Legal Document · ber939

ber939 Privacy Policy

This Privacy Policy explains how ber939 collects, uses, stores, and protects the personal information of players registered on the ber939 Platform. Your privacy matters to us — this document sets out your rights and our obligations in plain, readable language alongside the necessary legal detail.

Effective: 1 January 2026 Last Updated: 1 January 2026 Version 2.4 GDPR-Aligned
Our Commitments

Six Privacy Principles ber939 Lives By

Before you read the full legal document below, here are the six core commitments that underpin every data practice at ber939. These are not aspirations — they are enforced operational standards.

Transparency
ber939 tells you exactly what personal data we collect, why we collect it, how long we keep it, and with whom we share it. There are no hidden data practices. This Privacy Policy is the complete picture — nothing is omitted or obscured in fine print.
Purpose Limitation
Data collected for one purpose — for example, processing your JazzCash deposit — is not repurposed for unrelated activities without your explicit consent. ber939 does not use your transactional data for advertising profiling or sell it to third-party data brokers under any circumstances.
Data Minimisation
ber939 collects only the personal data genuinely necessary to provide our services, comply with regulatory obligations, and protect our Players. We do not collect data simply because it is convenient or potentially valuable in the future.
Security First
All personal data held by ber939 is protected by 256-bit SSL/TLS encryption in transit and AES-256 encryption at rest. Access to personal data is restricted on a strict need-to-know basis. ber939 conducts regular security audits and penetration testing on all data infrastructure.
Player Control
You retain meaningful rights over your personal data at all times. You can access, correct, export, or request deletion of your data by contacting ber939 Support. Requests are processed within the timeframes set out in Section 9 of this Policy.
Retention Limits
ber939 does not retain personal data beyond the period necessary for the purpose for which it was collected, or beyond the minimum period mandated by applicable regulatory requirements. Specific retention periods for each data category are documented in Section 8 of this Policy.
Contents
Effective 1 January 2026 Version 2.4 Applies Globally to ber939 Players
Section 01

Who We Are and How to Contact Us

ber939 ("ber939", "we", "us", "our") is the operator of the online gaming and sports betting platform accessible at ber939.one (the "Platform"). ber939 is the data controller responsible for the personal data of players registered on and using the Platform.

This Privacy Policy applies to all personal data collected, processed, and stored by ber939 in connection with the provision of its online casino, sports betting, and related services to players in Pakistan and internationally. It applies to data collected through the Platform, via email correspondence, through live chat support interactions, and through any other communication channel operated by ber939.

For all privacy-related enquiries, including requests to exercise your data rights as set out in Section 9 of this Policy, please contact ber939's Data Protection team. Contact details are provided in Section 15. ber939 is committed to responding to all data-related requests within the timeframes set out in applicable data protection law.

Plain Language Summary: ber939 is the company responsible for looking after your personal data when you use our Platform. This Privacy Policy explains what we do with your data and what rights you have. If you have questions about your data, Section 15 tells you how to contact us.
Section 02

Personal Data We Collect

ber939 collects the following categories of personal data from players:

Data Category Specific Data Points When Collected
Identity Data Full legal name, date of birth, CNIC number, nationality, gender During registration and KYC verification
Contact Data Pakistani mobile number, email address, city of residence During account registration
Financial Data JazzCash/EasyPaisa account number, bank account details (where applicable), deposit and withdrawal history, transaction amounts in PKR When making deposits or requesting withdrawals
Gaming Activity Data Bets placed, games played, session duration, win/loss records, bonus usage history During active gaming sessions
Technical Data IP address, device type and model, operating system, browser type, connection type, geolocation (city-level) During any Platform access
Communication Data Live chat transcripts, email correspondence, support ticket content When contacting ber939 Support
Document Data CNIC scan/photo, selfie photograph (for identity match), proof of address documents During KYC verification process
Note on Sensitive Data: ber939 does not intentionally collect sensitive personal data categories such as biometric data, health information, religious beliefs, or political opinions. If you voluntarily disclose such information in a support interaction, it will not be stored beyond the resolution of that specific interaction unless there is a legitimate reason to do so.
Section 03

How We Collect Your Data

ber939 collects personal data through the following channels and methods:

  • Direct submission: Data you provide when registering your ber939 Account, completing KYC verification, making deposits, requesting withdrawals, or contacting Support.
  • Automated collection: Technical and device data collected automatically through cookies, log files, and similar technologies when you access the Platform. See Section 10 for full cookie details.
  • Payment processors: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, SadaPay, and USDT TRC20 processors when you initiate a deposit or withdrawal.
  • Identity verification providers: Verification results received from third-party KYC service providers when you submit identity documentation.
  • Fraud detection systems: Risk signals and device fingerprinting data from ber939's fraud and AML monitoring systems, which operate continuously in the background during Platform use.
Section 04

