pet939 Privacy Policy

This Privacy Policy ("Policy") describes how pet939 ("pet939", "we", "us", "our") collects, uses, stores, shares, and protects the personal data of users ("you", "the Player", "the User") who access or use the pet939 online gaming platform at https://pet939.org and any associated mobile or web application (collectively, the "Platform").

This Policy is incorporated by reference into pet939's Terms & Conditions and forms part of the binding agreement between you and pet939. By registering an account or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

1 Introduction

pet939 is committed to protecting the privacy and personal data of all players who use our Platform. We recognise that trust is the foundation of any long-term relationship between a gaming platform and its players, and we take our data protection responsibilities extremely seriously.

This Policy applies to all personal data processed by pet939 in connection with your use of the Platform, including data collected during registration, identity verification, deposits and withdrawals, gameplay activity, customer support interactions, and marketing communications (where you have opted in).

1.1 Scope

This Policy covers all personal data processing activities carried out by pet939 as the data controller. It does not cover third-party websites or services that may be linked from the Platform, or the data practices of third-party payment processors, game software providers, or other service partners — each of whom operates under their own privacy policy.

1.2 Updates to This Policy

pet939 reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, applicable laws, or regulatory requirements. The date at the top of this document indicates when the Policy was last revised. We encourage you to review this page regularly.

2 Data Controller

For the purposes of applicable data protection legislation, pet939 is the data controller in respect of the personal data collected and processed through the Platform. As data controller, pet939 determines the purposes and means by which your personal data is processed.

pet939 operates under an international gaming licence and is subject to the data protection and player privacy requirements imposed by its licensing authority. Our Data Protection contact is reachable at [email protected] — please mark any data protection queries with the subject line "Data Protection Request".

3 Personal Data We Collect

The categories of personal data that pet939 collects and processes are set out in the table below. We collect only the data that is necessary for the stated purposes.

4 How We Collect Your Data

pet939 collects personal data through the following channels:

4.1 Direct Collection

Data you provide directly to us when you register an account on the pet939 Platform, complete KYC verification by submitting your CNIC, make a deposit or withdrawal request, contact our customer support team via live chat or email, participate in a promotion or bonus scheme, or update your account profile settings.

4.2 Automated Technical Collection

Data collected automatically when you access the Platform, including your IP address, device identifiers, browser fingerprint, session timestamps, and navigation patterns. This data is collected via server logs, session cookies, and analytics tools operated by or on behalf of pet939. We use this data primarily for security monitoring and fraud detection rather than for marketing profiling.

4.3 Third-Party Sources

In limited circumstances, pet939 may receive personal data about you from third-party sources, including: identity verification service providers used for KYC processing; fraud prevention databases and AML screening services; and payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank) who confirm transaction status and account ownership.

5 How We Use Your Personal Data

pet939 uses the personal data we collect for the following purposes:

• Account registration and management: Creating and maintaining your pet939 account, verifying your identity, and enabling you to access all Platform services including sports betting, casino, slots, and fishing games.
• Identity and age verification (KYC): Confirming that you are a real person aged 21 or above and that the information provided at registration is accurate, as required under our international gaming licence.
• Payment processing: Facilitating PKR deposits and withdrawals via your nominated JazzCash, EasyPaisa, HBL, UBL, or Meezan Bank account; reconciling transactions; and investigating disputed payments.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, money laundering, and other unlawful activities through automated and manual review processes.
• Responsible gaming: Monitoring wagering patterns to identify signs of problem gambling behaviour and enforcing deposit limits, loss limits, and self-exclusion requests made by you or required by our licensing authority.
• Customer support: Responding to your queries, complaints, and support requests, and maintaining records of those interactions for quality assurance and dispute resolution purposes.
• Legal and regulatory compliance: Meeting our obligations under our international gaming licence, applicable AML legislation, and any requests from competent regulatory authorities.
• Platform improvement: Analysing aggregated, anonymised usage data to identify and fix bugs, improve the user experience, and develop new features on the pet939 Platform.
• Marketing communications: Sending you promotional offers, bonus notifications, and game updates where you have opted in to receive such communications. You may opt out at any time.

6 Legal Basis for Processing

pet939 processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing your data is necessary to perform the contract between you and pet939 — i.e., to operate your account, process your bets, and deliver our gaming services to you.
• Legal obligation: Processing is required to comply with our legal and regulatory obligations under our international gaming licence, including KYC, AML, and responsible gaming mandates.
• Legitimate interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we rely on your consent — for example, for optional marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

7 Data Sharing & Disclosure

pet939 does not sell your personal data. We share your data only in the limited circumstances described below, and only with recipients who are subject to appropriate data protection obligations.

