This Privacy Policy ("Policy") describes how 939 Game ("the Platform", "we", "us", "our") at 939game.ws collects, processes, stores, and protects personal data belonging to registered players and visitors ("you", "your"). This Policy applies across all access points to 939 Game — including the website, any mobile-optimised version, and all associated customer communication channels.
By registering an account or using any service on 939 Game, you acknowledge that you have read this Policy and consent to data collection and processing as described. This Policy should be read alongside the Terms and Conditions and Responsible Gaming policy.
Introduction
Privacy matters. We know Pakistani users are increasingly aware of how their data is handled online — and rightly so. At 939 Game, we have made it a priority to be transparent about our data practices from day one. This is not a document buried in legalese that nobody reads. We have written this Policy in plain English so that any player in Pakistan can understand it without needing a lawyer.
939 Game collects personal data for specific, legitimate purposes: to operate your account, process PKR transactions, comply with anti-fraud obligations, and improve the platform experience. We do not collect data speculatively, and we do not hold onto it longer than we need to. Every data point we collect has a defined purpose and a defined retention period.
The contact point for all privacy-related matters at 939 Game is support@939game.ws. If you have any question about this Policy — whether before or after registration — please reach out and we will respond within 48 hours.
Personal Data We Collect
939 Game collects the following categories of personal data from players and, where applicable, from visitors who have not yet registered:
| Data Category | Specific Examples | When Collected |
|---|---|---|
| Identity Data | Full name, date of birth, CNIC number, username | Registration & KYC verification |
| Contact Data | Pakistani mobile number, email address | Registration |
| Financial Data | Easypaisa/JazzCash/NayaPay/SadaPay account reference, bank account details for IBFT, last four digits of card | Deposit & withdrawal setup |
| Transaction Data | Deposit amounts, withdrawal amounts, bet history, game session records, all denominated in PKR | Ongoing platform use |
| Technical Data | IP address, device type, browser type, operating system, session timestamps | Each platform session |
| Usage Data | Pages visited, games played, features accessed, time spent per session | Each platform session |
| Communication Data | Support chat transcripts, emails sent to and from support@939game.ws, complaint records | When you contact support |
| KYC Documents | Scanned CNIC, proof of address documents, selfie for liveness verification | KYC verification process |
What we do not collect: 939 Game does not collect full payment card numbers, CVV codes, or full bank account numbers. Payment processing is handled by certified third-party processors who hold PCI-DSS compliance. We only receive tokenised references, not full financial credentials.
How We Collect Your Data
939 Game collects personal data through three main channels:
- Direct input by you: Information you provide when registering, completing KYC, making deposits or withdrawals, filling in support requests, participating in promotions, or updating account settings. This is the primary source of identity, contact, and financial data.
- Automated collection: Technical and usage data collected automatically each time you access 939 Game. This includes IP address logging, browser fingerprinting for fraud prevention, session duration tracking, and game interaction data recorded by the platform's backend systems.
- Third-party sources: Identity verification data returned by our KYC provider after document checks. Fraud risk signals returned by payment processors during transaction screening. Analytics aggregates from platform performance monitoring tools that help us identify and fix technical issues.
939 Game does not purchase marketing lists, scrape data from other platforms, or collect data from social media profiles.
How We Use Your Personal Data
Every use of your data at 939 Game has a specific purpose. We do not use data for purposes beyond what is described below without first notifying you and obtaining any consent required.
- Account management: Creating, maintaining, and securing your 939 Game account. Processing login sessions, resetting credentials, and managing account preferences.
- Payment processing: Verifying that the payment method you use matches your registered identity. Processing PKR deposits, withdrawals, and refunds via Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT, Visa, and Mastercard.
- Identity and age verification: Confirming that all registered players meet the 18+ age requirement and that the identity information provided is genuine. This is a legal and operational requirement — not optional.
- Fraud prevention and platform integrity: Detecting and investigating suspicious account activity, bonus abuse, multiple account registrations, and bet manipulation. Protecting honest players by removing dishonest ones.
- Responsible gaming monitoring: Monitoring account activity for patterns that may indicate problem gambling behaviour, and making responsible gaming tools available proactively. Enforcing self-exclusion and deposit limit settings you have applied to your account.
