1. About This Privacy Policy
This Privacy Policy explains how 939game collects, uses, stores and protects personal information belonging to players who register and use the 939game platform. "Personal information" means any information that identifies you or could reasonably be used to identify you as an individual — for example, your name, Pakistani mobile number, CNIC number or payment account details.
This Policy applies to all interactions with 939game, including registration, depositing and withdrawing funds in PKR, playing games, placing bets, claiming bonuses, contacting customer support and using any feature of the platform. By creating a 939game account, you confirm that you have read and understood this Policy.
939game is committed to handling personal data responsibly and in accordance with good practice, even where specific legal requirements may not be fully defined in the applicable jurisdiction. Our standard is to do the right thing by our players, not simply to do the minimum required by law.
Plain English summary: This page tells you what we know about you, why we know it, who else sees it, how long we keep it and what you can do about it. We have written it in plain language deliberately — privacy policies should be readable, not something you need a lawyer to decode.
2. Personal Data We Collect
939game collects personal data through different channels depending on how you interact with the platform. Here is a complete breakdown of what we collect and how it reaches us.
2.1 Information You Give Us Directly
- Registration data: Your full legal name, date of birth, Pakistani mobile number and email address (if provided).
- Identity verification: A copy of your CNIC, passport or other identity document where requested for age verification or KYC (Know Your Customer) purposes.
- Payment information: Your Easypaisa account, JazzCash number, NayaPay ID, SadaPay details, bank account number (IBAN for IBFT) or card details (Visa/Mastercard). Full card numbers are processed by our payment processor and are not stored on 939game servers.
- Support communications: Any messages you send to our support team, including the content of your queries and any attachments you include.
- Responsible gaming information: Details of any deposit limits, loss limits or self-exclusion requests you make — held separately and with additional access controls.
2.2 Information Collected Automatically
- Device and browser data: Your device type, operating system, browser type and version, and screen resolution.
- IP address and location: Your IP address at the time of login and transactions. We use this for security purposes and to detect unusual account activity.
- Gameplay and betting data: Records of every game session, bet, deposit and withdrawal on your 939game account. This is necessary for account management, dispute resolution and legal compliance.
- Session data: Login timestamps, session duration and navigation patterns within the platform.
- Cookie data: See Section 6 for a full explanation of how 939game uses cookies.
2.3 Information from Third Parties
Where you use a third-party payment method such as Easypaisa, JazzCash, NayaPay or SadaPay, that provider may share transaction confirmation data with 939game for the purpose of crediting your account. We do not receive your full wallet credentials from these providers — only the information needed to confirm the transaction was successfully completed.
3. How 939game Uses Your Personal Data
Every use of your personal data at 939game has a specific purpose. We do not process your data for vague or speculative reasons. The table below sets out the main purposes for which 939game uses personal information:
| Purpose |
Data Used |
Legal Basis |
| Account registration & operation |
Name, mobile number, date of birth |
Contract performance |
| Payment processing |
Payment account details, transaction records |
Contract performance |
| Identity & age verification |
CNIC / identity document |
Legal obligation |
| Fraud prevention & security |
IP address, device data, transaction patterns |
Legitimate interests |
| Customer support |
Support communications, account history |
Contract performance |
| Responsible gaming monitoring |
Gameplay data, session data, limits set |
Legitimate interests / Legal obligation |
| Platform improvement |
Aggregated, anonymised usage data |
Legitimate interests |
| Marketing (where consented) |
Mobile number, email, gameplay preferences |
Consent |
If 939game wishes to use your personal data for a new purpose not described in this Policy, we will notify you in advance and, where required by applicable law, obtain your consent before proceeding.
4. Legal Basis for Processing
939game processes your personal data on one or more of the following legal grounds:
- Contract performance: Processing that is necessary to provide you with an active 939game account, to process your PKR deposits and withdrawals, and to deliver the games and betting services you have requested.
- Legal obligation: Processing required to comply with applicable law, including anti-money laundering requirements, age verification obligations and responses to lawful requests from competent Pakistani authorities.
- Legitimate interests: Processing necessary for the purposes of 939game's legitimate business interests — specifically fraud prevention, platform security, responsible gaming monitoring, and improving the quality of the platform — where those interests are not overridden by your rights and interests.
