be939 Privacy Policy — How We Protect Your Data

be939 operates be939.win as an online gaming platform for players in Pakistan. We understand that when you use our platform, you trust us with personal information about yourself — your name, contact details, payment information and your activity on the platform. That trust is not something we take lightly.

This Privacy Policy sets out clearly and honestly how we collect your personal data, what we do with it, who we share it with and for how long we keep it. It also explains the rights you have over your own information and how to exercise them. We have written this in plain language rather than dense legal text because we want you to actually understand it, not just scroll past it.

This policy applies to information collected through the be939 website, the be939 app and any communications between you and be939 through our support channels. It applies to all Pakistani players using the platform, and all transactions are conducted in PKR.

be939 collects personal information in several ways — directly from you when you register and use the platform, automatically through your use of the site and app, and from third parties such as payment processors and identity verification services. Here is a breakdown of the categories of information we collect:

We do not collect sensitive personal information beyond what is required for identity verification and fraud prevention. We do not collect information about your religion, political views or any other sensitive categories that are not relevant to the gaming service.

be939 uses your personal information for specific, legitimate purposes. We do not use your data beyond what is necessary to provide and improve the platform. The main purposes for which we use your information are:

• Account management: Creating and maintaining your be939 account, verifying your identity and keeping your account details up to date.
• Payment processing: Processing PKR deposits and withdrawals through JazzCash, Easypaisa, Raast, bank transfer and card methods.
• Platform provision: Enabling you to place bets on Cricket, PSL, Football, Esports and other markets; play Casino, Slots, Live Casino and Fish Games; and access all platform features.
• Security and fraud prevention: Detecting and preventing fraudulent activity, account abuse, bonus exploitation and other prohibited conduct as described in the Terms and Conditions.
• Customer support: Responding to your queries, complaints and requests through our support channels.
• Responsible gaming: Monitoring gaming activity to support responsible play tools, including deposit limit management and self-exclusion functionality.
• Platform improvement: Analysing usage patterns to improve the platform experience, fix technical issues and develop new features.
• Communications: Sending you account-related notifications, transaction confirmations and, where you have opted in, promotional communications.

We do not use your personal data for automated decision-making that produces significant legal effects on you without human oversight. Where automated systems flag unusual activity, a human review process is involved before any significant account action is taken.

All financial transactions on be939 are conducted in PKR. When you deposit or withdraw using JazzCash, Easypaisa, Raast, bank transfer or debit/credit card, your payment details are processed through our payment service providers. be939 does not store complete card numbers or full mobile wallet credentials on its own servers — payment data is handled by the relevant payment processor in accordance with their own security standards.

be939 retains records of your transaction history — amounts, dates, payment methods used and transaction references — as this is necessary for account management, dispute resolution and compliance with financial record-keeping requirements. This transaction data is stored securely and accessed only by authorised staff.

Where be939 requests documentation regarding the source of deposited funds, this is a standard financial security measure. Such documentation is handled with the same level of care and confidentiality as all other personal data collected by be939.

be939 does not sell your personal data to third parties. We share your information only in the limited circumstances described below, and only to the extent necessary for each purpose:

• Payment processors: JazzCash, Easypaisa, Raast, card processors and banking partners receive the payment information necessary to process your transactions.
• Identity verification providers: Third-party KYC services receive identity documents and verification data where identity checks are required.
• Fraud prevention services: We share relevant data with fraud detection systems to protect the integrity of the platform and its users.
• Technology providers: Hosting, infrastructure and analytics providers who process data on our behalf under strict data processing agreements.
• Legal compliance: Where required by applicable law or in response to valid legal requests from authorities, we may disclose personal data as required.

All third parties with whom we share personal data are required to maintain appropriate security standards and to use the data only for the purposes for which it was shared. We do not authorise our service providers to use your data for their own independent purposes.

be939 uses cookies and similar tracking technologies on the website and app to provide core platform functionality and to understand how the platform is being used. Cookies are small files stored on your device that help the platform remember your preferences and session information.

