be939 Privacy Policy

1. Who We Are

1.1 be939 is an online gaming platform operating at be939.pro, offering casino games, live dealer tables, sports betting, slot games, and related entertainment services to eligible players. The be939 platform is operated under an international gaming license and serves players across Pakistan including Karachi, Lahore, Islamabad, Faisalabad, and beyond.

1.2 For the purposes of this Privacy Policy, "be939", "we", "us", and "our" refer to the operator of the be939 platform. "You" and "User" refer to any individual who registers an Account or accesses any part of the be939 platform.

1.3 be939 acts as the data controller in respect of personal data collected through the Platform. As data controller, be939 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out lawfully and in accordance with this Policy.

1.4 If you have any questions about how be939 handles your data, you may contact our support team at any time. Contact details are provided in Section 14 of this Policy.

2. Personal Data We Collect

be939 collects the following categories of personal data from registered Users and Platform visitors:

2.1 Identity Data

• Full legal name as it appears on official identity documents
• Date of birth (used to verify the 21+ age requirement)
• National Identity Card (CNIC) number or passport number
• Copies of government-issued identity documents submitted during KYC verification
• Photograph or selfie where required for enhanced identity verification

2.2 Contact Data

• Email address registered at Account creation
• Mobile phone number (used for account verification and support communications)
• Residential address (required for KYC and regulatory compliance purposes)
• City of residence (e.g. Karachi, Lahore, Islamabad, Faisalabad)

2.3 Financial Data

• Payment method details including JazzCash account number, EasyPaisa account number, HBL or UBL bank account details, SadaPay details, or USDT TRC20 wallet address
• Deposit and withdrawal transaction amounts and timestamps
• Account balance history
• Source of funds documentation where requested during enhanced due diligence

2.4 Technical Data

• IP address and approximate geographic location at time of login
• Device type, operating system, and browser version
• Session duration and login timestamps
• Platform interaction logs including pages visited and features used

2.5 Gaming Activity Data

• Games played, bet amounts, and game outcomes
• Sports betting selections and wager history
• Bonus and promotion usage records
• Responsible gaming tool settings including deposit limits and self-exclusion status

2.6 Communications Data

• Records of customer support interactions including chat transcripts and email correspondence
• Feedback and complaint records
• Marketing preference settings and communication opt-in or opt-out status

3. How We Collect Your Data

3.1 Directly from You. The majority of personal data be939 holds is provided directly by Users during the Account registration process, KYC verification, deposit and withdrawal transactions, customer support interactions, and when setting responsible gaming preferences.

3.2 Automatically. When you access the be939 Platform, certain technical data is collected automatically through server logs, cookies, and similar tracking technologies. This includes your IP address, device information, and browsing behaviour within the Platform. Please refer to Section 7 of this Policy for full details on cookies and tracking.

3.3 From Third Parties. be939 may receive data about you from third-party identity verification providers used to complete KYC checks, payment processors used to facilitate deposits and withdrawals, and fraud prevention services. Data received from third parties is handled with the same level of care as data collected directly.

3.4 From Public Sources. Where necessary for fraud prevention or regulatory compliance purposes, be939 may cross-reference data against publicly available sources such as sanctions lists or politically exposed persons (PEP) databases maintained by relevant regulatory authorities.

4. Why We Use Your Personal Data

be939 uses your personal data for the following purposes:

Purpose	Data Categories Used
Account registration and management	Identity Data, Contact Data
Age verification and KYC compliance	Identity Data, Financial Data
Processing deposits and withdrawals	Financial Data, Identity Data
Delivering gaming and betting services	Gaming Activity Data, Technical Data
Customer support and complaint handling	Contact Data, Communications Data
Fraud prevention and security monitoring	Technical Data, Financial Data, Identity Data
Anti-money laundering compliance	Identity Data, Financial Data, Gaming Activity Data
Responsible gaming monitoring and enforcement	Gaming Activity Data, Contact Data
Marketing communications (where opted in)	Contact Data, Communications Data
Platform improvement and analytics	Technical Data, Gaming Activity Data (anonymised)

5. Legal Basis for Processing

5.1 Performance of a Contract. The majority of be939's data processing is necessary to perform the contract between be939 and the User — that is, to operate your Account, process transactions, deliver gaming services, and provide customer support. Without this processing, be939 cannot fulfil its contractual obligations to you.

