Privacy Policy

This Privacy Policy ("Policy") describes how 939gam ("we", "us", "our", "the Platform") collects, processes, stores and protects personal data provided by or automatically generated by users ("you", "User", "Player") of the 939gam website and mobile interface, accessible at https://939gam.cam (the "Services").

939gam operates an online betting and live casino platform oriented towards adult players, with a particular focus on users based in Pakistan. Our platform is offered exclusively in English. All data processing described in this Policy is conducted in accordance with our obligations under applicable data protection legislation in the operator's licence jurisdiction.

By registering an account, accessing the Services or submitting personal information to 939gam, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. If you do not accept this Policy, you must cease using the Services.

The following terms carry the meanings defined below throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, CNIC number, IP address and financial details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, alteration, retrieval, consultation, erasure or destruction.
• "Data Controller" means 939gam, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of 939gam under a contractual arrangement (e.g., payment processors, KYC verification providers).
• "Cookies" means small text files placed on your device by the Platform that store session and preference information.
• "KYC" (Know Your Customer) means identity, age and address verification procedures required under applicable Anti-Money Laundering (AML) regulations.
• "Special Category Data" means sensitive categories of personal data, such as health information relevant to responsible gambling assessments, processed only where explicitly permitted under applicable law.

939gam collects Personal Data across the following categories:

939gam collects Personal Data through the following methods:

• Direct Submission: Information you enter during account registration, KYC verification, deposit/withdrawal requests, support queries or promotional opt-ins.
• Automated Collection: Technical and usage data collected automatically as you navigate the platform, via server logs, cookies and similar tracking technologies (see Section 8).
• Third-Party Sources: Identity and fraud-screening data received from KYC verification providers, credit reference agencies and fraud-prevention databases, where you have authorised such checks during account registration.
• Payment Processors: Transaction confirmation and payment method data received from payment processing partners when you make a deposit or request a withdrawal. Easypaisa, JazzCash, Raast, bank transfer providers and other payment rails named in our cashier are referenced as familiar payment methods; their inclusion does not imply affiliation with or endorsement of 939gam.

Where applicable data protection law requires a legal basis for processing Personal Data, 939gam relies on one or more of the following:

• Performance of a Contract: Processing necessary to register your account, process bets and handle deposits and withdrawals under the Terms & Conditions you have agreed to.
• Legal Obligation: Processing required to comply with KYC, AML, age verification and financial crime prevention obligations under applicable law.
• Legitimate Interests: Processing for fraud detection, platform security, responsible gambling monitoring and analytical purposes, where these interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications or non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

939gam uses Personal Data for the following purposes:

• Creating, verifying and maintaining your account.
• Processing deposits and withdrawals in PKR and other accepted currencies.
• Verifying your identity and age to comply with KYC and AML regulatory requirements.
• Detecting, investigating and preventing fraud, money laundering, and other prohibited conduct as described in our Terms & Conditions.
• Monitoring betting and gaming activity to identify and respond to responsible gambling concerns, including applying self-imposed limits and self-exclusion requests.
• Providing customer support in English and Urdu, including resolving disputes and complaints.
• Sending transactional communications (account confirmations, withdrawal notifications, security alerts) and, where you have consented, promotional communications about offers and events.
• Analysing platform usage to improve the user experience, fix technical issues and develop new features.
• Maintaining legally required records and responding to regulatory or law-enforcement requests.

939gam does not sell, rent or trade your Personal Data to third parties for marketing purposes. We may share your data in the following limited circumstances:

• KYC / Identity Verification Providers: Third-party providers engaged to carry out identity, age and document verification checks. These providers act as Data Processors under contractual data processing agreements.
• Payment Processors: Financial institutions and payment intermediaries required to process your transactions. Data shared is limited to what is necessary to execute the transaction.
• Game and Technology Providers: Platform technology partners that deliver game content, sports data feeds and platform infrastructure. Shared data is limited to session identifiers and game-play data necessary for service delivery.
• Fraud and Risk Screening Services: Industry fraud-prevention networks and risk databases used to identify suspicious activity patterns and protect all users on the platform.
• Legal and Regulatory Authorities: Competent authorities, regulators or law enforcement agencies where disclosure is required by law, court order or regulatory instruction. 939gam will notify you of such disclosures where legally permitted to do so.
• Professional Advisers: Legal counsel, auditors and compliance consultants, bound by professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition or sale of assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections.

