Privacy Policy — bat39

1 Introduction

bat39 ("bat39", "we", "us", "our") is committed to protecting the privacy of every person who visits or registers an account on the bat39 platform at bat39.cam (the "Platform"). This Privacy Policy ("Policy") explains how we collect, use, store, share and protect your personal data, and sets out the rights available to you in relation to that data.

This Policy applies to all users of the Platform, including visitors who browse without registering and registered users who hold an active account. It should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference.

By accessing the Platform or completing the account registration process, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2 Definitions

In this Policy, the following terms carry the meanings assigned below unless the context requires otherwise:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, device identifiers and transaction history.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, alteration, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this case, bat39.
• "Data Processor" means any third party that processes Personal Data on behalf of bat39 under a written contractual arrangement.
• "Cookies" means small text files placed on your device by the Platform to collect browsing and session data.
• "KYC Data" means identity verification documents and related personal information submitted by a User in connection with the Platform's Know Your Customer process.
• "User" means any individual who accesses, browses or registers an account on the Platform.

3 Data Controller

bat39 acts as the Data Controller in respect of the Personal Data collected through the Platform. As Data Controller, bat39 is responsible for ensuring that Personal Data is processed lawfully, fairly and transparently in accordance with this Policy and applicable data protection law.

If you have any questions about how your Personal Data is handled, or wish to exercise any of the rights described in Section 11 of this Policy, you may contact us using the details set out in Section 15.

4 Data We Collect

bat39 collects Personal Data in the following categories, depending on your interaction with the Platform:

4.1 Registration Data

When you create an account, we collect:

• Full legal name;
• Date of birth (to verify minimum age eligibility);
• Residential address, including city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar);
• Email address and contact telephone number;
• Username and hashed password credentials.

4.2 Identity Verification (KYC) Data

To comply with identity verification requirements before processing withdrawals, we may collect:

• Copies of government-issued photo identity documents (e.g., CNIC, passport or driver's licence);
• Proof of address documentation (e.g., utility bills or bank statements);
• Proof of payment method ownership where applicable.

4.3 Financial Transaction Data

In connection with deposits and withdrawals, we collect transaction amounts, dates, payment method references and confirmation identifiers. bat39 does not store full payment card numbers. References to payment methods familiar to Pakistani users — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are used for identification and processing context only and do not imply endorsement by those providers.

4.4 Betting & Gaming Activity Data

We maintain records of bets placed, markets selected, odds accepted, game sessions, wager amounts and outcomes. This data is used to operate the Platform, resolve disputes, detect fraud and comply with responsible gambling obligations.

4.5 Technical & Device Data

When you access the Platform, we automatically collect:

• IP address and approximate geolocation;
• Browser type and version;
• Operating system and device type;
• Pages visited, session duration and navigation path;
• Referring URL.

4.6 Communications Data

If you contact bat39 support, we retain records of that correspondence — including email content, support ticket history and live chat logs — for quality assurance, dispute resolution and audit purposes.

5 Legal Bases for Processing

bat39 processes your Personal Data on the following legal bases, depending on the category of data and the purpose of processing:

6 How We Use Your Data

bat39 uses the Personal Data we collect for the following purposes:

• Account operation: Creating and managing your account, authenticating logins and processing account-related requests.
• Transaction processing: Handling deposits, withdrawal requests and associated payment verifications in PKR and other supported currencies.
• Identity and age verification: Confirming that you meet the minimum age requirement of 18 years (or such higher minimum as required by the applicable operator or license jurisdiction) and that the information you have provided is accurate.
• Fraud and security: Detecting, investigating and preventing fraudulent activity, money laundering, unauthorised access and other prohibited conduct described in our Terms & Conditions.
• Responsible gambling: Monitoring betting activity to identify patterns that may indicate problem gambling and applying any limit or self-exclusion tools you have activated.
• Customer support: Responding to your queries, resolving disputes and providing assistance through our support channels.
• Legal compliance: Meeting any obligations imposed by applicable law or competent regulatory authorities.
• Platform improvement: Analysing usage data in aggregate and anonymised form to improve the Platform's functionality, content and user experience.
• Marketing (with consent only): Sending promotional communications about bat39 offers, cricket and PSL betting markets, live casino features and other relevant content, where you have given explicit consent and in accordance with your marketing preferences. You may withdraw consent at any time.

7 Cookies & Tracking Technologies

bat39 uses cookies and similar tracking technologies to operate the Platform, maintain session state, detect fraud and analyse user behaviour. The categories of cookies we use are described below.

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may affect the functionality of the Platform and prevent you from accessing certain features. Disabling analytics or marketing cookies will not prevent you from using the Platform but will limit our ability to personalise your experience.

