ber939 Privacy Policy

1 Who We Are

ber939 is an online casino and sports betting platform operated under an international gaming licence and accessible at ber939.app. For the purposes of this Privacy Policy, ber939 acts as the data controller in respect of all personal data collected from players who register and use the Platform.

This Privacy Policy applies to all individuals who access ber939 — including registered players, visitors who browse the Platform without an account, and individuals who contact ber939 support. It covers all data processing activities carried out by ber939 in connection with the operation of its Platform and associated services, including cricket betting, live casino, slots, and PKR payment processing.

2 Personal Data We Collect

ber939 collects the following categories of personal data in the course of operating its Platform and fulfilling its legal obligations:

• Identity Data: Full name, date of birth, gender, nationality, and government-issued identification numbers (e.g., CNIC or passport number) provided during the registration and Know Your Customer (KYC) verification process.
• Contact Data: Email address, phone number, and city or region of residence (e.g., Karachi, Lahore, Islamabad, Faisalabad). This is used for account communications and, where you have opted in, promotional messages.
• Financial Data: References to your JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Bank Alfalah, or cryptocurrency wallet used for deposits and withdrawals. ber939 does not store full bank account credentials directly; payment references are handled by regulated payment processors.
• Technical Data: IP address, device identifiers, browser type and version, operating system, time zone settings, and session logs automatically recorded when you access the Platform.
• Usage Data: Information about your activity on the Platform, including games played, bet amounts, sports markets accessed, session duration, and bonus activity.
• Communications Data: The content of any live chat conversations, support emails, complaints, or feedback you submit to the ber939 team.
• Responsible Gaming Data: Records of any deposit limits, loss limits, cooling-off periods, or self-exclusion requests you have set, and any responsible gaming assessments conducted.

3 How We Collect Your Data

ber939 collects personal data through the following methods:

• Direct provision: Information you provide when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or respond to a survey or promotion.
• Automated collection: Technical and usage data collected automatically by the Platform as you browse, play games, or place bets — through server logs, session tracking, and platform analytics tools operating within the ber939 environment.
• Third-party providers: Identity verification and AML screening partners may share verification outcomes with ber939 as part of the KYC process. Payment processors confirm transaction status. ber939 does not receive raw banking credentials from these providers.
• Cookies and similar technologies: As described in Clause 6 below, ber939 uses cookies and comparable technologies to maintain session state, detect fraud, and improve Platform performance.

4 How We Use Your Data

ber939 uses the personal data it collects for the following purposes:

• Account management: To create, verify, maintain, and close your ber939 player account, including processing deposits and withdrawals in PKR.
• Identity and age verification: To confirm that you are at least 21 years of age and meet all eligibility requirements under ber939's Terms & Conditions and applicable regulations.
• Regulatory compliance: To fulfil Anti-Money Laundering (AML), Counter-Terrorism Financing (CTF), and Know Your Customer (KYC) obligations under ber939's international gaming licence.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account compromise, multi-accounting, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gameplay patterns for indicators of problem gambling, apply limits or restrictions you have set, and contact you where the ber939 responsible gaming team identifies a concern.
• Platform improvement: To analyse usage patterns, diagnose technical issues, and improve the performance and features of the ber939 Platform for players across Pakistan and beyond.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given explicit opt-in consent. You may withdraw this consent at any time from your account settings.
• Dispute resolution: To investigate and resolve complaints, chargebacks, or disputes in a fair, evidence-based manner.

5 Sharing Your Data with Third Parties

ber939 does not sell, rent, or trade personal data. Data is shared with third parties only in the following limited circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and cryptocurrency processing partners receive the minimum data necessary to process PKR transactions on your behalf.
• Identity verification providers: Licensed KYC and AML screening services receive identity data for the purpose of verifying your age, identity, and compliance with anti-money laundering regulations.
• Game software providers: Third-party game studios and live casino operators (such as those powering Ezugi Live tables) may receive a session token and your username for the purpose of launching game sessions. They do not receive your financial or identity documents.
• Legal and regulatory authorities: ber939 will disclose personal data to regulatory bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or the conditions of its international gaming licence.
• Professional advisers: Lawyers, auditors, and compliance consultants engaged by ber939 may access data on a confidential, need-to-know basis in the course of providing professional services.

All third-party data processors engaged by ber939 are bound by contractual data protection obligations consistent with the standards set out in this Privacy Policy.

6 Cookies & Tracking Technologies

ber939 uses cookies and similar local storage technologies on the Platform for the following purposes:

• Strictly necessary cookies: Required to keep you logged in to your ber939 account, maintain your session state across pages, and ensure the Platform operates correctly. These cannot be disabled without preventing access to core Platform features.
• Security cookies: Used to detect and prevent fraudulent access attempts, multi-accounting, and bot activity. These are integral to protecting the integrity of the Platform.
• Performance cookies: Collect anonymised data about how players navigate the Platform — such as which game categories are most visited and where errors occur — to help ber939 improve Platform performance and user experience.
• Preference cookies: Store your language preference, display settings, and responsible gaming configurations so these are remembered across sessions.

ber939 does not use third-party advertising cookies or share cookie data with external advertising networks. You can manage cookie preferences through your browser settings, though disabling strictly necessary cookies will affect your ability to use the Platform.