Legal Basis for Processing Your Data

ber939 processes your personal data only where a valid legal basis exists. The relevant legal bases applicable to ber939's data processing activities are:

  • Contractual necessity: Processing required to deliver the services you have contracted for by registering a ber939 Account — including account management, game delivery, deposit processing, and withdrawal handling.
  • Legal obligation: Processing required to comply with anti-money laundering (AML) regulations, Know Your Customer (KYC) obligations, tax reporting requirements, and obligations under ber939's gaming licence conditions.
  • Legitimate interests: Processing necessary for ber939's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, platform security, responsible gambling monitoring, and analytics to improve platform performance.
  • Consent: Processing based on your freely given, specific, and informed consent — primarily in the context of optional marketing communications and non-essential cookie usage. You may withdraw consent at any time.
Section 05

How ber939 Uses Your Personal Data

ber939 uses the personal data it collects for the following specific purposes:

  • Account creation and management: Creating and maintaining your ber939 Account, verifying your identity, managing your login credentials and security settings, and communicating account-related notifications.
  • Service delivery: Processing your deposits and withdrawals in PKR via your chosen payment method, delivering casino games and live betting services, settling bets and winnings, and managing your account balance.
  • Regulatory compliance: Conducting KYC checks, fulfilling AML monitoring obligations, reporting suspicious transactions to relevant authorities where legally required, and maintaining records in accordance with gaming licence conditions.
  • Security and fraud prevention: Detecting and preventing account fraud, bonus abuse, money laundering, underage gambling, and unauthorised account access. Enforcing ber939's one-account-per-player policy.
  • Responsible gambling: Monitoring gaming patterns to identify potential problem gambling indicators, enforcing player-set deposit and loss limits, and facilitating self-exclusion where requested.
  • Customer support: Responding to your enquiries, resolving disputes, processing formal complaints, and maintaining records of support interactions.
  • Platform improvement: Analysing anonymised and aggregated usage data to improve platform performance, game selection, and user experience features.
  • Marketing (consent-based): Where you have provided consent, sending promotional offers, bonus notifications, and news about ber939 Platform updates via your registered mobile number or email address.
Section 06

Sharing Your Personal Data

ber939 does not sell, rent, or commercially distribute your personal data to any third party. ber939 shares personal data only in the following limited and specific circumstances:

Recipient Category Purpose of Sharing Data Shared
Payment Processors Processing PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan, Allied Bank, SadaPay, USDT TRC20 Name, account reference, transaction amount
KYC Providers Identity and age verification for regulatory compliance Name, DOB, CNIC data, document images
Game Providers Delivering casino, live casino, and instant game content Anonymous player token (no personal data)
Fraud & AML Services Fraud detection, risk scoring, AML monitoring Technical data, transaction patterns
Regulatory Authorities Compliance with gaming licence and AML legal obligations As required by applicable law and licence conditions
Law Enforcement Response to valid legal process (court order, regulatory demand) As required by the specific legal instrument received
RG Support Services Responsible gambling support referrals (player-initiated only) Minimal data sufficient to facilitate referral
No Sale of Data: ber939 categorically does not sell player data to advertisers, data brokers, or any commercial third party. This applies to identifiable personal data and to pseudonymised or aggregated data derived from player activity on the Platform.
Section 07

International Data Transfers

ber939 operates on an internationally distributed infrastructure, which means that personal data collected from players in Pakistan may be processed and stored on servers located in countries other than Pakistan. Such countries may have data protection laws that differ from those applicable in Pakistan.

Where ber939 transfers personal data outside Pakistan to service providers or infrastructure providers, ber939 ensures that such transfers are protected by one or more of the following safeguards:

  • Standard contractual clauses that contractually bind the recipient to data protection obligations equivalent to those applicable to ber939;
  • Transfer to countries that have been assessed as providing an adequate level of data protection by relevant regulatory authorities;
  • Binding corporate rules where the transfer is to an entity within ber939's corporate group;
  • Specific consent obtained from the data subject where other transfer mechanisms are not available.

You may request further information about the specific safeguards in place for international transfers of your data by contacting ber939 via the contact details in Section 15.

