be939 Privacy Policy

Effective Date: 1 January 2026  ·  Version: 2026.1

1. Introduction

be939 ("be939", "the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of all individuals who access or use the be939 platform at be939.app ("you", "the User", "the Player"). This Privacy Policy explains what personal data be939 collects, why it is collected, how it is used, with whom it may be shared, and the rights you hold in relation to your data.

This Privacy Policy forms part of the be939 Terms & Conditions and should be read alongside them. By registering an account or using the be939 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

be939 processes personal data in accordance with applicable data protection principles, including those of purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality. We do not sell personal data to third parties for marketing purposes.

2. Personal Data We Collect

Depending on how you interact with be939, we may collect the following categories of personal data:

2.1 Registration and Identity Data

• Full legal name;
• Date of birth (for age verification);
• Pakistani mobile number (03xx format);
• Email address;
• Username and account password (stored in hashed form);
• Residential address (city, province).

2.2 Identity Verification (KYC) Data

• Government-issued photo identification (CNIC, passport, or driving licence);
• Proof of address documentation;
• Proof of payment method ownership (e.g., screenshot of JazzCash or Easypaisa account confirming registered name);
• Selfie or liveness verification image, where required.

2.3 Financial and Transaction Data

• Deposit and withdrawal amounts, timestamps, and payment method identifiers;
• Partial payment account numbers (e.g., last four digits of a card or mobile wallet number);
• Transaction history within the be939 platform;
• Bonus redemption and wagering activity records.

2.4 Gaming and Behavioural Data

• Game session records including game titles, bet amounts, outcomes, and session durations;
• Sports betting slip history;
• Responsible gaming tool usage (deposit limits set, cool-off periods activated, self-exclusion requests);
• Platform feature usage and navigation patterns.

2.5 Technical and Device Data

• IP address at time of login and transaction;
• Device type, operating system, and browser version;
• Geolocation data derived from IP address (country and city level only);
• Session tokens and authentication logs.

2.6 Communications Data

• Content of support chat conversations and ticket correspondence;
• Email correspondence with the be939 team;
• Records of promotional communications sent to and opened by the player.

3. How We Collect Your Data

be939 collects personal data through the following means:

• Directly from you during account registration, KYC submission, deposit and withdrawal requests, support interactions, and voluntary form submissions;
• Automatically through cookies, session tracking technologies, server logs, and platform analytics tools when you browse or interact with be939.app;
• From third-party service providers including payment processors (JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, Skrill, Neteller, and Visa/Mastercard), identity verification providers, and fraud detection services, in each case only to the extent necessary to verify your identity, process transactions, or comply with legal obligations.

4. Purposes of Processing

be939 processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your be939 account;
• Identity and age verification: Confirming you meet the 18+ age requirement and are who you say you are;
• Payment processing: Facilitating PKR deposits and withdrawals via supported payment methods;
• Fraud prevention and AML compliance: Detecting and preventing fraudulent activity, money laundering, and other financial crimes;
• Platform operation: Delivering gaming and betting services, resolving technical issues, and maintaining platform integrity;
• Responsible gaming: Monitoring gaming patterns that may indicate problem gambling behaviour and administering self-exclusion and limit tools;
• Customer support: Responding to your queries, complaints, and account-related requests;
• Legal compliance: Meeting obligations under applicable law, regulatory requirements, and court orders;
• Marketing communications: Where you have given consent, sending promotional offers, bonus notifications, and platform updates. You may withdraw consent at any time.

5. Legal Basis for Processing

be939 processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing is required to perform our agreement with you (the Terms & Conditions), including account creation, payment processing, and delivery of gaming services;
• Legal obligation: Processing is necessary to comply with anti-money laundering requirements, KYC regulations, and other applicable legal obligations;
• Legitimate interests: Processing serves the legitimate interests of be939 in fraud prevention, platform security, and improving our services, provided those interests are not overridden by your fundamental rights;
• Consent: For marketing communications and certain cookie categories, where your prior consent has been obtained and may be withdrawn at any time.

6. Data Sharing and Disclosure

be939 does not sell your personal data. We may share data with:

• Payment service providers (JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, Skrill, Neteller, Visa/Mastercard) for the purpose of processing your deposits and withdrawals;
• Identity verification and KYC providers for age and identity confirmation;
• Fraud prevention and anti-money laundering platforms for transaction risk screening;
• Game providers and platform technology partners to the extent required to deliver the gaming experience;
• Legal authorities and regulators where disclosure is required by law, court order, or regulatory demand;
• Professional advisers (lawyers, auditors, accountants) subject to confidentiality obligations.

