bat39 Privacy Policy – How We Handle Your Data

1. Who We Are

bat39 is an online gaming and sports betting platform operating at bat39.pro, providing services to players in Pakistan. bat39 offers Slots, Sports Betting, Fish Games, Bingo, Live Casino and related services, all operated in PKR for Pakistani players.

When you register a bat39 account, make a deposit, place a bet or use any feature of the platform, bat39 acts as the data controller for the personal information you provide. This Privacy Policy explains how that data is handled.

By creating an account on bat39, you acknowledge that you have read this Privacy Policy and that you consent to the collection and use of your personal data as described here. If you do not agree, please do not register an account.

2. Data We Collect

bat39 collects personal data at different stages of your interaction with the platform. The categories of data collected are as follows:

bat39 does not intentionally collect sensitive personal data beyond what is required for identity verification and payment processing. We do not collect biometric data, religious information or political views.

3. How We Use Your Data

The personal data bat39 collects is used for the following purposes:

• Account management: To create, verify and maintain your bat39 player account, including processing login authentication and account security checks.
• Payment processing: To process deposits and withdrawals through your registered payment methods — JazzCash, Easypaisa, Raast, Bank Transfer and cards — and to maintain accurate transaction records for your account.
• Identity verification: To verify your age (18+) and identity when required, particularly for withdrawal processing or where unusual account activity is detected.
• Platform operations: To operate and deliver bat39 services including Slots, Sports Betting, Fish Games, Bingo and Live Casino, and to maintain accurate records of game results and bet settlements.
• Bonus and promotion management: To determine eligibility for bonuses, track wagering progress and prevent bonus abuse across the platform.
• Security and fraud prevention: To detect and prevent fraudulent activity, multiple account registrations, money laundering and other prohibited conduct as outlined in the bat39 Terms and Conditions.
• Responsible gaming: To apply the deposit limits, session reminders and self-exclusion settings that you configure in your account dashboard.
• Customer support: To respond to your queries, investigate complaints and resolve disputes in connection with your bat39 account.
• Platform improvement: To analyse aggregated, anonymised usage data that helps bat39 improve the platform experience — for example, understanding which game categories are most popular or where players experience technical issues.
• Legal compliance: To comply with applicable legal obligations, including record-keeping requirements and responding to lawful requests from relevant authorities.

bat39 does not use your personal data for targeted advertising, profiling for third-party commercial purposes or selling your information to marketing companies.

4. Payment Data and Financial Information

When you make a deposit or request a withdrawal on bat39, payment processing is handled in conjunction with verified payment service providers. These include JazzCash, Easypaisa, Raast, banks and card processing networks as applicable.

bat39 stores the minimum payment information necessary to process transactions and maintain your account records — typically your registered payment account identifiers (such as a JazzCash or Easypaisa number or bank account details) and a record of each transaction. bat39 does not store full debit or credit card numbers on its own servers — card transaction data is passed directly to the payment processor using secure transmission.

You must only use payment accounts that are registered in your own name when depositing or withdrawing on bat39. Third-party payments are not permitted. If bat39 identifies a deposit or withdrawal attempt involving a payment account that does not match your registered identity, the transaction may be declined and your account may be reviewed.

5. Sharing Your Data

bat39 does not sell or trade your personal data. Your information may be shared only in the following limited circumstances:

• Payment processors: When you make a deposit or withdrawal, relevant payment data is shared with the applicable payment service provider (such as JazzCash, Easypaisa or your bank) solely for the purpose of completing the transaction.
• Identity verification providers: Where bat39 uses a third-party identity verification service to confirm your age or identity, the minimum required data is shared with that provider for this purpose only.
• Technology and hosting providers: bat39 uses third-party technology infrastructure providers to host the platform and deliver its services. These providers operate under contractual obligations that restrict them from using bat39 player data for any purpose other than providing the contracted service.
• Legal obligations: bat39 may disclose personal data if required to do so by applicable law or in response to a lawful request from a relevant authority. bat39 will not disclose more information than is required to satisfy such a request.
• Business transfers: In the event of a merger, acquisition or sale of bat39's business, player data may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such change that affects how their data is handled.

In all cases where data is shared with a third party, bat39 takes reasonable steps to ensure that the third party maintains appropriate security standards for the data they handle.

6. Cookies and Tracking Technologies

bat39 uses cookies and similar tracking technologies to operate the platform, maintain your session and improve your experience. The types of cookies used include:

• Essential cookies: Required for the platform to function — these handle login sessions, security tokens and core navigation. The platform cannot operate properly without these and they cannot be disabled.
• Functional cookies: These remember your preferences such as language settings and game lobby view preferences, so you do not have to reconfigure them each time you visit.
• Analytics cookies: bat39 uses aggregated, anonymised analytics to understand how the platform is being used — for example, which sections receive the most visits or where players encounter loading issues. This data is used only to improve the platform and is not linked back to individual player identities for commercial purposes.