- Customer support: Using communication data and account history to handle queries, resolve disputes, and investigate complaints. Support records are retained to ensure consistent service and to identify recurring issues.
- Platform improvement: Using aggregated, anonymised usage data to understand which features players use most, identify technical problems, and improve the 939 Game platform experience for Pakistani users.
- Marketing communications: Sending promotional emails or in-platform notifications about bonuses, promotions, and new features — only to players who have opted in to receive them. You can unsubscribe at any time.
Legal Basis for Processing
939 Game processes personal data under the following legal grounds:
- Contractual necessity: Most data processing at 939 Game is necessary to perform the contract between you and the platform — running your account, processing your bets, and paying out your winnings. Without this processing, the service cannot function.
- Legitimate interests: Fraud prevention, platform security, and responsible gaming monitoring are carried out on the basis of legitimate interests — protecting the integrity of the platform and the wellbeing of all players.
- Consent: Marketing communications and optional data uses — such as personalised game recommendations — are conducted only with your explicit, freely given consent. Consent can be withdrawn at any time without affecting other services.
- Legal obligation: KYC and identity verification, transaction record retention, and cooperation with lawful regulatory investigations are carried out to meet legal obligations applicable to platform operations.
Data Sharing
939 Game shares personal data with third parties only where it is strictly necessary for platform operations. We do not sell, rent, or license player data to any marketing company, data broker, or commercial third party.
The categories of third parties with whom 939 Game may share your data, and the limited purpose for each, are:
- Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, and banking partners receive the minimum data necessary to execute your deposit or withdrawal instruction — typically your registered name and the transaction amount in PKR.
- KYC and identity verification providers: Identity document data is shared with our certified KYC verification partner to confirm age and identity. This partner operates under its own data protection obligations and processes data only for verification purposes.
- Fraud prevention services: Technical data including IP addresses and device fingerprints may be shared with fraud detection services that help 939 Game identify suspicious account patterns across the industry.
- Regulatory and legal authorities: Where required by a lawful legal order, court ruling, or regulatory investigation, 939 Game may be required to disclose player information. We will notify affected players wherever legally permitted to do so.
- Platform analytics providers: Anonymised and aggregated usage data — with no personally identifiable information — may be shared with analytics providers to monitor platform performance and identify technical improvements.
What we never do: We do not share your betting history, account balance, or any personally identifiable information with advertisers, social media platforms, or data monetisation companies.
Cookies & Tracking Technologies
939 Game uses cookies and similar tracking technologies on its website. A cookie is a small text file placed on your device by the website you are visiting. Cookies allow the platform to recognise your device across sessions, maintain your login state, and remember your preferences.
| Cookie Type | Purpose | Can Be Disabled? |
|---|---|---|
| Essential Cookies | Required for login sessions, account authentication, bet slip functionality, and secure payment flows. Without these, the platform cannot operate. | No — required for core function |
| Performance Cookies | Collect anonymised data about which pages are visited and how long sessions last. Used to identify and fix technical issues. | Yes — via browser settings |
| Preference Cookies | Remember your platform preferences such as odds format (decimal/fractional/American), language settings, and last visited section. | Yes — clearing cookies resets preferences |
| Security Cookies | Used for fraud detection, bot detection, and session integrity verification. Help protect your account from unauthorised access. | No — required for account security |
You can manage or delete cookies through your browser settings at any time. Disabling non-essential cookies will not prevent you from using 939 Game, but it may affect certain personalisation features.
Data Retention
939 Game retains personal data for as long as it is necessary for the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply:
- Account data (identity, contact): Retained for the duration of your active account plus 5 years after account closure. This period covers potential regulatory review, fraud investigation timelines, and dispute resolution windows.
- Financial transaction records: All deposit, withdrawal, and betting transaction records are retained for a minimum of 5 years in line with standard financial record-keeping requirements.
- KYC documents: Identity verification documents are retained for 5 years from the date of submission or from account closure, whichever is later.
- Support communications: Chat logs and email correspondence with the support team are retained for 3 years to allow review of previous interactions in follow-up cases.
- Technical and session logs: IP logs and session technical data are retained for 12 months for fraud detection and security review purposes.
