be939 Privacy
Policy

be939 is Pakistan's premier online casino and sports betting platform, accessible at https://be939.club. The be939 platform is operated by its authorised operator ("be939", "we", "us", "our") under a licence issued by an international gaming authority. For data protection purposes, be939 acts as the data controller in respect of all personal data collected from registered players and platform visitors.

As the data controller, be939 determines the purposes for which your personal data is collected and the means by which it is processed. Where be939 engages third-party service providers to process personal data on its behalf, those providers act as data processors and are bound by strict contractual obligations that prohibit them from using your data for any purpose other than the specific service they provide to be939.

If you have any questions about be939's role as a data controller, or about any aspect of how your personal data is handled, please contact the be939 Data Protection team at [email protected].

be939 collects personal data from you through several channels: directly when you register an account or interact with the platform, automatically through technical systems as you use the platform, and from third parties such as payment providers and identity verification services where this is necessary for compliance purposes.

The categories of personal data that be939 may collect include:

be939 does not collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, or health data) except where the processing of such data is strictly necessary for responsible gaming purposes — for example, where a player voluntarily discloses a gambling-related health concern when requesting self-exclusion.

be939 uses the personal data it collects for the following purposes:

• Account Registration & Management: To create and maintain your be939 player account, verify your identity, and provide you with access to all platform features including casino games, cricket betting, slots, and live dealer games.
• KYC & Age Verification: To verify that you are at least 21 years of age as required under our licensing obligations, and to fulfil all applicable Know Your Customer (KYC) compliance requirements before processing any withdrawal request.
• Payment Processing: To process deposits made via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Raast, and to process withdrawal requests to your verified payment accounts in Pakistani Rupees (PKR).
• Customer Support: To respond to your enquiries, complaints, and support requests via live chat and email, and to maintain records of those communications for quality assurance and compliance purposes.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, and other prohibited conduct on the be939 platform in accordance with our compliance obligations.
• Responsible Gaming: To monitor player behaviour for signs of problem gambling, to administer self-exclusion requests and deposit limit settings, and to send responsible gaming communications where our systems identify patterns of concern.
• Promotions & Bonuses: To administer welcome bonuses, reload bonuses, and other promotional offers, and to verify eligibility for specific promotions where required.
• Platform Improvement: To analyse aggregated usage data and technical performance data in order to improve the be939 platform experience for all Pakistani players.
• Legal & Regulatory Compliance: To comply with applicable laws, regulatory requirements, licensing authority requests, and lawful orders from governmental or law enforcement authorities.

be939 processes your personal data only where there is a valid legal basis for doing so. The primary legal bases on which be939 relies are as follows:

• Contractual Necessity: Much of the data processing described in this Policy is necessary for be939 to perform its contractual obligations to you under the be939 Terms & Conditions — including operating your account, processing payments, and delivering gaming services. Without this processing, be939 cannot provide its services to you.
• Legal Obligation: be939 is required by its international gaming licence and by applicable anti-money laundering and counter-terrorist financing regulations to collect and verify identity data, retain transaction records, and report suspicious activity. This processing is mandatory regardless of your consent.
• Legitimate Interests: be939 processes certain technical and usage data on the basis of its legitimate interests in fraud prevention, platform security, and service improvement. Where this basis applies, be939 has conducted a balancing test to confirm that its legitimate interests are not overridden by your privacy rights.
• Consent: Where be939 wishes to send you direct marketing communications about promotions, bonuses, or new game launches, it will do so only with your prior consent, which you may withdraw at any time by updating your communication preferences in your account settings or by contacting customer support.

The be939 platform uses cookies and similar tracking technologies to ensure the platform operates correctly, to remember your preferences, and to help be939 understand how players use the platform so we can continue to improve it.

