399bat Privacy
Policy

399bat ("we", "us", "our", or "the Platform") is committed to protecting and respecting the privacy of all individuals who access or use the 399bat online gaming and sports betting platform at 399bat.vu. This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by 399bat.

This Policy applies to all data processing activities carried out by 399bat in connection with the services offered on the platform, including account registration, deposits and withdrawals, gaming and betting activity, customer support interactions, bonus programme participation, and marketing communications where applicable.

Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it. This Policy should be read alongside the Terms & Conditions, which govern the overall use of the 399bat platform and are incorporated herein by reference.

For the purposes of applicable data protection legislation, 399bat is the data controller in respect of all personal data collected from Players and visitors to the 399bat platform. As data controller, 399bat determines the purposes for which and the means by which personal data is processed.

399bat operates under an internationally recognised gaming licence, the terms of which include binding obligations with respect to the lawful, fair, and transparent processing of personal data. These obligations are fully reflected in the practices described in this Privacy Policy.

If you have any questions, concerns, or requests relating to the processing of your personal data by 399bat, you may contact our dedicated data protection team at the contact details provided in Section 15 of this Policy.

399bat collects a range of personal data in the course of providing its services. The categories of personal data we may collect and process include, but are not limited to, the following:

Identity and Contact Data

• Full legal name as it appears on government-issued identification (CNIC).
• Date of birth and age verification data.
• Residential address and city of residence within Pakistan.
• Email address and mobile phone number.
• Copies of identity documents submitted for KYC verification, including CNIC and proof of address.

Financial and Transaction Data

• JazzCash, EasyPaisa, HBL, UBL, or Meezan Bank account details used for deposits and withdrawals.
• Transaction history including deposit amounts, withdrawal requests, dates, and payment methods.
• PKR wallet balance and transaction logs within the 399bat account.
• Bonus fund credits, wagering activity, and promotional participation records.

Gaming and Betting Activity Data

• Records of all bets placed, games played, and casino sessions initiated on the 399bat platform.
• Wagering amounts, game outcomes, and session duration data.
• Responsible gaming settings applied to the account, including deposit limits and self-exclusion records.

Technical and Usage Data

• IP address, device identifiers, browser type and version, and operating system.
• Geolocation data derived from IP address or, where consented to, device GPS.
• Platform navigation data, page views, click paths, and session duration.
• Cookie identifiers and similar tracking technology data as described in Section 9.

Communications Data

• Records of customer support interactions including live chat transcripts and email correspondence.
• Feedback, complaints, and dispute records submitted to 399bat through any channel.
• Marketing communication preferences and unsubscribe records.

399bat collects personal data through the following primary channels:

399bat processes personal data only where a lawful basis for doing so exists. The following table sets out the primary purposes for which 399bat processes personal data and the corresponding legal basis for each purpose:

Where 399bat processes personal data on the basis of consent, Players have the right to withdraw that consent at any time without affecting the lawfulness of any processing carried out prior to the withdrawal. To withdraw consent for marketing communications, Players may update their preferences within their account settings or contact support.

399bat retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with applicable legal and regulatory obligations, and to resolve any disputes or enforce agreements that may arise. Specific retention periods are governed by the following principles:

• Active Account Data: Personal data associated with an active 399bat account is retained for the full duration of the account's existence plus a minimum post-closure retention period required by applicable gaming regulations.
• Transaction Records: Financial transaction records, including deposit and withdrawal history, are retained for a minimum of five (5) years from the date of each transaction in compliance with anti-money laundering legislation.
• KYC Documents: Identity verification documents submitted by Players are retained for the minimum period required by the gaming licence conditions applicable to 399bat, typically five (5) years from account closure.
• Customer Support Records: Live chat transcripts and support email correspondence are retained for a period of three (3) years from the date of the interaction.
• Technical Logs: Server and platform access logs are retained for a period of twelve (12) months, after which they are securely deleted unless required for an ongoing investigation.
• Marketing Preferences: Records of consent and unsubscribe actions are retained indefinitely to demonstrate compliance with applicable marketing regulations.

