det939 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how det939 (hereinafter "det939", "we", "us", "our") collects, processes, stores, shares and protects personal data relating to individuals who access or use the det939 website at det939.cam, along with any associated applications, platforms and services (collectively, the "Services"). This Policy applies to registered account holders and to visitors who browse the platform without registering.

det939 is committed to handling your personal data responsibly, transparently and in accordance with applicable data protection standards. We collect only the data necessary to provide our Services, comply with legal and regulatory obligations, and continuously improve platform quality and security.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference into the overall agreement between you and det939.

2 Definitions

The following definitions apply throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, date of birth, payment details and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, deletion or any combination thereof.
• "Data Controller" means det939, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third-party service provider that processes Personal Data on behalf of det939 under a written data processing agreement.
• "KYC Data" means identity and age verification documents and information collected in connection with Know Your Customer obligations.
• "Cookies" means small text files placed on your device by the det939 platform for the purposes described in Section 7.
• "Services" means the full range of betting, casino, content and support services offered by det939 via det939.cam and associated platforms.
• "Special Category Data" means sensitive personal data including, where applicable, health data that may be collected in connection with responsible gambling assessments or self-exclusion requests.

3 Data We Collect

det939 collects Personal Data through several channels. The categories and examples of data collected are summarised below:

3.1 Registration Data

When you create an account, we collect: full legal name, date of birth, email address, residential address, contact number and preferred currency (PKR for eligible players in Pakistan). This data is essential for account creation, identity verification and transaction processing.

3.2 KYC and Verification Data

To comply with anti-money laundering (AML) obligations and to prevent underage gambling, we collect copies of government-issued photo identification (such as a Pakistani National Identity Card, passport or driving licence), proof of residential address (such as utility bills or bank statements) and proof of payment method ownership. All KYC documents are processed under strict confidentiality controls.

3.3 Financial and Transaction Data

We collect data related to deposits, withdrawals, balances and betting or gaming transactions. This includes payment method references (such as Easypaisa wallet IDs, JazzCash references, Raast IDs or conventional bank transaction references from institutions such as HBL, UBL, Meezan Bank and Bank Alfalah). The mention of these payment providers is for transactional context only and does not imply their endorsement of or affiliation with det939.

3.4 Usage and Behavioural Data

We automatically collect data about how you interact with the platform, including: pages visited, games played, bets placed, session duration, device type and operating system, browser type and version, IP address, and referring URLs. This data is used to improve platform performance, personalise the experience and detect fraudulent activity.

3.5 Responsible Gambling Data

Where you voluntarily use responsible gambling tools — such as deposit limits, loss limits, session reminders, cooling-off periods or self-exclusion requests — we record the details of those restrictions. Where applicable, this may constitute Special Category Data processed with your explicit consent and in the legitimate interest of player protection.

3.6 Communications Data

When you contact det939 support via email, live chat or any other channel, we retain records of those communications, including the content of your messages, timestamps and any resolution actions taken. This data is held for quality assurance, dispute resolution and regulatory audit purposes.

3.7 Summary Data Collection Table

4 How We Use Your Data

det939 uses collected Personal Data for the following purposes:

• Account Management: Creating, maintaining and securing your det939 account; processing logins and account updates;
• Service Delivery: Enabling access to sports betting markets, live dealer games, slots and all other platform features;
• Payment Processing: Facilitating deposits, processing withdrawal requests and reconciling transaction records;
• Identity and Age Verification: Conducting KYC checks to confirm your identity, age and payment method ownership in compliance with AML obligations;
• Fraud Prevention and Security: Monitoring activity for signs of fraud, unauthorised account access, bonus abuse, money laundering and other prohibited conduct;
• Responsible Gambling: Enforcing deposit limits, loss limits, self-exclusion records and other player protection tools activated by you or by det939 where risk factors are identified;
• Platform Improvement: Analysing usage patterns to optimise platform design, game selection, odds display and loading performance;
• Customer Support: Responding to queries, resolving disputes and maintaining records of support interactions;
• Legal and Regulatory Compliance: Meeting obligations under applicable licensing conditions, AML legislation and data protection regulations;
• Communications: Sending transactional notifications (account confirmations, withdrawal updates, security alerts) and, where you have provided consent, promotional communications about det939 offers and events.