The types of cookies be939 uses include:

• Essential cookies: Required for the platform to function. These handle your login session, keep you logged in between pages and enable core features. These cannot be disabled without breaking the platform.
• Analytics cookies: Help us understand how players use the platform — which pages are visited most, how long sessions last and where users encounter issues. This data is used in aggregate to improve the platform.
• Preference cookies: Remember your settings and preferences, such as language preferences and display options, so you do not need to reset them every visit.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies may affect some features of the platform but will not prevent you from accessing core gaming and account functions.

be939 retains your personal data for as long as your account is active and for a reasonable period after account closure to meet our legal, financial and operational obligations. The specific retention periods we apply are as follows:

• Account data: Retained for the duration of your account and for up to five years after account closure, as required for financial record-keeping and fraud prevention purposes.
• Transaction records: Retained for a minimum of five years in line with standard financial record-keeping requirements.
• Identity verification documents: Retained for the duration of the account plus the legally required period after closure.
• Support communications: Retained for up to three years to enable review of previous interactions in ongoing support cases.
• Technical and log data: Generally retained for shorter periods, typically 12 months, as it is used primarily for security monitoring and platform diagnostics.

After the applicable retention period has passed, personal data is securely deleted or anonymised so that it can no longer be linked back to you.

be939 takes the security of your personal data seriously and has implemented a range of technical and organisational measures to protect it. These include:

• Encryption of data in transit using TLS/SSL protocols across the website and app
• Secure storage of personal data on access-controlled servers
• Strict internal access controls — only authorised staff can access personal data, and only to the extent needed for their role
• Regular security reviews and monitoring of platform infrastructure
• Payment data handled by PCI-compliant payment processors rather than stored directly on be939 servers

While we take strong precautions, no system is completely immune to security threats. In the event of a data breach that poses a risk to your rights, be939 will take prompt action to contain the breach and will notify affected users as appropriate. You can also help protect your account by keeping your password confidential and not sharing your login details with anyone.

As a user of be939, you have rights over your own personal data. These rights include:

• Right of access: You can request a copy of the personal data be939 holds about you.
• Right to rectification: If any personal data be939 holds about you is inaccurate, you can ask us to correct it.
• Right to erasure: In certain circumstances — for example, where data is no longer needed for the purpose it was collected — you can request deletion of your personal data. Note that legal retention obligations may mean we are required to keep certain records.
• Right to restrict processing: You can ask be939 to limit how your data is used in certain circumstances while a query or dispute is being resolved.
• Right to object: Where data is being processed on the basis of legitimate interests, you can object to that processing.

To exercise any of these rights, contact be939 support through your account or via the contact details on the platform. We will respond to requests within a reasonable timeframe. We may need to verify your identity before processing a data rights request to ensure we are responding to the correct person.

be939 is strictly for adults aged 18 and above. We do not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and believe that a minor has registered on be939 or provided personal information to us, please contact support immediately. We will take prompt steps to delete the account and remove any associated personal data.

During registration, users are required to confirm that they are 18 or over. Where age verification is requested, identity documents are checked to confirm eligibility. Any account found to belong to a person under 18 will be permanently closed and all associated data will be deleted in accordance with this policy.

be939 may update this Privacy Policy from time to time to reflect changes in our data practices, platform features or applicable standards. When material changes are made, the updated policy will be published on this page with a revised "Last Updated" date at the top.

We recommend reviewing this page periodically so you are always aware of how your data is being handled. Continued use of be939 after an updated Privacy Policy has been published constitutes your acceptance of the changes. If you disagree with any changes to this policy, you should stop using the platform and may request account closure through support.

If you have questions, concerns or requests relating to this Privacy Policy or to the personal data be939 holds about you, please get in touch with our support team. We are available around the clock and will respond to privacy-related queries as a priority.

You can also visit the FAQ page for answers to common questions, or review the Terms and Conditions for the full platform rules. For guidance on managing your gaming activity, visit the Responsible Gaming page.