Section 08

Data Retention Periods

ber939 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law or regulatory obligation. The following retention periods apply:

Data Category Retention Period Basis
Account & Identity Data Duration of account + 5 years post-closure Gaming licence and AML regulatory requirement
Financial Transaction Records Duration of account + 7 years post-closure AML legislation and tax reporting obligations
KYC Documents (CNIC, Selfie) Duration of account + 5 years post-closure Gaming licence KYC obligation
Gaming Activity Logs Duration of account + 3 years post-closure Dispute resolution and licence compliance
Support Communication Records 3 years from date of interaction Dispute resolution and quality assurance
Marketing Consent Records Until consent withdrawn + 1 year Consent verification
Technical / Log Data 13 months from date of generation Security monitoring and fraud detection

Where ber939 is required to retain data beyond the standard retention period due to an ongoing legal dispute, regulatory investigation, or law enforcement request, data will be retained until the relevant matter is fully resolved, following which standard deletion procedures will apply.

Section 09

Your Privacy Rights

Subject to applicable data protection law and any overriding legal obligations (such as AML retention requirements), you have the following rights in respect of your personal data held by ber939:

  • Right of Access: Request a copy of the personal data ber939 holds about you. ber939 will provide this within 30 days of receipt of a valid request.
  • Right to Rectification: Request correction of inaccurate or incomplete personal data. Corrections to identity data may require re-submission of KYC documentation.
  • Right to Erasure: Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and where no overriding legal obligation to retain it exists.
  • Right to Restriction: Request that ber939 restrict processing of your data in certain circumstances — for example, where you contest the accuracy of data and ber939 is in the process of verifying it.
  • Right to Data Portability: Request that ber939 provide you with a copy of certain personal data in a structured, commonly used, machine-readable format.
  • Right to Object: Object to processing of your data for legitimate interests or for direct marketing purposes. Where you object to direct marketing, processing for that purpose will cease immediately.
  • Right to Withdraw Consent: Where processing is based on your consent, withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Important Limitation: The right to erasure and restriction may be limited where ber939 has a legal obligation to retain data — for example, AML transaction records must be retained for the period specified in Section 8 regardless of an erasure request. ber939 will inform you of any such limitation when responding to your request.

To exercise any of the above rights, contact ber939's Data Protection team using the details in Section 15. Please provide sufficient information to verify your identity and describe your request clearly. ber939 may require a copy of your CNIC to verify identity before actioning a data rights request.

Section 10

Cookies and Tracking Technologies

ber939 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file placed on your device by the Platform when you access it. Cookies are used for the purposes described below. The full ber939 Cookie Policy is incorporated into this Privacy Policy.

ber939 uses the following categories of cookies:

Cookie Details

ber939 Cookie Categories

Strictly Necessary Cookies
Required

These cookies are essential for the ber939 Platform to function correctly. They manage your login session, maintain your account authentication state, handle security tokens, and ensure that your shopping cart and game session data persist as you navigate. These cookies cannot be disabled without breaking core Platform functionality. No consent is required for strictly necessary cookies as they are integral to service delivery.

Performance & Analytics Cookies
Optional

These cookies collect anonymised data about how players use the ber939 Platform — which pages are visited most frequently, where players encounter errors, how long sessions last, and which games generate the most engagement. This data is processed in aggregate and is used exclusively to improve Platform performance and user experience. No individual player is identifiable from this data. You may opt out of these cookies without affecting your ability to use the Platform.

Functionality Cookies
Optional

These cookies remember your preferences and customisation choices — such as your preferred game view, language settings, notification preferences, and whether you have dismissed particular information banners. Disabling these cookies means ber939 will not be able to remember your preferences between sessions, requiring you to re-configure them on each visit.

Security & Fraud Detection Cookies
Required

These cookies support ber939's fraud prevention, AML monitoring, and account security systems. They assist in identifying suspicious access patterns, detecting multiple accounts operated from the same device, and assessing the risk level of individual login attempts. These cookies are an integral part of ber939's regulatory compliance obligations and cannot be disabled while using the Platform.

Marketing & Promotional Cookies
Optional

With your consent, ber939 may use cookies to serve you relevant promotional content — including details of bonuses, game launches, and PSL cricket betting promotions — within the Platform. These cookies do not track your activity across third-party websites and are used only to personalise the promotional content you see within ber939's own Platform. You may withdraw consent for these cookies at any time through your Account settings or by contacting Support.

Cookie Management: You can manage cookie preferences through your ber939 Account settings or through your browser's built-in cookie management tools. Note that disabling certain categories of cookies (particularly security cookies) may impair your ability to use some features of the Platform. Blocking all cookies may prevent you from logging in to ber939 entirely.
Player Rights

Your Data Rights — At a Glance

A visual summary of the seven data rights every ber939 player holds under this Privacy Policy. Full legal descriptions are in Section 9 of the Policy above.

