This Privacy Policy explains how 939gam ("the Company", "we", "us", "our") collects, processes, stores, uses, and protects personal data provided by or generated through the use of the 939gam platform at 939gam.net. We take the privacy and data security of every Pakistani player seriously, and this document sets out exactly what we do with your information and the rights you hold in relation to that data.
Six core principles that govern how 939gam handles every piece of personal data entrusted to us by Pakistani players.
All personal data held by 939gam is protected by 256-bit SSL encryption at rest and in transit. We do not store full payment card numbers on 939gam servers. Sensitive fields including CNIC scans are stored in encrypted, access-controlled environments with strict internal authorisation policies.
939gam collects only the personal data that is strictly necessary for the purposes described in this Privacy Policy. We do not collect personal data speculatively or for purposes beyond what is set out here. You will always be informed of why a particular piece of information is being requested.
939gam does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Data is only shared with carefully selected processors who assist in operating the 939gam platform, under binding data processing agreements.
You have the right to access, correct, and in certain circumstances request deletion of the personal data 939gam holds about you. These rights are not procedural formalities — 939gam maintains a dedicated process for handling data rights requests, described in full in Section 9 of this Policy.
939gam does not retain personal data indefinitely. Retention periods are defined for each data category based on operational necessity and regulatory requirements. When data is no longer needed, it is securely deleted or anonymised in accordance with our data retention schedule.
This Privacy Policy is written in plain English and is designed to be genuinely readable rather than deliberately obscure. If any part of this Policy is unclear, players in Pakistan are encouraged to contact our support team at [email protected] for clarification before using the platform.
For the purposes of this Privacy Policy, 939gam acts as the data controller in respect of personal data collected from Players who register accounts or use the Services available at 939gam.net. As data controller, 939gam is responsible for determining the purposes and means by which personal data is processed.
939gam operates under an international gaming licence and is subject to the data protection obligations associated with that regulatory framework. In cases where 939gam engages third-party service providers to process data on its behalf, those providers act as data processors and are bound by written data processing agreements that restrict their use of player data to the specific purposes for which it is shared.
All enquiries relating to data protection, privacy rights, or this Privacy Policy should be directed to the 939gam support team. Contact details are provided in Section 14 of this Policy.
939gam collects personal data in the following categories from Players who register accounts or use the 939gam platform:
| Category | Data Elements | Purpose |
|---|---|---|
| Identity Data | Full legal name, date of birth, CNIC number, CNIC document scan | Account registration; KYC/age verification; AML compliance |
| Contact Data | Pakistani mobile number, email address | Account communication; OTP delivery; security alerts |
| Financial Data | JazzCash/EasyPaisa wallet reference, bank account details (partial), Visa/Mastercard last-4 digits | Payment processing; deposit/withdrawal; fraud prevention |
| Transaction Data | Deposit history, withdrawal requests, bet history, game session data, PKR balances | Account management; dispute resolution; AML monitoring |
| Technical Data | IP address, device type, browser, OS, session timestamps, login history | Platform security; fraud detection; responsible gaming monitoring |
| Usage Data | Pages visited, games played, time spent, feature interactions | Platform improvement; personalisation; responsible gaming tools |
| Communications Data | Support chat transcripts, email correspondence, complaint records | Customer service; dispute resolution; quality assurance |
939gam collects personal data through the following channels:
939gam processes personal data on one or more of the following legal bases, depending on the category of data and the specific processing activity:
4.1 Contractual necessity: Processing that is necessary to perform the contract between 939gam and the Player — including account management, payment processing, bet settlement, and customer support.
4.2 Legal obligation: Processing required to comply with applicable legal and regulatory obligations, including anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements imposed by 939gam's gaming licence, and the retention of financial transaction records.
4.3 Legitimate interests: Processing necessary for 939gam's legitimate business interests where those interests are not overridden by the Player's privacy rights — including fraud prevention, platform security, responsible gaming monitoring, and analytics for platform improvement.
4.4 Consent: Where 939gam processes data for optional purposes such as marketing communications, this processing is based on your explicit consent, which may be withdrawn at any time by contacting 939gam support.
939gam uses the personal data it collects for the following purposes:
939gam does not sell, rent, or trade player personal data. Data is shared only in the following limited circumstances:
No commercial data sales. 939gam will never sell your personal data to advertisers, data brokers, or any commercial third party. This is an absolute commitment, not subject to any exception.
