ber939 Privacy Policy –
How We Handle Your Data

01 Introduction

This Privacy Policy explains how ber939 ("we", "us", "the platform") collects, uses, stores and protects personal data when you register an account, make deposits or withdrawals, play games, use our mobile app, or communicate with our support team.

By creating an account on ber939, you confirm that you have read this Privacy Policy and agree to the processing of your personal data as described here. This Policy should be read alongside our Terms and Conditions, which are available at /terms-conditions.

We have written this policy as clearly as possible because we believe Pakistani players deserve to understand exactly what happens with their data — not wade through deliberately complex legal language. If you have any question about anything on this page, contact the support team before registering.

02 Data We Collect

We collect personal data in several ways and across several categories. Here is a clear breakdown:

We do not collect sensitive categories of data such as biometric data (unless you opt into biometric login on the app, in which case biometric verification happens locally on your device and is never sent to our servers), health data, racial or ethnic origin, or political opinions. We do not collect data about your physical location beyond the IP address registered during your sessions.

03 Why We Use Your Data

Every piece of data we collect serves a specific purpose. We do not collect data speculatively. The main purposes are:

• Account creation and management: Your name, date of birth, email and phone number are needed to create your account, verify your identity and ensure only you can access it.
• Age verification: We are required to confirm that all players are 18 or over. Date of birth and identity documents are used for this purpose.
• Payment processing: Payment details are required to process deposits to your PKR balance and to send withdrawals to your registered payment method (JazzCash, Easypaisa, Raast, bank transfer).
• Platform security and fraud prevention: Technical data including IP addresses, device fingerprints and session patterns are analysed to detect suspicious activity, duplicate account attempts and fraudulent payment patterns.
• Responsible gaming compliance: Account activity data is used to identify patterns that may indicate problematic gaming behaviour, allowing us to apply responsible gaming tools and respond to self-exclusion requests correctly.
• Customer support: Communication records are kept so that support agents have context when you contact us, making it possible to resolve issues without asking you to repeat your history every time.
• Platform improvement: Aggregated, anonymised usage data helps us understand how players use the platform and where improvements should be made.
• Marketing communications (with consent only): If you have opted in, we may send promotional offers and updates by email or push notification. You can withdraw this consent at any time.

04 Payment Data and PKR Transactions

Given that most Pakistani players use JazzCash and Easypaisa for deposits and withdrawals, it is worth explaining specifically how payment data is handled on ber939, because payments involve some of the most sensitive personal information you share with us.

When you initiate a JazzCash or Easypaisa deposit, you are interacting with Jazz's or Telenor's own payment gateway. Your wallet PIN is entered and verified on that network — it is never sent to or stored on ber939 servers. What ber939 receives is a payment confirmation token and the relevant transaction reference, not your PIN or full mobile wallet credentials.

For bank transfers and debit card payments, ber939 works with PCI-DSS compliant payment processors. Full card numbers are not stored by ber939. The payment processor handles the card data under the card industry's highest security standard, and ber939 holds only a payment reference and the amount.

Your mobile wallet number or bank account details are stored in an isolated database environment that is separate from the main account and game database. Access between these environments requires separate authentication credentials. This architecture means that a breach of the general account database does not automatically expose payment data.

05 Who We Share Your Data With

ber939 does not sell, rent or trade your personal data to third parties for their own marketing or commercial purposes. Data is shared only where necessary for the platform to operate, and only with parties who are bound by appropriate data protection and confidentiality agreements. The categories of recipients are:

• Payment processors and gateway providers: JazzCash, Easypaisa, Raast, bank partners and card processors receive the minimum data required to complete a transaction. This is unavoidable — a payment cannot be processed without sharing at least the recipient details and amount.
• Game providers: When you launch a game from a provider such as Pragmatic Play or Jili, a session token is passed to that provider's game server. This token identifies your session and balance but does not include your full personal profile.
• Customer support tools: Our support system stores communication records so agents can assist you effectively. This is a third-party tool operating under a data processing agreement.
• Security and fraud detection: Some technical and account activity data may be processed by security services that help identify fraudulent patterns or suspicious account behaviour.
• Legal and regulatory requirements: If required by applicable law or by a valid legal order, ber939 may disclose data to relevant authorities. We will only do this where we are genuinely required to, not speculatively or voluntarily.