8 Data Sharing & Disclosure

bat39 does not sell, rent or trade your Personal Data to third parties for their own marketing or commercial purposes. We may share your Personal Data with the following categories of recipients, strictly for the purposes described:

• Payment processors and financial service providers: To facilitate deposits, withdrawals and transaction verification. These processors are bound by confidentiality and data security obligations.
• Identity verification providers: Third-party KYC and anti-fraud service providers who assist in verifying the identity of registered users and detecting suspicious activity.
• IT infrastructure and hosting providers: Cloud hosting, database and platform infrastructure providers operating under strict data processing agreements.
• Customer support platforms: Third-party support software providers, subject to contractual data protection obligations.
• Regulatory and law enforcement authorities: Where bat39 is required by law, court order or competent regulatory direction to disclose Personal Data. bat39 will take reasonable steps to notify you of such disclosure where legally permitted.
• Successors in the event of a business transfer: In the event of a merger, acquisition or sale of all or part of bat39's business, Personal Data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

9 International Data Transfers

As an online platform serving users across multiple regions, bat39 may transfer Personal Data to servers or service providers located outside the country in which you reside. Where such transfers occur, bat39 takes reasonable steps to ensure that adequate safeguards are in place to protect your Personal Data, including the use of contractual data protection clauses with receiving parties.

Users in Pakistan should be aware that data transferred internationally may be subject to the laws of the destination country, which may differ from Pakistani law. By using the Platform, you acknowledge and consent to such transfers as described in this Policy.

10 Data Retention

bat39 retains Personal Data for the minimum period necessary to fulfil the purpose for which it was collected, unless a longer retention period is required or permitted by applicable law. The general retention principles bat39 applies are as follows:

• Account and registration data is retained for the duration of your active account relationship with bat39, plus a post-closure period as required for legal, audit and dispute resolution purposes.
• Transaction and financial data is retained for a minimum period of five (5) years following the transaction date, in line with typical financial record-keeping requirements.
• KYC documentation is retained for the period required by applicable anti-money laundering and compliance obligations, typically a minimum of five (5) years from account closure or the last transaction date.
• Betting and gaming activity records are retained for a minimum of three (3) years from the date of the relevant activity.
• Support correspondence is retained for a minimum of two (2) years from the date of the last interaction.
• Technical and device data collected via server logs is retained for up to twelve (12) months.

When Personal Data is no longer required, bat39 will securely delete or anonymise it so that it can no longer be associated with any individual.

11 Your Rights

Subject to applicable law and certain conditions, you have the following rights in relation to the Personal Data that bat39 holds about you:

To exercise any of the above rights, please contact bat39 at the address listed in Section 15. bat39 will respond to all verified requests within a reasonable timeframe. We may need to confirm your identity before processing a rights request. Some requests may be subject to limitations where retention is required by law or for legitimate operational purposes.

12 Security Measures

bat39 implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including KYC documentation and financial records;
• Role-based access controls that limit access to Personal Data to authorised personnel with a legitimate business need;
• Multi-factor authentication for internal systems that store or process Personal Data;
• Regular internal security reviews and vulnerability assessments;
• Staff training on data protection obligations and secure handling practices.

While bat39 takes data security seriously and applies industry-standard safeguards, no system is entirely immune from risk. In the event of a data breach that is likely to result in a risk to your rights and freedoms, bat39 will notify affected users without undue delay in accordance with applicable notification requirements.

13 Children's Privacy

The Platform is strictly intended for adults aged 18 years and above — or the higher minimum required by the applicable operator or license jurisdiction. bat39 does not knowingly collect Personal Data from individuals under the age of 18. If we become aware that a registered user is under the minimum age, we will immediately suspend the account, delete the associated Personal Data and return any deposited funds in accordance with our Terms & Conditions.

If you believe that a minor has registered an account on the Platform, please contact us immediately at [email protected]. We take underage access extremely seriously and will act promptly upon receipt of any such report.

14 Changes to This Policy

bat39 reserves the right to amend or update this Privacy Policy at any time. When changes are material — for example, a change to the categories of data collected, a new purpose for processing, or a new category of third-party recipient — bat39 will notify registered users by email to the address on file and will publish the revised Policy on the Platform with an updated effective date at the top of this page.

Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how we handle your Personal Data.

15 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the way bat39 handles your Personal Data, please get in touch using the details below. We aim to respond to all data-related enquiries within a reasonable timeframe.

When submitting a data rights request, please include your registered username and a clear description of your request. For security purposes, bat39 may require you to verify your identity before actioning any request. Please do not include passwords, full payment card numbers or other sensitive credentials in any correspondence.