All third parties with whom be939 shares data are required to process that data only for the specified purpose and in accordance with applicable data protection requirements.

7. International Data Transfers

7.1 The be939 platform operates internationally and your personal data may be processed in countries outside Pakistan. Where data is transferred to countries that do not have an equivalent level of data protection to that applicable in Pakistan, be939 will implement appropriate safeguards including standard contractual clauses or equivalent transfer mechanisms.

7.2 Payment data processed through JazzCash and Easypaisa is handled within Pakistani jurisdiction. Data processed through international payment providers (Skrill, Neteller, Visa/Mastercard) may be subject to those providers' own international transfer practices.

8. Data Retention

8.1 be939 retains personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and reporting obligations.

8.2 Account data is typically retained for a minimum of five years following account closure to meet anti-money laundering record-keeping requirements. Gaming and transaction records may be retained for a longer period where required by applicable law.

8.3 KYC documentation is retained for the duration of the account and for a minimum of five years following account closure.

8.4 Support correspondence is retained for up to three years following the resolution of the matter to which it relates.

8.5 Where data is no longer required for any legitimate purpose, be939 will securely delete or anonymise it.

9. Security Measures

9.1 be939 implements technical and organisational security measures proportionate to the risk associated with processing your personal data. These include:

• Encryption of data in transit using TLS;
• Hashing of account passwords using industry-standard algorithms;
• Two-factor authentication available to all account holders;
• Access controls limiting data access to authorised personnel on a need-to-know basis;
• Session management and automatic timeout for inactive sessions;
• Regular security assessments and monitoring of the platform infrastructure.

9.2 No security system is infallible. If you suspect that your be939 account has been compromised, contact support immediately via live chat or email.

10. Cookies and Tracking Technologies

10.1 be939 uses cookies and similar tracking technologies to operate the platform, maintain session state, detect fraud, and analyse user behaviour in aggregate for platform improvement purposes.

10.2 Categories of cookies used on be939 include:

• Strictly necessary cookies: Required for the platform to function. These cannot be disabled;
• Session cookies: Maintain your authenticated session during a visit and are deleted when you close your browser;
• Analytics cookies: Used in aggregate, anonymised form to understand how players navigate the platform. No individual-level tracking is sold to third parties;
• Preference cookies: Store your language and display preferences.

10.3 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair the functionality of the be939 platform.

11. Your Data Rights

Subject to applicable law, you may have the following rights in relation to your personal data held by be939:

• Right of access: Request a copy of the personal data be939 holds about you;
• Right of rectification: Request correction of inaccurate or incomplete data;
• Right of erasure: Request deletion of your data in certain circumstances, subject to legal retention obligations;
• Right to restrict processing: Request that processing of your data be restricted in certain circumstances;
• Right to data portability: Request your data in a structured, machine-readable format where technically feasible;
• Right to object: Object to processing based on legitimate interests or for direct marketing purposes;
• Right to withdraw consent: Withdraw consent for marketing communications at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, contact be939 support. be939 will respond within a reasonable period in accordance with applicable law. We may need to verify your identity before fulfilling a data request.

12. Minors

12.1 be939 does not knowingly collect personal data from individuals under the age of 18. The platform implements age verification controls during registration.

12.2 If you believe that a minor has provided personal data to be939, please contact support immediately. Upon confirmation, be939 will delete the data and close the associated account without delay.

13. Third-Party Services

13.1 The be939 platform integrates third-party services including game providers, payment processors, and analytics tools. Each of these providers operates under their own privacy policies. be939 is not responsible for the privacy practices of third-party services outside of the data sharing arrangements described in Section 6.

13.2 be939.app does not contain links to external websites for navigational purposes. Any references to third-party payment providers or game studios within this policy are informational only.

14. Amendments to This Policy

14.1 be939 may update this Privacy Policy from time to time. Material changes will be communicated to registered players via in-platform notification or email before the revised policy takes effect.

14.2 The effective date at the top of this document reflects the version currently in force. Continued use of be939 following notification of changes constitutes acceptance of the updated Privacy Policy.

15. Contact and Data Queries

For questions about this Privacy Policy, to exercise your data rights, or to raise a privacy concern, please contact the be939 team:

Email: [email protected]
Live Chat: Available on-site 24 hours a day, 7 days a week
Ticket System: For account-specific data requests requiring documentation

Email addresses displayed on this site are plain text references only and are not hyperlinked.