ber939 is an online casino and sports betting platform operating at ber939.bet. For the purposes of this Privacy Policy, ber939 is the data controller — meaning we are the entity that determines the purpose and means of processing your personal data. When this document refers to "ber939", "we", "us", or "our", it refers to the company behind ber939.bet and its affiliated data processing operations.
ber939 is a platform built specifically for Pakistani players. All of the data practices described in this policy are designed with the context of Pakistani users in mind — our PKR payment integrations, our player verification processes, and our communication preferences all reflect the reality of operating a platform for members in Pakistan.
Our primary contact for all privacy-related matters is our Data Protection team, reachable at privacy@ber939.bet. For general account and support queries, please use support@ber939.bet or the 24/7 live chat accessible from any ber939 page when logged in.
ber939 collects only the personal data that is genuinely necessary for running your account, providing services, verifying your identity, processing payments, and complying with legal obligations. We do not collect data speculatively. Here is a breakdown of the categories of data we collect and when each is gathered.
| Data Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full legal name, CNIC number, date of birth, nationality | Registration & KYC verification |
| Contact Data | Email address, Pakistani mobile number, city of residence | Registration |
| Financial Data | Easypaisa/JazzCash wallet number, bank account details (for IBFT), card last-4 digits | First deposit / payment setup |
| KYC Documents | CNIC scan/photo, selfie for liveness check, proof of payment method ownership | Pre-withdrawal verification |
| Account Activity Data | Login timestamps, bet history, game sessions, deposit/withdrawal history, bonus usage | Ongoing platform use |
| Technical Data | IP address, device type, browser version, operating system, session duration | Automatically on each visit |
| Communication Data | Support chat transcripts, email correspondence, complaint records | When you contact ber939 support |
| Marketing Preferences | Opt-in/opt-out status for promotional emails and SMS | Registration & updated in account settings |
ber939 does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, or health data unless directly relevant to a responsible gaming intervention and with your explicit consent.
Every piece of data that ber939 collects has a specific, documented purpose. We do not use your data for any purpose beyond what is described in this policy. The main purposes for which ber939 processes your personal data are:
- Account management: Creating, maintaining, and securing your ber939 account. This includes login authentication, session management, password recovery, and profile updates.
- Identity verification (KYC): Verifying your identity and age before processing withdrawals. This is a legal requirement under our gaming licence and anti-money-laundering obligations. ber939 uses CNIC verification and document checks for this purpose.
- Payment processing: Processing deposits and withdrawals through your chosen PKR payment method — Easypaisa, JazzCash, NayaPay, SadaPay, IBFT bank transfers, or Visa/Mastercard. Financial data is handled by our licensed payment processors and never stored on ber939's own servers in full form.
- Service delivery: Providing access to casino games, live dealer tables, sports betting markets, and all other features of the ber939 platform. This includes personalising your lobby view and remembering your preferences.
- Responsible gaming: Monitoring account activity for patterns consistent with problem gambling behaviour. If ber939's system flags unusual patterns, we may apply protective restrictions or contact you — these interventions are carried out in your interest and with your wellbeing as the only motivation.
- Fraud prevention & security: Detecting and preventing fraudulent activity, multiple accounts, bonus abuse, and other prohibited conduct. Technical data including IP addresses and device fingerprints is used for this purpose.
- Legal compliance: Meeting our obligations under our gaming licence, anti-money-laundering (AML) regulations, and applicable data protection law. This may include retaining transaction records for specified periods and reporting suspicious transactions to regulatory authorities.
- Marketing communications: Sending you emails or SMS about promotions, bonus offers, and platform news — but only if you have opted in. You can change your marketing preferences in your account settings at any time.
- Platform improvement: Analysing aggregated, anonymised usage data to identify how the platform is being used and where improvements can be made. This analysis does not individually identify users.
ber939 processes your personal data only where a valid legal basis exists. Depending on the purpose, the legal basis is one or more of the following:
- Contract performance: Processing that is necessary to provide the services you signed up for — running your account, processing bets, and handling payments. Without this processing, ber939 cannot provide its services.
- Legal obligation: Processing required to comply with our gaming licence, AML regulations, KYC requirements, and tax reporting obligations. This processing is mandatory and cannot be opted out of.
- Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and platform analytics. ber939 has assessed that these interests do not override your privacy rights in these specific contexts.
