Privacy Policy
be939 Online Betting Platform

This Privacy Policy (hereinafter "Policy" or "Privacy Policy") is issued by the operator of the be939 online betting and live casino platform, accessible at be939.cam (hereinafter "be939", "we", "us" or "our"). It describes the types of personal data we collect from users of the Platform, the purposes for which that data is processed, the basis on which processing takes place, and the rights available to data subjects.

be939 is an English-language online betting and live casino platform serving Pakistani users. All interface content is presented in English and all amounts are displayed in Pakistani Rupees (PKR). This Policy applies to all Users of be939.cam regardless of the device or network used to access the Platform.

This Privacy Policy forms part of the overall agreement between you and be939 and should be read alongside the Terms & Conditions and the Responsible Gambling Policy.

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person ("Data Subject"), including but not limited to name, email address, telephone number, CNIC number, IP address, device identifier, location data, account transaction history and any other information that could be used to identify you directly or indirectly.
• "Processing" — any operation or set of operations performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transmission, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data, which in this context is the operator of be939.cam.
• "Data Processor" — any third party engaged by be939 to process Personal Data on its behalf under contractual obligations consistent with this Policy.
• "User" / "Data Subject" — any natural person who accesses, registers on or interacts with the Platform.
• "Platform" — the be939 online service accessible at be939.cam, including all games, betting markets, account areas and support functions.
• "KYC" — Know Your Customer identity verification procedures, including collection of government-issued identity documents such as a CNIC or passport.
• "Cookies" — small text files placed on your device by the Platform to facilitate session management, analytics and user-experience improvements.

3.1  Data Provided Directly by You. The following categories of Personal Data are collected when you register, complete KYC, make transactions or contact support:

3.2  Data Collected Automatically. When you access the Platform, certain technical data is collected automatically by our systems and third-party tools:

• IP address and approximate geographic location;
• Device type, operating system and browser version;
• Session timestamps, pages visited and betting activity;
• Referring URL and navigation behaviour within the Platform;
• Cookie identifiers and similar tracking technologies (see Section 7).

3.3  Data from Third Parties. We may receive data about you from third-party identity verification services, fraud-detection providers, payment processors and, where applicable, responsible gambling support databases. Such data is processed only for the stated purposes in Section 5.

4.1  be939 processes Personal Data on one or more of the following legal bases depending on the activity involved:

• Contractual Necessity: Processing is necessary to perform the contract between you and be939 — including account management, bet settlement, transaction processing and support services.
• Legal Obligation: Processing is necessary to comply with applicable anti-money laundering (AML), fraud prevention and KYC legal requirements.
• Consent: Where you have provided explicit consent for specific processing activities — such as receiving promotional communications — your data will be processed on that basis. You may withdraw consent at any time by contacting support.
• Legitimate Interests: Processing is necessary for legitimate interests pursued by be939 — including platform security, fraud prevention, analytics-driven improvement and responsible gambling programme management — provided those interests do not override your fundamental rights.

5.1  be939 uses Personal Data for the following purposes:

• Account Management: Creating, maintaining and securing your Account, including authentication, session management and recovery processes.
• Identity Verification (KYC): Confirming your identity and age (18+ requirement) before permitting deposits, withdrawals or access to certain features. This may involve cross-referencing submitted documents with third-party verification services.
• Transaction Processing: Facilitating deposits and withdrawals in PKR, recording transaction histories and reconciling payment records with available payment method references.
• Fraud Prevention & AML: Detecting and preventing fraudulent account activity, money laundering, multiple account registrations and other forms of abuse. We may flag, investigate and report suspicious activity to relevant authorities where required by applicable law.
• Responsible Gambling: Monitoring betting patterns to identify potential problem gambling behaviour. Data may be used to apply responsible gambling tools, trigger intervention messages or enforce self-exclusion where appropriate.
• Platform Improvement: Analysing aggregate usage data to understand how users interact with the Platform, identify technical issues and improve the user experience for Pakistani players across devices and cities.
• Customer Support: Responding to enquiries, complaints and disputes submitted via live chat or email at [email protected].
• Marketing Communications (with consent): Sending promotional content regarding bonuses, tournaments and new features, where you have consented to receive such communications. You may opt out at any time.
• Legal & Regulatory Compliance: Meeting obligations imposed by applicable law, including record retention requirements and responses to lawful authority requests.

5.2  be939 does not use Personal Data for automated profiling that produces legally significant effects on individual Users without human review.

6.1  be939 does not sell your Personal Data to third parties for marketing purposes. Personal Data is shared only in the circumstances described below:

• Service Providers (Data Processors): Third-party companies engaged to provide KYC verification, payment processing, fraud detection, analytics, customer support infrastructure and IT hosting. These processors operate under data processing agreements and are contractually bound to process data only for the specified purposes.
• Payment Providers: When you make a deposit or request a withdrawal, relevant transaction data is transmitted to the relevant payment processor. Payment provider names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah appear as familiar local references only. None of these providers are endorsed by or have confirmed a partnership with be939. Availability and data-handling practices of each provider are governed by their own privacy policies.
• Regulatory Authorities and Law Enforcement: Where required by applicable law, court order or regulatory requirement, Personal Data may be disclosed to competent authorities. Such disclosures are made only to the extent required and are logged internally.
• Affiliated Entities: Where be939 operates as part of a larger group, data may be shared with affiliated entities for internal administrative purposes, subject to equivalent data protection standards.
• Business Transfers: In the event of a merger, acquisition or asset sale involving be939, Personal Data held by be939 may be transferred to the acquiring entity as part of the transaction, provided that equivalent protections are maintained.