- Consent: Processing you have specifically agreed to, such as receiving promotional communications from 939game. You may withdraw consent for this type of processing at any time without affecting other uses of your data.
5. Sharing Your Personal Data
939game does not sell your personal data to anyone. We share your information only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose.
5.1 Payment Processors
To process your PKR deposits and withdrawals, 939game shares the necessary payment information with our payment processing partners — which include the technical infrastructure supporting Easypaisa, JazzCash, NayaPay, SadaPay, IBFT and card payments. These partners are contractually bound to use your data only for payment processing purposes and to maintain appropriate security standards.
5.2 Identity Verification Providers
Where identity or age verification is required, 939game may use a third-party identity verification service to cross-reference the documents or information you provide. These services are used only for verification purposes and your data is not retained by them beyond what is needed to complete the check.
5.3 Legal and Regulatory Authorities
939game will disclose personal data to Pakistani law enforcement, financial intelligence units or other regulatory bodies where required to do so by a valid legal process — such as a court order — or where we are legally obligated to report suspicious activity. We will not voluntarily disclose data to authorities beyond what is legally required.
5.4 Service Providers
Certain technical functions of the 939game platform are delivered by third-party service providers — for example, cloud hosting infrastructure and email delivery services. These providers operate under data processing agreements that restrict them from using your data for any purpose other than delivering the specific service they provide to 939game.
Important: 939game does not transfer your personal data to any third party for advertising, marketing profiling or data brokerage purposes. Your information is never made available for sale or for use by companies unrelated to the operation of your 939game account.
6. Cookies and Tracking Technologies
939game uses cookies and similar tracking technologies to operate the platform, remember your preferences and analyse how the platform is used. Here is what that means in practice:
6.1 Essential Cookies
These are cookies that are strictly necessary for the platform to function. They maintain your logged-in session, remember your language and currency preferences and enable core platform features. You cannot opt out of essential cookies without disabling your ability to use 939game, since they are required for basic operation.
6.2 Analytics Cookies
939game uses anonymised analytics to understand how players navigate the platform so we can improve it. Analytics data does not identify you as an individual — it tells us things like which pages are most visited and where players encounter problems. You can opt out of analytics cookies without affecting your ability to use 939game.
6.3 Security Cookies
These cookies help 939game detect and prevent fraudulent activity, including account takeover attempts and unusual transaction patterns. They operate in the background and do not collect any information beyond what is needed for security purposes.
6.4 Managing Cookies
You can manage cookie preferences through your browser settings. Most modern browsers allow you to view, delete and block cookies from specific websites. Blocking all cookies from 939game may affect your ability to stay logged in and use certain features of the platform.
7. Data Security
939game implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:
- TLS encryption on all data transmitted between your device and 939game servers.
- Encryption of sensitive data at rest, including payment information and identity documents.
- Access controls that restrict which 939game staff can access personal data, based on the principle of least privilege — staff can only access data they need to do their specific job.
- Regular security reviews and penetration testing of the platform infrastructure.
- Two-factor authentication options for player accounts and for internal staff systems.
- Secure disposal procedures for data that is no longer required to be retained.
No security system is completely impenetrable. In the event of a data breach that is likely to result in a risk to players' rights and interests, 939game will notify affected players as promptly as reasonably possible and will take immediate steps to contain the breach and minimise harm.
8. How Long We Keep Your Data
939game retains your personal data for the following periods:
- Active account data: Retained for as long as your 939game account remains open and active.
- Closed account data: Following account closure, we retain the minimum data required by our legal obligations — typically transaction records and identity verification data for a period of five years from the date of the last transaction, in line with anti-money laundering record-keeping standards.
- Support communications: Retained for three years from the date of the communication, unless they relate to a dispute or legal matter in which case they are retained until the matter is fully resolved.
- Marketing consent records: Retained for as long as you have consented to receive communications and for one year after consent is withdrawn, as evidence of your consent history.
- Analytics data: Aggregated and anonymised — not subject to retention limits as it does not identify individuals.
When data reaches the end of its retention period, it is securely deleted or rendered anonymous so it can no longer be linked back to you as an individual.
9. Your Data Rights
As a 939game player, you have the following rights in relation to your personal data. These rights are free to exercise and can be invoked at any time by contacting support@939game.app.