- Marketing consent records: Records of marketing opt-in and opt-out events are retained for the period of your account plus 2 years, to allow compliance verification if requested.
When data is no longer required and no legal retention obligation applies, 939 Game permanently deletes or irreversibly anonymises it. Anonymised data may be retained indefinitely for aggregate statistical analysis.
Data Security
939 Game implements technical and organisational security measures appropriate to the sensitivity of the data we hold. Security is not an afterthought here — it is a core operating requirement given that we handle financial data for Pakistani players.
- All data transmitted between your device and 939 Game's servers is encrypted using TLS (Transport Layer Security). This protects your login credentials, deposit confirmations, and account information from interception.
- Account passwords are stored using one-way cryptographic hashing. 939 Game staff cannot see your password and will never ask you for it.
- Access to player data within 939 Game is restricted on a need-to-know basis. Customer support agents can see what is necessary to handle your query. They do not have access to full payment credentials or raw KYC document images.
- All third-party service providers who process player data on 939 Game's behalf are contractually required to maintain equivalent data security standards.
- In the event of a data security incident that is likely to affect your rights or freedoms, 939 Game will notify affected players promptly and take immediate remediation steps.
Protect your own account: Use a strong, unique password for your 939 Game account. Enable two-factor authentication if offered. Never share your login credentials with anyone — 939 Game staff will never ask for your password. If you think your account has been compromised, contact support@939game.ws immediately.
Your Data Rights
You have specific rights over the personal data that 939 Game holds about you. These rights are meaningful and exercisable — not just legal formalities. To exercise any of the rights below, contact support@939game.ws. All requests will be acknowledged within 5 business days.
Right of Access
You can request a copy of all personal data 939 Game holds about you. We will provide this within 30 days of a verified request, in a readable format.
Right to Rectification
If any personal data we hold about you is inaccurate or incomplete, you can request that we correct it. Changes to identity data may require re-verification.
Right to Erasure
You can request deletion of your personal data. Note that data subject to legal retention obligations (financial records, KYC) cannot be deleted before the mandatory period expires.
Right to Withdraw Consent
Where processing is based on consent — primarily marketing communications — you can withdraw consent at any time. This will not affect any processing already carried out.
Right to Restriction
You can request that we restrict processing of your data while a dispute is under investigation or while you challenge the accuracy of data we hold.
Right to Portability
You can request a structured, machine-readable copy of the data you have provided to 939 Game, where technically feasible and where the processing is based on consent or contract.
Children's Privacy
939 Game's services are strictly for adults aged 18 and above. We do not knowingly collect personal data from anyone under the age of 18. If 939 Game discovers that a registered account belongs to an individual under 18, that account will be closed immediately, any real-money balance will be returned to the verified payment method, and all data associated with the account will be deleted within the limits of legal retention obligations.
Parents and guardians who believe a minor may have registered on 939 Game are encouraged to contact support@939game.ws immediately. 939 Game will investigate and act promptly. We also encourage the use of parental control software to prevent minors from accessing online gaming platforms.
If you are under 18, you are not permitted to use 939 Game under any circumstances. Do not register and do not attempt to place bets. If you need help with problem gambling affecting someone in your household, visit our Responsible Gaming page.
Changes to This Policy & Contact
939 Game may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or platform features. When material changes are made, we will notify registered players by email and/or in-platform notification at least 7 days before the new Policy takes effect. The "Last Updated" date at the top of this page will always reflect the current version.
If you continue using 939 Game after a revised Privacy Policy has taken effect, you are deemed to have accepted the updated terms. If you disagree with any change, you have the right to close your account by contacting support before the new Policy takes effect.
For all privacy-related requests, questions, or complaints, please contact:
- Email: support@939game.ws — We acknowledge all privacy requests within 5 business days and aim to resolve them within 30 days.
- Live Chat: Available on the 939 Game platform when logged in. For urgent account security concerns, live chat is the fastest channel.
- FAQ: Common questions about account data and privacy are answered on our FAQ page.
Our commitment: 939 Game is committed to handling every privacy request with the same seriousness we apply to financial transactions. Your data deserves the same level of care as your PKR balance — and at 939 Game, it gets it.