness of our processing is being investigated.
• Right to data portability: You may request that bit939 provide your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
• Right to object: You may object to processing based on legitimate interests, and you may withdraw consent to marketing communications at any time.
• Right not to be subject to automated decision-making: Where bit939 uses automated systems to make decisions that significantly affect you (such as account suspension triggers), you have the right to request human review of those decisions.

9.2 To exercise any of the above rights, please contact bit939 support by email at the address provided in Section 12. We will respond to all data rights requests within thirty (30) days of receipt. Where a request is complex or we receive a high volume of requests, we may extend this period by a further sixty (60) days, and we will notify you accordingly.

9.3 bit939 will not charge a fee for handling data rights requests unless the request is manifestly unfounded or excessive, in which case a reasonable administrative fee may be applied.

10.1 bit939 operates a strict minimum age policy of 21 years. The Platform is not directed at, and does not knowingly collect personal data from, individuals under the age of 21. Registration on bit939.org requires confirmation that the registrant is 21 years of age or older.

10.2 As part of our KYC process, bit939 verifies the date of birth of all registered users. Any account found to belong to a person under the age of 21 will be immediately suspended. All associated deposits and any winnings will be withheld pending investigation, and the account will be permanently closed.

10.3 If you believe that a minor may have created an account on bit939.org, please notify our support team immediately at the contact details in Section 12. We take such reports extremely seriously and will investigate without delay.

11.1 bit939 operates under an international gaming license and may engage service providers located outside of Pakistan. As a result, your personal data may be transferred to, and processed in, countries other than Pakistan.

11.2 Where personal data is transferred outside of Pakistan, bit939 ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that described in this Privacy Policy. Such safeguards may include:

• Standard contractual clauses approved under applicable international data protection frameworks;
• Transfers to countries that have been determined to provide an adequate level of data protection;
• Binding corporate rules where the transfer is to a member of the same corporate group as bit939.

11.3 By using the bit939 Platform, you acknowledge and consent to the transfer of your personal data as described in this section. If you have questions about the specific safeguards in place for any particular transfer, please contact us using the details provided in Section 12.

12.1 Updates to this Policy. bit939 reserves the right to update this Privacy Policy at any time. Where changes are material, we will notify registered users by email at least seven (7) days before the updated policy takes effect. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. Continued use of the Platform after the effective date of any update constitutes acceptance of the revised Privacy Policy.

12.2 How to contact us. If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data bit939 holds about you, please contact our Data Protection team:

Email: [email protected]
Support Hours: 9:00 AM – 1:00 AM PKT (overnight agents available)
Language: English and Urdu

12.3 Complaints. If you are not satisfied with bit939's response to a data rights request or privacy concern, you may escalate your complaint to the relevant supervisory authority under the jurisdiction of our international gaming license. Details of the applicable supervisory authority are available upon request from our support team.