5.2 Legal Obligation. be939 is required by its international gaming license and applicable anti-money laundering regulations to collect and process identity data, conduct KYC verification, monitor transactions for suspicious activity, and retain records for regulatory audit purposes. This processing is mandatory and cannot be opted out of.

5.3 Legitimate Interests. be939 processes certain technical and gaming activity data on the basis of its legitimate interests in maintaining platform security, preventing fraud, improving the User experience, and operating a sustainable gaming business. Where we rely on legitimate interests, we have assessed that our interests do not override your fundamental privacy rights.

5.4 Consent. Where be939 processes your data for marketing communications, we rely on your explicit consent as the legal basis. You may withdraw your consent to marketing communications at any time by updating your preferences in the Account dashboard or by contacting be939 support.

6. Sharing Your Personal Data

6.1 be939 does not sell, rent, or trade your personal data to any third party for commercial purposes. Data sharing is limited to the circumstances described in this section.

6.2 Service Providers. be939 works with carefully selected third-party service providers who process data on be939's behalf. These include identity verification providers, payment processors (including JazzCash, EasyPaisa, HBL, UBL, SadaPay, and USDT processing services), fraud detection services, and customer support platform providers. All service providers are bound by data processing agreements that restrict their use of your data to the purposes for which it was shared.

6.3 Regulatory Authorities. be939 is required by its gaming license and anti-money laundering obligations to share certain data with licensing authorities, financial intelligence units, and law enforcement agencies upon lawful request. be939 is prohibited from disclosing to Users when such reporting has occurred.

6.4 Business Transfers. In the event that the be939 business or platform is acquired by or merged with another entity, your personal data may be transferred as part of that transaction. Users will be notified of any such transfer and any resulting changes to this Privacy Policy prior to completion of the transaction wherever legally permissible.

6.5 With Your Consent. be939 will not share your data with any other third party without first obtaining your explicit, informed consent, except as described above.

7. Cookies & Tracking Technologies

7.1 The be939 Platform uses cookies and similar tracking technologies to enable core platform functionality, maintain your login session, remember your preferences, and analyse how the Platform is used. Cookies are small text files placed on your device by the Platform.

7.2 be939 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These enable login session management, security features, and core navigation. They cannot be disabled without severely impacting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings and responsible gaming configurations so you do not have to reset them on each visit.
• Analytics Cookies: Collect anonymised data about how Users interact with the Platform to help be939 identify areas for improvement. No individually identifiable data is transmitted via analytics cookies.
• Marketing Cookies: Used only where you have opted in to marketing communications. These help be939 deliver relevant promotions and measure campaign effectiveness.

7.3 You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to use core Platform features including logging in to your be939 Account.

7.4 be939 does not use third-party advertising network cookies that track your browsing activity across other websites.

8. Data Retention

8.1 be939 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, comply with regulatory obligations, and resolve any disputes that may arise.

8.2 The following general retention periods apply:

• Account and Identity Data: Retained for the lifetime of your Account and for a minimum of 5 years following Account closure, in accordance with anti-money laundering record-keeping requirements.
• Transaction and Financial Data: Retained for a minimum of 5 years from the date of each transaction.
• Gaming Activity Data: Retained for 3 years following Account closure unless regulatory requirements dictate a longer period.
• Customer Support Records: Retained for 3 years from the date of the final communication in each support interaction.
• Technical and Log Data: Retained for up to 12 months and then automatically deleted or anonymised.
• Marketing Preference Records: Retained for as long as your Account is active and for 2 years following Account closure for compliance audit purposes.