The 939gam website uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are used:
You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use the 939gam platform. Analytics and functional cookies can be disabled without preventing core platform access.
939gam retains personal data for the periods set out below, after which data is securely deleted or irreversibly anonymised:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account & Identity Data | Duration of account + 5 years post-closure | Regulatory / AML obligation |
| Financial Transaction Records | 5 years from transaction date | Gaming licence / financial regulation |
| KYC Documents | 5 years from account closure | AML / regulatory requirement |
| Support Communications | 3 years from interaction date | Dispute resolution / legitimate interest |
| Technical / Log Data | 12 months | Security / fraud prevention |
| Marketing Consent Records | Until consent is withdrawn + 1 year | Legal compliance |
Where retention is required beyond the periods listed above due to an ongoing legal dispute, regulatory investigation, or court order, 939gam will retain the relevant data until that matter is concluded.
Subject to applicable law and the conditions described below, 939gam Players have the following rights in relation to their personal data:
You may request a copy of the personal data 939gam holds about you. We will provide this within 30 days of a verified request.
You may request that inaccurate personal data held by 939gam be corrected or updated. Changes to KYC data require re-verification.
You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and no regulatory retention obligation applies.
You may request that 939gam restrict the processing of your data in certain circumstances, such as while the accuracy of data is being verified.
You may request a machine-readable copy of the personal data you have provided to 939gam, where technically feasible.
Where processing is based on your consent (e.g., marketing), you may withdraw that consent at any time by contacting 939gam support.
To exercise any of the rights listed above, please contact the 939gam support team at the email address provided in Section 14. We will acknowledge your request within five (5) business days and respond in full within thirty (30) business days. Requests will be processed following identity verification to protect against unauthorised data disclosures.
939gam implements technical and organisational security measures appropriate to the risk profile of the personal data it processes. Key security measures in place include:
Notwithstanding these measures, no online platform can guarantee absolute security against all possible threats. Players are encouraged to contribute to their own account security by using strong unique passwords and not sharing login credentials with any third party.
The 939gam platform is strictly restricted to individuals aged 21 years and above. 939gam does not knowingly collect personal data from persons under 21 years of age. CNIC-based age verification is applied to all accounts as part of the KYC process. If 939gam becomes aware that a Player account has been registered or used by a person under 21 years of age, the following actions will be taken immediately:
If you are a parent or guardian of a minor who you believe has registered an account on 939gam, please contact our support team immediately at the address provided in Section 14.
Data collected through 939gam's responsible gaming tools — including deposit limit settings, session time data, self-exclusion requests, and gaming behaviour monitoring — is treated with a heightened level of sensitivity and is used exclusively for the purpose of player protection. This data is not used for commercial profiling or marketing purposes. It is used solely to fulfil 939gam's responsible gaming obligations and to ensure that players who have indicated a wish to limit or stop their gambling activity are protected from receiving promotional communications that could undermine that decision.
Self-exclusion records are retained for the duration of the exclusion period and for a minimum of five (5) years thereafter, in compliance with responsible gaming obligations under 939gam's gaming licence. Further details on the responsible gaming tools available to 939gam players can be found on the Responsible Gaming page.
939gam reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or 939gam's data processing practices. When material changes are made to this Policy, 939gam will notify registered Players by displaying a notice on the platform or communicating the change to the Player's registered mobile number or email address. The updated Policy will display a revised effective date at the top of this document. Continued use of the 939gam platform following notification of an updated Privacy Policy constitutes acceptance of the revised terms.
For any questions, requests, or concerns relating to this Privacy Policy, or to exercise any of the data rights described in Section 9, please contact the 939gam Data Protection team. Our support email address is provided below as plain text — it is not a clickable link:
939gam Support & Data Enquiries: [email protected]
Please include "Privacy Request" in the subject line of your enquiry and provide your registered mobile number so we can verify your identity. We respond to all privacy-related enquiries within 24 hours and will provide a substantive response within 30 business days.
939gam is a strictly 21+ platform. Age is verified using CNIC documentation before any real-money access is granted. If you have questions about how your personal data is used in connection with responsible gaming monitoring or self-exclusion, please visit the Responsible Gaming page or contact our support team. Gambling is for entertainment purposes only. Play responsibly.
Your data is protected. Your PKR is secure. Live casino, PSL cricket betting, and 500+ slots — all on Pakistan's licensed gaming platform. 21+ only.