6.2  be939 will endeavour to notify affected Users of any material change in data sharing arrangements where practicable and legally permissible.

7.1  be939 uses cookies and similar technologies to operate and improve the Platform. The following categories of cookies may be active on be939.cam:

7.2  Most web browsers allow you to manage cookies through browser settings. Disabling strictly necessary cookies may affect Platform functionality. Disabling analytics or functional cookies will not prevent you from using core services.

7.3  be939 does not use cookies to serve third-party advertising or share browsing data with ad networks.

8.1  be939 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, tax or accounting obligations.

8.2  The following general retention principles apply:

• Account Data: Retained for the duration of your account and for a minimum period thereafter as required by applicable AML and gaming regulations. Specific retention periods depend on the operator's licence jurisdiction requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five years following the transaction date in accordance with standard financial record-keeping requirements.
• KYC Documents: Identity verification documents are retained for the period required by applicable AML regulations in the operator's licence jurisdiction.
• Support Communications: Customer support records are retained for a period sufficient to resolve outstanding disputes, typically a minimum of two years from the last relevant interaction.
• Marketing Data: Contact information used for marketing purposes is retained until you withdraw consent or unsubscribe, after which it is removed from active marketing lists promptly.

8.3  Upon expiry of the relevant retention period, Personal Data is securely deleted or anonymised in accordance with applicable data destruction standards.

9.1  be939 implements technical and organisational security measures designed to protect Personal Data against unauthorised access, alteration, disclosure or destruction. These measures include, but are not limited to:

• Encryption of data in transit using TLS (Transport Layer Security) protocols;
• Encryption of sensitive data at rest within secure storage environments;
• Access controls limiting Personal Data access to authorised personnel on a need-to-know basis;
• Regular security assessments and vulnerability monitoring of Platform infrastructure;
• Two-factor authentication options for User Account access;
• Contractual data security obligations imposed on all third-party processors.

9.2  Whilst be939 takes reasonable steps to protect your data, no internet transmission or storage system is entirely secure. Users are responsible for maintaining the confidentiality of their own login credentials and must notify support immediately at [email protected] if they suspect unauthorised access to their Account.

10.1  Subject to applicable data protection law in the operator's licence jurisdiction, you may have the following rights in relation to your Personal Data. The availability of specific rights may depend on the legal basis for processing and applicable local law. To exercise any right, contact support at [email protected] with your request and sufficient identification to verify your identity.

11.1  be939 is designed for use by Pakistani players located in cities including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. This localisation reflects user-experience choices and does not imply that be939 is licensed, approved or endorsed by any Pakistani authority.

11.2  Pakistan does not currently have a comprehensive standalone data protection statute equivalent to the GDPR. The Personal Data Protection Bill (PDPB) has been under development; its current legislative status may have evolved since this Policy was drafted. be939 applies data handling standards consistent with those required in its primary operating jurisdiction, which provides equivalent or higher protections than those currently available under Pakistani law.

11.3  Your Personal Data may be transferred to and processed in jurisdictions outside Pakistan in connection with Platform operations, KYC processing, fraud-detection services or hosting infrastructure. Where such transfers occur, be939 takes steps to ensure that an adequate level of protection is applied to your data in accordance with the data protection standards of the operator's licence jurisdiction.

11.4  be939 is not regulated by the State Bank of Pakistan, PTA or any Pakistani provincial authority. Payment provider references — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — appear as familiar local context only. Each payment provider's own privacy policy governs how that provider handles data transmitted during payment transactions.

12.1  The Platform is strictly restricted to adults aged 18 years or older — or the higher minimum required by the operator's licence jurisdiction. be939 does not knowingly collect Personal Data from persons under the minimum age requirement.

12.2  If be939 becomes aware that Personal Data has been collected from a person under the applicable minimum age, that data will be deleted promptly and the account closed without delay.

12.3  If you believe that a person under the minimum age has registered on the Platform using your or another person's information, please contact support immediately at [email protected] (plain text — not a clickable link).

13.1  The Platform does not contain outbound links to third-party websites for commercial or advertising purposes. Where the cashier area references payment processor services, those services operate under their own terms and privacy policies. be939 is not responsible for the data practices of third-party payment processors or service providers once data exits the Platform through those channels.

13.2  Any third-party services embedded within the Platform — such as analytics tools or fraud-detection services — are bound by data processing agreements that restrict how they may use data shared with them. These providers do not receive more data than is necessary for the specific service they provide.

14.1  be939 reserves the right to update or amend this Privacy Policy at any time. Material changes will be notified to registered Users via email or in-platform notification where practicable. The revised Policy will be posted at be939.cam/privacy-policy with an updated effective date.

14.2  Your continued use of the Platform following the posting of an updated Policy constitutes your acceptance of the revised terms. If you do not agree with any amendment, you should cease use of the Platform and close your Account.

14.3  It is your responsibility to review this Policy periodically. be939 is not liable for any loss arising from your failure to review amendments in a timely manner.

15.1  If you have any questions, concerns or complaints regarding this Privacy Policy or the way in which be939 processes your Personal Data, please contact us through the following channels:

• Live Chat: Available within the Platform during operational hours.
• Email (plain text — not a clickable link): [email protected]

15.2  When submitting a data-related request or complaint, please include your registered username, a clear description of your request, and sufficient information to verify your identity. We aim to acknowledge all privacy-related correspondence promptly and will respond within the timeframe required by applicable law.

15.3  For matters related to responsible gambling, account limits or self-exclusion, please visit our Responsible Gambling page for dedicated guidance.