The types of cookies used by be939 are as follows:

• Essential Cookies: These are strictly necessary for the be939 platform to function. They enable core features such as your login session, account balance display, and game loading. These cookies cannot be disabled without disrupting your ability to use the platform.
• Functional Cookies: These cookies remember your preferences — such as your preferred language and currency display — so that you do not need to re-enter them on each visit. They improve your experience but are not strictly necessary.
• Analytics Cookies: be939 uses first-party analytics tools to collect aggregated information about how players navigate and interact with the platform. This data is used in anonymised or pseudonymised form and helps be939 identify areas for improvement.
• Security Cookies: These cookies help be939 detect unusual account access patterns and potential fraud, including repeated failed login attempts and suspicious session behaviour.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies will prevent you from logging into and using the be939 platform. be939 does not use third-party advertising cookies or behavioural targeting cookies.

be939 shares your personal data with third parties only in the following strictly defined circumstances:

• Payment Service Providers: be939 shares necessary financial and identity data with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Raast for the sole purpose of processing your deposits and withdrawals in PKR. These providers are bound by their own data protection and financial regulations.
• Identity Verification Services: be939 may use third-party KYC and age verification service providers to verify the identity documents you submit. These providers process your identity data solely for the purpose of completing the verification check on behalf of be939.
• Game Software Providers: The casino games, live dealer games, and slot titles available on the be939 platform are provided by licensed third-party software companies. Minimal technical data (such as session tokens) may be shared with these providers to facilitate game play. Game providers do not receive your identity or financial data.
• Regulatory & Law Enforcement Authorities: be939 may be required to disclose your personal data to licensing authorities, financial intelligence units, or law enforcement agencies where required by law or by a lawful order. be939 will comply with such requests to the extent required by applicable law.
• Legal Advisers: In the context of a legal dispute, claim, or regulatory investigation involving your account, be939 may share relevant personal data with its legal counsel on a strictly confidential basis.

As an internationally licensed online gaming platform serving Pakistani players, be939's data processing infrastructure may involve the transfer of personal data to countries outside Pakistan. This may occur where be939's server infrastructure, payment processing partners, or KYC verification providers are based in other jurisdictions.

Wherever personal data is transferred internationally by be939, appropriate safeguards are in place to ensure that your data receives a level of protection equivalent to that provided within Pakistan. These safeguards may include:

• Contractual clauses requiring the recipient to protect your data to an equivalent standard.
• Transfers to jurisdictions that maintain data protection frameworks recognised as providing adequate protection.
• Technical security measures including encryption of data in transit and at rest.

You may request further information about the specific safeguards applicable to any international transfer of your personal data by contacting be939 at [email protected].

be939 retains your personal data for as long as your be939 account is active, and for a defined period after account closure as required by law and our licensing obligations. The general retention periods applicable to the main data categories are as follows:

• Account & Identity Data: Retained for a minimum of 5 years after account closure, as required under anti-money laundering regulations applicable to licensed gaming operators.
• Transaction & Financial Data: Retained for a minimum of 5 years after the date of the transaction, in line with financial record-keeping requirements.
• KYC Documentation: Retained for the duration of the account relationship and for 5 years after account closure.
• Customer Support Communications: Retained for 3 years after the date of the last communication in a given support thread, for quality assurance and dispute resolution purposes.
• Technical & Usage Data: Retained in identifiable form for up to 24 months, after which it is anonymised or deleted.
• Responsible Gaming Data: Self-exclusion records are retained for the duration of the exclusion period and for 5 years thereafter, to ensure compliance with re-registration restrictions.

When personal data is no longer required for any lawful purpose, be939 will securely delete or anonymise it in a manner that prevents recovery or reconstruction.

As a be939 player, you have the following rights in relation to your personal data. To exercise any of these rights, please contact the be939 Data Protection team by email at [email protected] with the subject line "Data Rights Request — [Your Username]".

• Right of Access: You may request a copy of all personal data that be939 holds about you. be939 will provide this in a structured, commonly used format within 30 days of receiving a valid request.
• Right to Rectification: If any personal data be939 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. Where the data relates to your account registration details, you should update these directly in your account settings where possible.
• Right to Erasure: You may request that be939 delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to be939's legal retention obligations — be939 cannot delete data that it is required by law to retain.
• Right to Restriction: You may request that be939 restrict the processing of your data in certain circumstances, for example while a dispute about the accuracy of your data is being resolved.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, you may request that be939 provide your personal data in a machine-readable format suitable for transfer to another service provider.
• Right to Object: You may object to be939's processing of your data where that processing is based on legitimate interests. be939 will cease the relevant processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent — for example, for marketing communications — you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

be939 will respond to all valid data rights requests within 30 calendar days. In complex cases this period may be extended by a further 30 days, in which case be939 will notify you of the extension and the reason for it within the initial 30-day period.