- Consent: Processing for marketing communications is based on your consent. You can withdraw consent at any time by updating your preferences in account settings or contacting support.
ber939 does not sell your personal data to any third party. We share personal data only with trusted partners who are contractually bound to process it only for the purpose for which it was shared and to maintain appropriate security standards. The categories of third parties with whom ber939 may share your data are:
- Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, and banking partners involved in processing your PKR deposits and withdrawals. These providers receive only the data needed to process your transaction and operate under their own privacy policies and regulatory obligations.
- Identity verification providers: KYC service providers who assist with CNIC verification, document authentication, and liveness detection. These providers process your identity documents under strict data handling agreements with ber939.
- Game content providers: Slot and live casino game providers whose software runs within the ber939 platform. These providers may receive anonymised session data to facilitate gameplay and resolve technical issues, but do not receive your full personal profile.
- Fraud prevention services: Third-party tools that help ber939 detect multiple accounts, suspicious payment patterns, and automated bot activity. These services process technical data such as IP addresses, device fingerprints, and behavioural signals.
- Cloud and infrastructure providers: Hosting, database, and content delivery services that power the ber939 platform. These providers act as data processors under ber939's instructions and are contractually prohibited from using data for their own purposes.
- Regulatory authorities: Gaming regulators, financial intelligence units, and law enforcement agencies may receive your data if ber939 is legally required to report a transaction or comply with an investigation. ber939 will notify you of such disclosures where legally permitted to do so.
ber939 carries out due diligence on all data processors and suppliers before sharing any member data with them. Contracts include data protection clauses, security requirements, and breach notification obligations.
Financial transactions at ber939 are processed in Pakistani Rupees (PKR) through regulated payment partners. The handling of your payment data is subject to the highest security standards we apply across the entire platform.
How ber939 handles payment data: Full payment account details — such as your complete Easypaisa mobile wallet number or full bank account number — are not stored on ber939's own servers after a transaction is completed. Payment processing is handled by our regulated payment partners who are PCI-DSS compliant or hold equivalent certifications for mobile money operators. ber939 stores only the minimum reference data needed to process future transactions with the same method (for example, a partial account reference), never the full sensitive payment details.
Transaction records: ber939 retains records of all financial transactions (amounts, dates, payment methods used, reference numbers) for the period required by our gaming licence and AML obligations. These records may be needed in the event of a dispute or regulatory enquiry.
- All data transmitted between your device and ber939.bet is encrypted using TLS (Transport Layer Security) — the same standard used by banks for online transactions.
- ber939 staff cannot view your full payment account details. Support agents can see a masked version (e.g., Easypaisa wallet ending in XXXX) for verification purposes only.
- Withdrawal requests are matched against your verified payment methods to prevent fraudulent withdrawal attempts by unauthorised parties.
ber939 uses cookies and similar technologies to make the platform work properly, remember your preferences, keep your session secure, and — with your consent — understand how the platform is being used so we can improve it. Here is a breakdown of the cookies ber939 uses.
| Cookie Type | Purpose | Can Be Disabled? |
|---|---|---|
| Session management, login authentication, CSRF protection, language/currency preferences. Without these, ber939 cannot function. | No — required for the platform to work | |
| Aggregated, anonymised data on page views, session duration, feature usage. Helps ber939 understand how players use the platform and identify areas for improvement. | Yes — via cookie preferences | |
| Tracking whether you arrived at ber939 via a specific campaign or affiliate link. Used to measure the effectiveness of promotional activity. No personal data is shared with advertisers. | Yes — via cookie preferences |
You can manage your cookie preferences at any time via the cookie settings panel accessible from the footer of ber939.bet. Disabling analytics and marketing cookies will not affect your ability to use any part of the platform — these cookies are genuinely optional.
ber939 does not use third-party advertising cookies that track your activity across other websites. Our marketing tracking is limited to measuring the source of traffic to ber939.bet itself.
ber939 retains your personal data only for as long as is necessary for the purpose it was collected and for the periods required by applicable law and regulation. The retention periods below reflect both operational necessity and legal obligations.
- Active account data: Retained for the duration of your account's active status, plus a post-closure period of 5 years in line with standard AML and gaming licence record-keeping requirements.
- KYC documents (CNIC scans, selfies): Retained for 5 years from the date of verification or account closure, whichever is later. This is required by anti-money-laundering regulations.