We do not share data with data brokers, advertising networks, social media companies or any party for the purpose of targeting advertisements at you on third-party platforms.

06 Cookies and Session Tracking

The ber939 website and mobile app use cookies and similar session tracking technologies to keep you logged in between pages, to remember your preferences, and to collect technical data that helps us maintain platform security and improve performance.

The cookies used by ber939 fall into three broad categories:

• Essential cookies: These are required for the platform to function. They keep your session active while you are logged in and maintain the connection between your browser and the server. You cannot opt out of essential cookies and continue to use the platform.
• Functional cookies: These remember your preferences — such as your chosen language, your last-visited game category, and your notification settings. Disabling these means you may have to re-enter preferences on each visit.
• Analytics cookies: Aggregated, anonymised data about how players move through the platform helps us identify where improvements are needed. This data does not identify you as an individual.

The native Android and iOS apps use equivalent session management mechanisms to cookies — local storage and app session tokens — for the same purposes. You can clear app data through your device settings, which will log you out and clear locally stored preferences.

07 How We Protect Your Data

ber939 applies technical and organisational security measures designed to protect your data against unauthorised access, loss, alteration or disclosure. The key measures in place are:

• 256-bit SSL / TLS 1.3 encryption on all connections between your device and ber939 servers
• Encryption of sensitive data at rest in our databases
• Isolated storage environment for payment data with separate access controls
• Automated anomaly detection for unusual login patterns, withdrawal requests and account changes
• Biometric login support on the native app (processed locally on your device, not server-side)
• Access controls limiting which team members can access player data, with access logged and reviewed
• Regular review of security configurations as technology and threat landscapes change

No system is completely immune from security incidents. In the event of a data breach that is likely to affect your rights and interests, we will notify affected players and take appropriate remedial action without unreasonable delay. If you believe your account has been compromised, contact support immediately through the live chat.

08 How Long We Keep Your Data

We retain personal data only for as long as it is genuinely needed for the purpose it was collected for, or as required by applicable obligations. The general retention principles are:

• Active account data: Retained for the full duration of your account being open. If your account is closed, core identity and transaction records are typically retained for a further period (usually 5–7 years) to meet financial record-keeping and anti-money laundering requirements.
• Transaction and payment records: Retained for 7 years from the date of the transaction as standard financial record-keeping practice.
• Support communications: Retained for the duration of your account and for a reasonable period after closure, to allow for any follow-up queries or disputes.
• Technical session data (IP logs, device logs): Retained for security purposes for up to 12 months, after which it is deleted or anonymised.
• Marketing preference data: If you opt out of marketing, your opt-out preference is retained indefinitely to ensure we do not accidentally restart communications to you.

When data is no longer required and the retention period has passed, it is deleted or anonymised. We do not hold data indefinitely simply because storage is cheap.

09 Your Rights Over Your Data

As a user of ber939, you have the following rights regarding your personal data. To exercise any of these rights, contact the support team through live chat or at [email protected]:

10 Minors and Age Restrictions

ber939 is strictly for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If we discover or are informed that an account belongs to a person under 18, that account will be immediately closed, any balance forfeited, and all personal data associated with the account deleted or anonymised as quickly as the process allows.

If you are a parent or guardian and believe a person under 18 may have created an account on ber939 using your details or their own, please contact us at [email protected] so we can investigate and act immediately.

11 Changes to This Privacy Policy

ber939 may update this Privacy Policy from time to time. Where we make a material change — for example a change to what data we collect or how we share it — we will notify players through an in-platform announcement. The updated policy will be posted at this page with a revised "Last Updated" date.

Continued use of the platform after notification of a material change constitutes acceptance of the updated policy. If you do not agree with a material change, you should close your account before the change takes effect. Minor changes — such as clarifications to existing text that do not alter the substance of the policy — will be updated without formal notification but will still appear with a revised date.

12 Contact and Data Queries

For any questions about this Privacy Policy, to exercise your data rights, or to raise a concern about how your personal information has been handled, contact the ber939 support team. We are available 24/7 via live chat on the website and app, and by email.