Upon the expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents re-identification. Where data is anonymised rather than deleted, the resulting anonymised dataset is no longer subject to this Privacy Policy.

399bat does not sell, rent, or trade personal data to any third party for commercial purposes. Personal data may be shared with third parties only in the following circumstances, each of which is governed by appropriate data protection safeguards:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment service providers receive the minimum personal and financial data necessary to process transactions on behalf of Players.
• KYC & Identity Verification Providers: Third-party identity verification services receive identity document data solely for the purpose of completing the KYC process required under 399bat's licensing conditions.
• Fraud Prevention & AML Services: Personal data may be shared with fraud prevention databases and anti-money laundering compliance services for the purpose of protecting the platform and its Players from financial crime.
• Game Providers & Technology Partners: Game providers and platform technology vendors may receive technical and gaming activity data necessary for the delivery of their services, subject to binding data processing agreements.
• Regulatory & Law Enforcement Authorities: 399bat will disclose personal data to licensing regulators, law enforcement agencies, or other competent authorities where required to do so by applicable law or by a valid legal order.
• Professional Advisers: Legal, accounting, and compliance advisers may access personal data on a need-to-know basis, subject to professional confidentiality obligations.

In the course of providing its services, 399bat may transfer personal data to third parties located in jurisdictions outside of Pakistan. Where such transfers occur, 399bat ensures that adequate safeguards are in place to protect the personal data transferred, including:

• Transfers to recipients in jurisdictions recognised as providing an adequate level of data protection.
• Execution of standard contractual clauses or equivalent data transfer agreements with receiving parties.
• Application of binding corporate rules or other approved transfer mechanisms where applicable.

By using the 399bat platform and providing personal data, you acknowledge and consent to the potential transfer of your data to jurisdictions outside Pakistan for the purposes described in this Policy, subject to the safeguards described above.

The 399bat platform uses cookies and similar tracking technologies to enhance the Player experience, maintain session security, and support platform analytics. Cookies are small text files placed on your device by your web browser at the instruction of the 399bat platform.

Types of Cookies Used by 399bat

• Essential Cookies: Required for the basic operation of the 399bat platform, including maintaining login sessions, preventing cross-site request forgery, and enabling core platform functionality. These cookies cannot be disabled without impairing platform functionality.
• Analytical Cookies: Used to collect aggregated and anonymised data about how Players use the 399bat platform, including pages visited, features used, and navigation paths. This data is used to improve the platform experience and identify technical issues.
• Preference Cookies: Used to remember Player preferences and settings, such as language preferences and responsible gaming configuration, so that you do not need to re-enter these settings on each visit.
• Security Cookies: Used for fraud detection, account security monitoring, and to identify unusual access patterns that may indicate unauthorised account activity.

You may manage your cookie preferences through your web browser settings. Please note that disabling essential or security cookies may affect the functionality and security of your 399bat account. Your continued use of the 399bat platform following the display of the cookie notice constitutes your consent to the use of non-essential cookies as described in this section.

399bat implements a comprehensive range of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security programme includes:

• 256-bit SSL/TLS encryption for all data transmitted between Player devices and the 399bat platform.
• Encryption of sensitive personal data and financial information at rest within 399bat's data storage systems.
• Role-based access controls ensuring that personal data is accessible only to 399bat personnel who require it to perform their job functions.
• Regular independent penetration testing and security audits of the 399bat platform and infrastructure.
• Multi-factor authentication requirements for administrative access to 399bat's internal systems.
• Continuous monitoring for unusual access patterns, data anomalies, and potential security incidents.
• Formal data breach response procedures including notification protocols in accordance with applicable regulatory requirements.