- Financial transaction records: Retained for 5–7 years depending on the applicable regulatory framework. These records may be required for auditing, dispute resolution, or regulatory enquiry.
- Support communications: Live chat transcripts and email correspondence are retained for 3 years after the conversation is closed, in case of follow-up disputes or regulatory review.
- Technical/log data: IP address logs and device session data are retained for 12 months for fraud prevention and security purposes, then deleted or anonymised.
- Marketing preference records: Opt-in and opt-out records are retained indefinitely as evidence of consent, even after you stop receiving marketing communications.
After the applicable retention period, ber939 securely deletes or anonymises your data such that it can no longer be associated with you as an individual. Anonymised, aggregated data (for example, platform usage statistics) may be retained indefinitely as it no longer constitutes personal data.
As a ber939 member, you have specific rights regarding your personal data. These rights are real and exercisable — they are not formalities. To exercise any of these rights, contact ber939 at privacy@ber939.bet with the subject "Data Rights Request" and your registered email address. ber939 will respond within 30 days.
Right of Access
Request a copy of all personal data ber939 holds about you. We will provide it in a clear, structured format within 30 days of your request.
Right of Rectification
If any personal data ber939 holds about you is inaccurate or outdated, you have the right to request a correction at any time.
Right to Erasure
Request deletion of your personal data. This right is subject to retention obligations — legally required records cannot be deleted early, but all other data can be.
Right to Restriction
Ask ber939 to temporarily stop processing your data while you contest its accuracy or the legal basis for processing it.
Right to Portability
Receive your personal data in a machine-readable format so you can transfer it to another service — applicable to data you provided and that was processed by automated means.
Right to Object
Object to ber939 processing your data for marketing or on the basis of legitimate interests. ber939 will stop unless it can demonstrate compelling legitimate grounds.
ber939 is not designed for, targeted at, or accessible to persons under the age of 18. We do not knowingly collect personal data from minors. If ber939 identifies that personal data has been collected from a person under 18, that data will be immediately deleted and the account will be permanently closed.
ber939 uses CNIC verification and other age-assurance measures to prevent underage registration. If you are a parent or guardian and believe your child has registered at ber939, please contact us immediately at privacy@ber939.bet with details so we can investigate and act promptly.
We also encourage parents and guardians to use device-level content filtering and parental controls to prevent minors from accessing gambling websites, including ber939.bet.
ber939 operates internationally and some of the third-party processors we work with — game providers, cloud infrastructure providers, fraud detection services — may process data outside Pakistan. Where this occurs, ber939 ensures that appropriate safeguards are in place to protect your data to the same standard that applies within Pakistan.
These safeguards typically include contractual clauses that bind our suppliers to data protection standards equivalent to those required under our licensing jurisdiction. ber939 conducts data transfer impact assessments for transfers to suppliers in jurisdictions without equivalent data protection frameworks.
Your financial data is processed by Easypaisa, JazzCash, and our other PKR payment partners, which are Pakistani entities subject to Pakistani financial regulation. The payment data element of your ber939 experience is processed locally within Pakistan.
ber939 may update this Privacy Policy from time to time to reflect changes in our data practices, changes in the services we offer, or changes in applicable law. When material changes are made, ber939 will notify registered members via email to the address on file and via an in-platform notification.
The "Effective" date at the top of this policy reflects when the current version came into force. Older versions of the policy are archived and available on request by emailing privacy@ber939.bet.
Continued use of ber939 following notification of an updated Privacy Policy constitutes acceptance of the revised terms. If you have concerns about a specific change, please contact our Data Protection team before that version takes effect.
If you have any questions about this Privacy Policy, want to exercise any of your data rights, or have a concern about how ber939 has handled your personal data, please contact us through one of the following channels:
- Data Protection queries: privacy@ber939.bet — please use the subject line "Privacy Query" or "Data Rights Request" as appropriate.
- General support: support@ber939.bet or 24/7 live chat from any ber939 page when logged in.
ber939 will acknowledge any data-related enquiry within 48 hours and provide a substantive response within 30 days. For complex requests — such as full data access requests involving large volumes of historical transaction data — ber939 may take up to 60 days and will notify you if this is the case.
If you are not satisfied with our response, you have the right to escalate your complaint to the relevant data protection supervisory authority in the jurisdiction under which ber939 holds its gaming licence. ber939 will provide the details of the appropriate authority in our response to any complaint that we are unable to resolve to your satisfaction internally.