Access
Request a full copy of all personal data ber939 holds on your account — delivered within 30 days.
Rectification
Correct any inaccurate or outdated personal data on your ber939 account at any time.
Erasure
Request deletion of personal data where legal retention obligations no longer apply.
Restriction
Ask ber939 to pause processing of your data in specific circumstances while a query is resolved.
Portability
Receive a copy of your data in a structured, machine-readable format to transfer elsewhere.
Object
Object to processing based on legitimate interests, including direct marketing — takes effect immediately.
Withdraw Consent
Withdraw any previously given consent to data processing at any time, without penalty.
Complain
Lodge a complaint with the relevant supervisory authority if you believe your rights have been violated.
Section 11

Children and Minors

The ber939 Platform is strictly for adults aged 21 years and above. ber939 does not knowingly collect, process, or retain personal data of individuals under 21 years of age. If you are under 21, you must not attempt to register an account or access any ber939 services.

ber939 employs active age verification technology as part of its account registration and KYC processes specifically to prevent access by minors. Where ber939 identifies or receives credible information indicating that personal data has been collected from an individual under 21, ber939 will immediately close the relevant account, delete the associated personal data to the extent permitted by law, and take appropriate reporting steps.

21+ Policy: If you are a parent or guardian and believe your child has registered a ber939 account, contact ber939 Support immediately via live chat or by emailing [email protected]. We will investigate and take action within one business day.
Section 12

Security Measures

ber939 implements industry-leading technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

  • 256-bit SSL/TLS encryption for all data transmitted between your device and ber939's servers;
  • AES-256 encryption for personal and financial data stored on ber939's database infrastructure;
  • Strict role-based access controls limiting employee access to personal data on a need-to-know basis;
  • Multi-factor authentication required for all internal staff access to systems holding player personal data;
  • Regular independent security audits, penetration testing, and vulnerability assessments of all Platform infrastructure;
  • Continuous monitoring of network traffic for anomalies and potential intrusion attempts;
  • A documented Data Breach Response Plan, including mandatory notification procedures in the event of a breach affecting player data.

While ber939 takes every reasonable precaution, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. You can protect your own ber939 account data by using a strong, unique password and enabling two-factor authentication.

Section 13

Third-Party Links and Services

The ber939 Platform may contain references to third-party game providers and payment services. When you interact with third-party services — for example, when initiating a JazzCash deposit — you will be subject to that third party's own privacy policy and data practices, not this ber939 Privacy Policy.

ber939 is not responsible for the privacy practices of third-party services accessible through or in connection with the Platform. ber939 recommends that you review the privacy policies of all third-party services you interact with in connection with your ber939 account, particularly your chosen payment provider.

Section 14

Changes to This Privacy Policy

ber939 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, ber939 will notify registered players by:

  • Sending a notification to your registered email address or mobile number at least 14 days before the changes take effect;
  • Displaying a prominent notice on the ber939 Platform when you next log in;
  • Updating the "Last Updated" date and version number at the top of this page.

Your continued use of the ber939 Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of those changes. Where changes involve new processing activities requiring your consent, ber939 will seek that consent separately before commencing such processing.

Section 15

Contact Information

For all privacy-related queries, data rights requests, or concerns about ber939's data practices, please contact us through the following channels:

  • Live Chat: Available 24/7 directly on the ber939 Platform. Select "Privacy / Data Request" from the Support menu for prioritised routing to the Data Protection team.
  • Email: [email protected] — use the subject line "Privacy Policy Enquiry" or "Data Rights Request" for fastest handling. Responses within 5 business days for standard queries; 30 days for formal data rights requests.
Data Rights Requests: When submitting a data rights request (access, erasure, portability, etc.), please include your full name, registered mobile number or email address, and a brief description of your request. ber939 may require identity verification before processing your request. All requests are logged and acknowledged within 3 business days.

ber939 is committed to resolving all privacy-related concerns directly and promptly. If you remain unsatisfied after engaging with ber939's Data Protection team, you retain the right to escalate your complaint to the relevant supervisory authority under applicable data protection law.

Your Data. Your Rights. Our Commitment.

ber939 is built on trust. Your personal data is protected by industry-leading security standards. Log in and experience Pakistan's most secure online gaming platform.

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21+ only. ber939 operates under an international gaming licence. Data protected under this Privacy Policy. Please gamble responsibly — visit our Responsible Gaming page for support tools.