5 Legal Basis for Processing

det939 processes your Personal Data on one or more of the following legal bases, depending on the nature of the processing activity:

• Contractual Necessity: Processing required to perform the contract between you and det939 — including account registration, payment processing and service delivery;
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including AML laws, KYC requirements and licensing conditions under the applicable operator licence jurisdiction;
• Legitimate Interests: Processing carried out to pursue det939's legitimate business interests where those interests are not overridden by your rights — including fraud detection, platform security, responsible gambling monitoring and business analytics;
• Consent: Processing based on your freely given, specific, informed and unambiguous consent — including marketing communications and, where applicable, the processing of Special Category Data related to responsible gambling assessments.

Where det939 relies on consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

det939 does not sell, rent or trade your Personal Data to any third party for their independent commercial purposes. We may share your Personal Data only in the following limited circumstances:

6.1 Service Providers

det939 engages trusted third-party service providers to support platform operations. These include payment processing partners, KYC and identity verification providers, cloud hosting and server infrastructure providers, customer support platform operators, fraud detection and analytics providers, and email communication services. All service providers are bound by written data processing agreements that restrict their use of your data to the specific services they perform on det939's behalf.

6.2 Regulatory and Legal Authorities

det939 may disclose Personal Data to competent regulatory authorities, law enforcement agencies, financial intelligence units or courts where required to do so by applicable law, court order, licensing obligation or in connection with the investigation of suspected financial crime, fraud or match-fixing. Where disclosure is made, det939 will disclose only the minimum data necessary to satisfy the legal requirement.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of assets involving det939, your Personal Data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and of any material change to this Privacy Policy that results from it.

6.4 Responsible Gambling Registers

Where required by applicable licensing conditions, det939 may submit self-exclusion records to multi-operator self-exclusion registers. This is done in your interest and only to the extent required by the licence jurisdiction's responsible gambling framework.

7 Cookies & Tracking Technologies

det939 uses cookies and similar tracking technologies (including pixel tags, web beacons and local storage objects) to operate the platform, remember your preferences, analyse usage patterns and support fraud detection. The principal categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies, security tokens and load-balancing cookies. They cannot be disabled without impairing platform functionality.
• Functional Cookies: Store your preferences such as language settings, display preferences and last-visited game categories to provide a more personalised experience on return visits.
• Analytics Cookies: Collect anonymised or aggregated data about how players navigate the platform — which pages are most visited, how long sessions last, and which features are most used. This data helps us improve the platform continuously.
• Security and Fraud Detection Cookies: Support our fraud prevention and account security systems by tracking device fingerprints and unusual access patterns.

You may control cookie settings through your browser's privacy or settings menu. Please note that disabling certain cookies may impair the functionality of the det939 platform, including the ability to maintain a logged-in session. det939 does not use third-party advertising or behavioural tracking cookies.

8 Data Retention

det939 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory or licensing obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of the account relationship and for a defined period after account closure as required by AML and licensing regulations (typically a minimum of 5 years from the date of the last transaction, though the specific period is governed by the applicable licence jurisdiction);
• KYC Documents: Retained for the period required under applicable AML regulations following account closure;
• Transaction Records: Retained in accordance with financial record-keeping requirements under the applicable licence jurisdiction's AML framework;
• Support Communications: Retained for a period of up to 3 years following the resolution of the relevant query or dispute;
• Marketing Consent Records: Retained for as long as you hold an active account or, if you have not registered, for a reasonable period following the withdrawal of consent;
• Self-Exclusion Records: Retained for the duration of the exclusion period and for a defined period thereafter to prevent re-registration.