939gam uses cookies and similar tracking technologies to operate the platform, maintain your session and analyse usage patterns. The following cookie categories are in use:

• Strictly Necessary Cookies: Required for the platform to function. These include session cookies that maintain your logged-in state, security tokens and load-balancing identifiers. These cannot be disabled without breaking core platform functionality.
• Performance & Analytics Cookies: Collect anonymised information about how users navigate the platform — pages visited, features used, error occurrences and session duration. Used to identify and fix issues and improve the overall experience.
• Functional Cookies: Store your preferences such as display settings, last-visited markets and language preferences (English).
• Marketing Cookies: Used only where you have given explicit consent to receive tailored promotional communications. You may withdraw this consent at any time via your account settings.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing the core Services, but may affect personalisation features. Note that strictly necessary cookies cannot be disabled via browser controls without disrupting your ability to use the platform.

939gam retains Personal Data for as long as necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods:

• Account and Transaction Data: Retained for a minimum of five years from the date of account closure or the last transaction, as required by applicable AML and financial record-keeping regulations.
• KYC and Verification Documents: Retained for the duration of your account and for a minimum of five years after account closure, in accordance with anti-money laundering obligations.
• Support Communications: Retained for up to three years from the date of the communication, or longer where subject to an ongoing dispute or regulatory inquiry.
• Technical and Usage Data: Retained for up to 24 months for analytical and security purposes, after which it is anonymised or deleted.
• Marketing Consent Records: Retained until consent is withdrawn or for three years from the last marketing interaction, whichever is earlier.

At the expiry of applicable retention periods, Personal Data is securely deleted or irreversibly anonymised. Anonymised data (which can no longer identify you) may be retained indefinitely for statistical and analytical purposes.

939gam implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction or alteration:

• Transport Layer Security (TLS) encryption for all data in transit between your device and our servers.
• Encryption of stored Personal Data and financial records using AES-256 or equivalent industry-standard encryption.
• Role-based access controls ensuring staff can only access Personal Data on a strict need-to-know basis.
• Regular internal security reviews and vulnerability assessments.
• Incident response procedures to contain, investigate and notify users of data breaches in accordance with applicable law.

Notwithstanding these measures, no internet-based system is completely secure. While we take all reasonable precautions, we cannot guarantee the absolute security of data transmitted over the internet. You are responsible for maintaining the confidentiality of your account credentials and for using a secure, up-to-date browser and device when accessing the Services.

939gam and its Data Processors may store or process your Personal Data in jurisdictions outside the country from which you access the Services. Where such transfers occur, 939gam ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required in the operator's licence jurisdiction.

Safeguards for international transfers may include standard contractual clauses, data processing agreements or transfer to jurisdictions recognised as providing an adequate level of data protection by relevant regulatory authorities.

For users in Pakistan, please be aware that your data may be processed outside Pakistan. By using the Services, you acknowledge and accept this transfer in accordance with the terms of this Policy.

Subject to applicable data protection legislation, you have the following rights in respect of your Personal Data held by 939gam:

To exercise any of the above rights, submit a written request to [email protected] (plain text — do not include sensitive document attachments in email). We will acknowledge receipt and respond within the applicable legal timeframe. We may need to verify your identity before processing a rights request.

The Services are strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's licence jurisdiction. 939gam does not knowingly collect Personal Data from persons under the minimum eligible age.

If we become aware that Personal Data has been collected from a person below the minimum age, that data will be deleted and the associated account closed immediately. If you believe a minor has registered an account on 939gam, please contact us at [email protected] without delay.

The 939gam platform does not contain links to third-party websites other than those necessary for payment processing or identity verification within the account portal. This Policy does not govern the privacy practices of any third-party service. Where third-party services are accessed as part of the payment or verification flow, you should review the privacy policy of that provider before submitting data to them.

939gam reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law or platform operations. Where changes are material, we will provide reasonable advance notice via an on-screen notification or email to your registered address.

Your continued use of the Services after the effective date of any revised Policy constitutes your acceptance of the updated terms. We recommend reviewing this page periodically. The "Last Updated" date at the top of the page indicates when the most recent revision was made.

If you have any questions, concerns or complaints about how 939gam processes your Personal Data, or if you wish to exercise any of your data rights, please contact us:

If you are not satisfied with our response to your data-related complaint, you may have the right to lodge a complaint with the supervisory authority in the operator's licence jurisdiction. Details of the relevant authority will be provided upon request.

For questions about your account, betting or support outside of data privacy, visit our FAQ page or review our Terms & Conditions.