8.3 Where data is subject to a legal hold in connection with an ongoing investigation or dispute, retention will be extended until the matter is resolved, after which standard retention periods resume.

9. Data Security

9.1 be939 implements a layered approach to data security combining technical and organisational measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure.

9.2 Technical security measures applied by be939 include 256-bit SSL/TLS encryption for all data in transit between your device and be939 servers, encryption of sensitive data at rest, multi-factor authentication for internal system access, and regular independent security assessments of the Platform infrastructure.

9.3 Organisational measures include role-based access controls limiting data access to authorised personnel only, staff training on data protection obligations, and documented data breach response procedures.

9.4 In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, be939 will notify affected Users without undue delay and will take immediate remediation steps to contain the breach and prevent recurrence.

10. Your Data Rights

10.1 As a be939 User, you hold the following rights in respect of your personal data. Requests to exercise any of these rights should be submitted in writing to the be939 support team using the contact details in Section 14.

• Right of Access: You may request a copy of all personal data that be939 holds about you. be939 will provide this within 30 days of receiving a verified request.
• Right to Rectification: If any personal data be939 holds about you is inaccurate or incomplete, you have the right to request that it be corrected.
• 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 be939's overriding legal obligations to retain certain data under its regulatory framework.
• Right to Restrict Processing: In certain circumstances you may request that be939 restricts its processing of your personal data while a dispute about accuracy or lawfulness is resolved.
• Right to Data Portability: Where processing is based on your consent or on the performance of a contract, you may request that be939 provide your data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interests or for direct marketing purposes. Where you object to direct marketing, be939 will cease such processing immediately.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

10.2 be939 will respond to all verified data rights requests within 30 calendar days. In complex cases, this period may be extended by a further 60 days, in which case be939 will notify you of the extension and the reasons for it within the initial 30-day period.

10.3 be939 will not charge a fee for the exercise of data rights requests except where requests are manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

11. Children & Minors

11.1 The be939 Platform is strictly intended for persons aged 21 years and above. be939 does not knowingly collect personal data from any person under the age of 21. Age verification is conducted as part of the registration and KYC process for all Users.

11.2 If be939 becomes aware that personal data has been collected from a User who is under 21 years of age, that Account will be immediately suspended and all associated data will be deleted, except where retention is required by law.

11.3 If you are a parent or guardian and believe that a person under your care has registered on the be939 Platform, please contact be939 support immediately using the contact details in Section 14 and the matter will be resolved as a priority.

12. International Data Transfers

12.1 The be939 Platform serves players in Pakistan and processes data in connection with its international gaming license. This means that your personal data may be transferred to and processed in jurisdictions outside Pakistan, including the jurisdiction in which be939's servers and service providers are located.

12.2 Where data is transferred internationally, be939 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy, including through contractual obligations imposed on service providers and compliance with the data protection requirements of be939's gaming license.

12.3 By registering an Account on be939, you acknowledge and consent to the international transfer of your personal data as described in this section.

13. Updates to This Privacy Policy

13.1 be939 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or Platform services. The date of the most recent revision is clearly displayed at the top of this page.

13.2 Where changes to this Policy are material — that is, where they significantly affect how we collect, use, or share your personal data — be939 will notify registered Users via their registered email address at least 14 days before the changes take effect.

13.3 Your continued use of the be939 Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree to the revised terms, you should discontinue use of the Platform and contact be939 support to request Account closure.

14. Contact Us

14.1 If you have any questions, concerns, or complaints about this Privacy Policy or about how be939 handles your personal data, please contact our support team. be939's support team is available 24 hours a day, 7 days a week to assist with data-related queries.

14.2 You may also use the contact details below to submit a formal data rights request as described in Section 10 of this Policy. Please include your registered username, the nature of your request, and sufficient information to allow be939 to verify your identity before processing any data rights request.

For further information about your rights and the legal framework governing our platform, please also review our Terms & Conditions and our Responsible Gaming Policy.