Where data is no longer required for any lawful purpose, det939 will securely delete or anonymise it.

9 Data Security

det939 implements a layered set of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and det939's servers;
• AES-256 encryption at rest for sensitive personal and financial data stored on det939's infrastructure;
• Role-based access controls limiting staff access to Personal Data to those with a demonstrated operational need;
• Multi-factor authentication requirements for all administrative system access;
• Regular security assessments, vulnerability scans and penetration testing of platform infrastructure;
• Incident response procedures to detect, assess and notify affected parties of any personal data breach in accordance with applicable notification obligations.

10 International Data Transfers

det939 operates globally and may transfer your Personal Data to countries outside Pakistan and outside the jurisdiction in which the applicable operator licence is held, where service providers or infrastructure partners are located. Where such transfers occur, det939 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to or exceeding the protections described in this Policy.

Appropriate safeguards for international transfers may include:

• Standard contractual clauses or equivalent data transfer mechanisms incorporated into agreements with Data Processors;
• Transfer to jurisdictions that provide an equivalent level of data protection recognised by the applicable regulatory framework;
• Binding corporate rules where transfers occur within a corporate group.

If you require further information about the specific safeguards in place for international transfers of your data, please contact us at [email protected].

11 Your Rights

Subject to applicable data protection law and any overriding legal obligations (including AML record-keeping requirements), you hold the following rights in relation to your Personal Data held by det939:

• Right of Access: You may request a copy of the Personal Data det939 holds about you and information about how it is processed;
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data held about you;
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected and where no overriding legal obligation requires its retention;
• Right to Restriction: You may request that det939 restricts the processing of your data in certain circumstances, for example while the accuracy of data is disputed;
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request that det939 provide your Personal Data in a structured, commonly used and machine-readable format;
• Right to Object: You may object to processing carried out on the basis of legitimate interests or for direct marketing purposes;
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

12 Children & Minors

The det939 platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the applicable operator or licence jurisdiction. det939 does not knowingly collect Personal Data from any person under the applicable minimum age.

Where det939 identifies or has reasonable grounds to believe that Personal Data has been submitted by a person below the minimum age threshold, all associated data will be deleted without delay and the account will be closed immediately. Any funds held in such an account may be handled in accordance with applicable regulatory obligations.

If you are a parent or guardian and believe that a minor in your care has registered with det939 or submitted their Personal Data to the platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action without delay.

13 Third-Party Links

The det939 platform does not contain links to external third-party websites as a matter of policy. However, where contextual references to payment channels, sports leagues (such as Pakistan Super League/PSL, ICC T20 tournaments or other cricket competitions) or other services appear in platform content, such references are informational only. det939 is not responsible for the privacy practices of any third-party entity and this Policy applies only to data collected through det939's own platform and services.

If you navigate away from det939.cam to any external platform through your own browser activity, we encourage you to review the privacy policy of that platform independently.

14 Policy Amendments

det939 reserves the right to update or amend this Privacy Policy at any time. Where a proposed amendment materially affects your rights or the way in which your Personal Data is processed, det939 will use reasonable efforts to notify registered account holders via email or an in-platform notification before the revised Policy takes effect.

The "Last reviewed" date displayed at the top of this page reflects the date of the most recent revision. We encourage you to review this Policy periodically to remain informed about how det939 protects your data. Your continued use of the Services following publication of a revised Policy constitutes acceptance of the updated terms. If you do not agree to a material amendment, you should cease using the Services and contact det939 to arrange account closure.

15 Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the way det939 processes your Personal Data, please reach out to our support team. All data-related requests must be submitted in writing and will be handled with strict confidentiality.

det939 is committed to responding to all privacy-related queries promptly and professionally. Where your query relates to a right of access, erasure or rectification, please include your registered email address and a brief description of the request so that we can verify your identity and process your request efficiently.