Notwithstanding the above measures, no data transmission over the internet or data storage system can be guaranteed as completely secure. Players are responsible for maintaining the security of their own account credentials and should immediately report any suspected security breach to 399bat support.

Subject to applicable data protection legislation, Players have the following rights in relation to personal data held by 399bat. These rights may be exercised by submitting a written request to the 399bat data protection team at the contact details provided in Section 15:

• Right of Access: You have the right to request confirmation of whether 399bat holds personal data about you and, if so, to receive a copy of that data along with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate personal data held by 399bat. Where data has been corrected, 399bat will notify any third parties to whom the inaccurate data was disclosed where reasonably practicable.
• Right to Erasure: You have the right to request deletion of personal data where it is no longer necessary for the purposes for which it was collected. This right is subject to overriding legal obligations that may require retention, such as anti-money laundering record-keeping requirements.
• Right to Restriction: You have the right to request that processing of your personal data be restricted in certain circumstances, such as where you contest the accuracy of the data or object to its processing.
• Right to Data Portability: You have the right to receive personal data you have provided to 399bat in a structured, commonly used, and machine-readable format and to have that data transmitted to another controller where technically feasible.
• Right to Object: You have the right to object to processing of your personal data where it is carried out on the basis of legitimate interests. 399bat will comply with such a request unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

399bat will respond to all data rights requests within thirty (30) days of receipt. Where a request is complex or numerous, this period may be extended by up to a further two (2) months, in which case you will be notified of the extension and the reasons for it. There is no charge for exercising your data rights unless requests are manifestly unfounded or excessive.

Where 399bat discovers that personal data has been collected from an individual under the age of 21 — whether through a false declaration at registration or by any other means — 399bat will immediately close the associated account, delete all personal data pertaining to that individual, and reverse any financial transactions associated with the account to the extent permitted by applicable law and payment provider capabilities.

If you are a parent or guardian and believe that a person under your care has registered a 399bat account without authorisation, please contact 399bat support immediately. We will investigate and take all necessary remedial action as a matter of priority.

The 399bat platform integrates with various third-party services — including payment processors, game providers, and identity verification services — that operate under their own separate privacy policies. 399bat is not responsible for the privacy practices of these third parties and encourages Players to review the relevant third-party privacy policies where applicable.

The 399bat platform does not embed third-party social media widgets, external advertising networks, or third-party tracking pixels that share Player data with social media platforms or unaffiliated advertisers. All tracking technologies on the 399bat platform are operated by or on behalf of 399bat solely for the purposes described in this Privacy Policy.

All third-party processors engaged by 399bat are subject to written data processing agreements that require them to: process personal data only on 399bat's documented instructions; implement appropriate technical and organisational security measures; and assist 399bat in fulfilling its obligations to Players under applicable data protection law.

399bat reserves the right to update, modify, or replace this Privacy Policy at any time. All changes will be posted on this page with an updated effective date. Where a proposed change is material — meaning it significantly affects how we process your personal data — 399bat will provide advance notice of the change either by displaying a prominent notice on the platform or by sending an email notification to your registered email address.

Non-material changes, such as typographical corrections, clarifications of existing practices, or updates to reflect changes in applicable law, will take effect immediately upon publication without prior notice. Players are encouraged to review this Privacy Policy periodically to remain informed of 399bat's current data practices.

Continued use of the 399bat platform following the effective date of any update to this Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with any changes made, you should cease using the platform and request account closure through the 399bat support team.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 399bat, please contact our data protection team through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week from any page on the 399bat platform. Select "Privacy / Data Request" as the subject category for fastest routing.
• Email: [email protected] — please include "Privacy Request" in the subject line. Responses are typically provided within one (1) business day.

For formal data rights requests — including subject access requests, erasure requests, or objection notices — please submit your request in writing to the email address above with your full name, registered account email address, and a clear description of the right you wish to exercise. 399bat may request additional information to verify your identity before processing a data rights request.