Most browsers allow you to manage or block cookies through their settings. Please note that disabling essential cookies will affect your ability to log in and use the bat39 platform normally. Blocking functional or analytics cookies will not prevent you from using the platform but may affect some preferences.

7. Data Retention

bat39 retains your personal data for as long as your account is active and for a reasonable period after account closure to meet any legal, compliance or dispute resolution obligations. The general retention periods are as follows:

• Active account data: Retained for the duration your bat39 account remains open.
• Transaction records: Financial transaction records are retained for a minimum period following the transaction date to satisfy record-keeping obligations.
• Identity verification records: Retained for a defined period following account closure or the date of verification, as required to comply with applicable obligations.
• Support communications: Retained for a reasonable period following resolution of the relevant query or complaint.
• Closed accounts: When an account is closed voluntarily, bat39 will delete or anonymise personal data that is no longer required, subject to any retention obligations that require it to be kept.

If you request deletion of your account and associated data, bat39 will action this request and confirm when it has been completed, subject to any data that must be retained under applicable legal obligations.

8. Your Rights Over Your Data

As a bat39 account holder, you have the following rights regarding your personal data:

• Right of access: You can request a copy of the personal data bat39 holds about you. bat39 will provide this within a reasonable timeframe following identity verification.
• Right to correction: If the personal data bat39 holds about you is inaccurate or incomplete, you can request that it be corrected. For basic account details such as phone number, you can update these directly in your account settings.
• Right to deletion: You can request that bat39 delete your personal data and close your account. bat39 will action this where there are no ongoing legal or compliance obligations requiring the data to be retained.
• Right to object: You can object to the use of your data for analytics or non-essential purposes. Essential uses such as payment processing, security and legal compliance cannot be opted out of while your account remains open.
• Right to withdraw consent: Where bat39 relies on your consent to process certain data (for example, for optional communications), you can withdraw that consent at any time by updating your account preferences or contacting support.

To exercise any of these rights, contact bat39 support at [email protected]. Please use your registered contact details when making a data request so that bat39 can verify your identity before actioning the request.

9. Children's Privacy

bat39 is strictly for adults aged 18 and above. bat39 does not knowingly collect personal data from anyone under 18 years of age. If bat39 discovers that a player account belongs to an individual under 18, the account will be closed immediately and the associated data will be deleted in accordance with this policy and any applicable obligations.

If you believe a person under 18 has registered a bat39 account, please contact support at [email protected] immediately so that the matter can be reviewed and acted upon.

Parents and guardians concerned about a young person's access to online gaming platforms are encouraged to use device-level parental controls and internet filtering tools available on most smartphones and home routers.

10. Security

bat39 applies technical and organisational security measures to protect the personal data it holds against unauthorised access, accidental loss, alteration or disclosure. These measures include encrypted data storage, access controls restricting who can view account-level data and secure transmission protocols for all platform communications.

While bat39 takes reasonable precautions, no online platform can guarantee absolute security. You also play a role in keeping your account secure:

• Use a strong, unique password for your bat39 account and do not reuse it on other platforms.
• Do not share your bat39 login credentials with anyone, including friends or family members.
• Log out of your bat39 account when using a shared or public device.
• Contact bat39 support immediately at [email protected] if you suspect unauthorised access to your account.

bat39 will never ask for your password via email, SMS or any support channel. If you receive a communication claiming to be from bat39 that asks for your password, treat it as suspicious and report it to support.

11. Changes to This Privacy Policy

bat39 may update this Privacy Policy from time to time to reflect changes in the platform, services or applicable requirements. When changes are made, the updated policy will be published on this page with a revised effective date.

For changes that are material — meaning they significantly affect how your personal data is collected, used or shared — bat39 may notify registered players via their registered contact details. For minor updates such as clarifications or formatting changes, the update will be published on this page without a separate notification.

Your continued use of bat39 after a Privacy Policy update constitutes acceptance of the revised policy. If you do not agree with a revised policy, you may request account closure by contacting support.

12. Contact Us

If you have any questions about this Privacy Policy, how bat39 handles your personal data, or if you would like to exercise any of your data rights, please get in touch with the bat39 support team:

For information about Responsible Gaming tools including deposit limits and self-exclusion, please visit the Responsible Gaming page or access the tools directly from your account dashboard.