The be939 platform is strictly restricted to individuals who are 21 years of age or older. be939 does not knowingly collect personal data from any person under the age of 21. The be939 registration process includes age verification steps designed to prevent underage individuals from creating accounts.

If you are a parent or guardian and you have reason to believe that a minor in your care has registered on the be939 platform, please contact be939 customer support immediately via live chat or at [email protected] so that the account can be investigated and closed without delay.

be939 takes the security of your personal data seriously and implements a comprehensive set of technical and organisational security measures to protect your data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the be939 platform is encrypted using TLS 1.3. Sensitive data stored at rest — including identity documents and financial account details — is encrypted using AES-256.
• Access Controls: Access to personal data within be939's systems is strictly role-based. Only employees and contractors who have a genuine operational need to access a specific category of data are granted that access. All access is logged and audited regularly.
• Two-Factor Authentication: be939 strongly recommends that all players enable two-factor authentication (2FA) on their accounts to provide an additional layer of protection against unauthorised access. 2FA is available via the account security settings panel.
• Penetration Testing: be939's platform security is subject to regular independent penetration testing and vulnerability assessments to identify and remediate potential security weaknesses before they can be exploited.
• Incident Response: In the event of a data security incident that poses a risk to your personal data, be939 has a formal incident response procedure in place. Affected players will be notified promptly in accordance with applicable breach notification requirements.

While be939 takes all reasonable and proportionate steps to protect your personal data, no online platform can guarantee absolute security against all possible threats. You also have a responsibility to protect your be939 account by choosing a strong and unique password, enabling 2FA, and not sharing your login credentials with any third party.

be939's responsible gaming programme relies on the careful and sensitive processing of player data. Understanding how this data is used is important for all Pakistani players on our platform.

be939's systems automatically monitor player activity — including deposit frequency, session length, betting patterns, and the use of responsible gaming tools — for indicators of potential problem gambling behaviour. Where our systems flag a concern, a member of the be939 responsible gaming team may proactively reach out to you. This is done in your interests and is a condition of our international gaming licence.

Responsible gaming data — including self-exclusion status, deposit limits, cooling-off periods, and any self-assessment responses you provide — is treated with the highest level of sensitivity and is accessible only to the limited number of be939 staff who require it to administer responsible gaming tools and comply with our licensing obligations.

If you self-exclude from be939, your self-exclusion status is retained even after the exclusion period expires. This data is used to verify your identity and exclusion history if you attempt to re-register in the future, and to ensure the exclusion period is fully honoured.

be939 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or changes required by our licensing authority. The effective date at the top of this Policy will always reflect the date of the most recent update.

Where changes to this Privacy Policy are material — meaning they significantly affect how be939 uses your personal data or the rights available to you — be939 will provide advance notice by email to your registered address and via a prominent notice on the be939 platform before the revised Policy takes effect.

Your continued use of the be939 platform after the effective date of a revised Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree with any changes to this Privacy Policy, you should discontinue your use of the platform and may close your account by contacting be939 customer support.

The current version of this Privacy Policy is always available at https://be939.club/privacy-policy and supersedes all previous versions.

If you have any questions, concerns, or complaints about this Privacy Policy or about how be939 handles your personal data, please contact the be939 Data Protection team through one of the following channels:

• Live Chat: Available 24/7 directly within the be939 platform. Average response time is 3–5 minutes. For data protection queries, please clearly state "Data Protection Enquiry" at the start of your message so your chat is directed to the appropriate team member.
• Email: [email protected] — please use the subject line "Privacy Policy Query — [Your Username]" for data protection matters. Average email response time is 4–8 hours.

be939 is committed to resolving all data protection queries and complaints fairly and promptly. If you submit a formal data protection complaint and you are not satisfied with be939's response, you may have the right to escalate your complaint to the data protection supervisory authority or regulatory body in your jurisdiction, or to the relevant body designated by be939's licensing authority.

For formal written complaints regarding data protection matters, please email [email protected] with the subject line "Formal Data Protection Complaint — [Your Username]". be939's compliance team will acknowledge receipt within 5 business days and aim to provide a substantive response within 30 calendar days.