7 Data Security

ber939 implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction:

• All data in transit between your device and ber939 servers is encrypted using Transport Layer Security (TLS 1.2 or higher).
• Passwords are stored using industry-standard one-way hashing algorithms and are never held in plain text.
• Access to production databases containing player data is restricted to authorised personnel only and is protected by multi-factor authentication and detailed access logging.
• ber939 conducts regular internal security reviews and vulnerability assessments to identify and remediate potential weaknesses in the Platform infrastructure.
• In the event of a data breach that poses a risk to your rights and freedoms, ber939 will notify affected players and relevant authorities as required by its licensing obligations and applicable law, without undue delay.

8 Data Retention

ber939 retains personal data for the following periods, after which data is securely deleted or anonymised:

• Active account data: Retained for the full duration of your ber939 account being open and active.
• Closed account data: Following account closure — whether voluntary or due to a Terms breach — ber939 retains identity, financial, and transaction records for a minimum of five (5) years to satisfy AML, KYC, and gaming licence regulatory requirements.
• Support communications: Live chat transcripts and email correspondence are retained for three (3) years to support dispute resolution and service quality review.
• Technical and usage logs: Retained for up to twelve (12) months for security and fraud investigation purposes, after which they are anonymised or deleted.
• Marketing consent records: Retained for as long as your account is active or until you withdraw consent, plus one (1) year thereafter as evidence of consent status.

Where ber939 is required by law or regulatory obligation to retain data beyond these periods, the longer retention period will apply. You may request confirmation of the retention period applicable to your specific data by contacting ber939 support.

9 Your Data Rights

Subject to applicable law and the conditions of ber939's international gaming licence, you have the following rights in respect of your personal data:

• Right of Access: You may request a copy of the personal data ber939 holds about you. ber939 will provide this within 30 days of receiving a verified request.
• Right of Rectification: You may request correction of any inaccurate or incomplete personal data. Certain corrections — such as changes to your registered name — may require supporting documentation.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ber939's regulatory retention obligations.
• Right to Restrict Processing: You may request that ber939 limit processing of your data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: You may request that ber939 provide your data in a structured, commonly used, machine-readable format where technically feasible.
• Right to Object: You may object to processing of your data for direct marketing at any time. You may also object to processing based on legitimate interests, though ber939 may continue processing where it can demonstrate compelling legitimate grounds.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time via your account settings or by contacting support. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, contact ber939 support via live chat or email. ber939 will verify your identity before processing any data rights request to prevent unauthorised access to your information.

10 Children & Minors

ber939 operates a strict 21+ age policy. The Platform is not intended for, directed at, or designed to be used by individuals under the age of 21. ber939 does not knowingly collect personal data from anyone under 21 years of age.

Age verification is carried out at registration and may be repeated at any point during your use of the Platform. If ber939 discovers that an account has been opened by or is being used by a person under 21, that account will be immediately suspended, all funds will be frozen pending investigation, and the matter will be referred to ber939's compliance and responsible gaming teams.

If you are a parent or guardian and believe that a minor in your household has accessed ber939, please contact ber939 support immediately so that the account can be investigated and closed. ber939 recommends the use of parental control software to prevent minors from accessing online gambling platforms.

11 International Data Transfers

ber939 is operated under an international gaming licence, and some of its technology infrastructure, game software providers, and compliance partners are located outside Pakistan. As a result, your personal data may be transferred to and processed in countries other than Pakistan.

Where such transfers occur, ber939 takes steps to ensure that appropriate safeguards are in place to protect your data to a standard consistent with this Privacy Policy. These safeguards may include contractual data protection clauses with the receiving entity, reliance on the receiving country's adequacy status under applicable data protection frameworks, or other recognised transfer mechanisms.

By using the ber939 Platform, you acknowledge that your data may be processed in jurisdictions outside Pakistan in the manner described above.

12 Updates to This Privacy Policy

ber939 may update this Privacy Policy from time to time to reflect changes in its data practices, applicable law, or the structure of the Platform. When material changes are made, ber939 will notify registered players by posting a notice on the Platform and, where appropriate, by sending a notification to your registered email address.

The date of the most recent update is displayed at the top of this document. Your continued use of the ber939 Platform following the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the updated Policy, you must cease using the Platform and request account closure.

ber939 recommends that you review this Privacy Policy periodically to stay informed about how your data is being protected. Previous versions of the Privacy Policy are available upon request by contacting ber939 support.

13 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way ber939 handles your personal data, please contact the ber939 support and data team through the following channels:

• Live Chat: Available 24/7 directly within your ber939 account dashboard, in both English and Urdu — ideal for players across Karachi, Lahore, Islamabad, and Faisalabad.
• Email: [email protected] — responses are targeted within 24 hours on business days. This address is provided as plain text only and is not a clickable link.

ber939 is committed to resolving privacy concerns promptly and transparently. If you submit a formal data-related complaint, ber939 will acknowledge receipt within 5 business days and provide a substantive response within 30 days. Where a complaint cannot be resolved internally, ber939 will direct you to the applicable escalation mechanism under its international gaming licence.