7.1 Service Providers

We share data with carefully selected third-party service providers who process data on our behalf and under our instructions, including: KYC and identity verification providers; payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank); cloud infrastructure and hosting providers; fraud detection and AML screening services; and customer support platform providers. All service providers are contractually bound to protect your data and to use it only for the specified purpose.

7.2 Legal and Regulatory Authorities

We may disclose your personal data to regulatory authorities, law enforcement agencies, or gaming licensing bodies where we are legally required to do so — for example, in response to a valid court order, regulatory investigation, or AML reporting obligation. In such cases, we will disclose only the minimum data necessary to satisfy the legal requirement.

7.3 Business Transfers

In the event that pet939 is involved in a merger, acquisition, or sale of all or substantially all of its assets, your personal data may be transferred as part of that transaction. You will be notified of any such transfer and of any resulting changes to this Privacy Policy before your data is transferred to a new controller.

8 Data Retention

pet939 retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by our legal and regulatory obligations. The following retention periods apply as a general guide:

After the applicable retention period, data is securely deleted or anonymised in accordance with industry best practices so that it can no longer be associated with any individual player.

9 Data Security

pet939 implements robust technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes the following measures:

• Encryption in transit: All data transmitted between your browser or app and the pet939 Platform is encrypted using TLS 1.2 or higher.
• Encryption at rest: Sensitive data — including CNIC details and financial records — is encrypted at rest using AES-256 encryption on our servers.
• Password hashing: Account passwords are never stored in plain text. We use industry-standard one-way hashing algorithms with salt to store password credentials.
• Two-factor authentication (2FA): pet939 supports 2FA for all player accounts and strongly recommends that all players enable this feature to protect their pet939 Login credentials.
• Access controls: Access to personal data within pet939's internal systems is restricted on a strict need-to-know basis. Customer support agents have access only to the data necessary to resolve your support query.
• Penetration testing: pet939's Platform undergoes regular third-party penetration testing and vulnerability assessments to identify and remediate security weaknesses before they can be exploited.
• Incident response: pet939 maintains a formal data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify you and the relevant regulatory authority within the timeframes required by applicable law.

10 Your Data Rights

As a player on the pet939 Platform, you have the following rights in respect of your personal data. To exercise any of these rights, please contact us via live chat or at [email protected] with the subject line "Data Rights Request". We will respond within 30 days.

Please note that some rights are subject to exemptions and limitations. For example, we may be unable to delete certain data that we are legally required to retain under our AML and gaming licence obligations. Where we cannot fully comply with a request, we will explain the reason in writing.

11 Cookies & Tracking Technologies

pet939 uses cookies and similar tracking technologies on the Platform to ensure core functionality, maintain your session, and help us understand how players use the Platform. We do not use advertising cookies or third-party tracking pixels for commercial retargeting purposes.

11.1 Types of Cookies We Use

11.2 Managing Cookies

You can manage or disable cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will impair your ability to log in and use the Platform. Functional and analytics cookies can be disabled without affecting core account access. Refer to your browser's help documentation for instructions on managing cookie settings.

12 Protection of Minors

pet939 operates an online gaming platform that is strictly restricted to persons aged 21 years or older. We do not knowingly collect, store, or process the personal data of individuals under the age of 21. Our mandatory KYC verification process — which requires submission of a valid CNIC — is specifically designed to screen out underage users before any gaming activity can take place.

If pet939 discovers or is notified that a minor has registered an account or provided personal data on the Platform, we will immediately suspend the account, delete all associated personal data as far as is permissible under our regulatory obligations, and refund any deposits made, less any bonuses claimed. Any winnings accrued by an underage user are not payable.

13 International Data Transfers

As an internationally licensed gaming platform, pet939 may transfer your personal data to countries outside of Pakistan for processing and storage. This may occur where our cloud infrastructure, KYC providers, or other service partners operate servers in other jurisdictions.

Where personal data is transferred internationally, pet939 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Policy. These safeguards may include contractual clauses with data recipients, reliance on adequacy decisions, or the adoption of binding corporate rules.

14 Changes to This Privacy Policy

pet939 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, the services we offer, or applicable legal and regulatory requirements. When we make material changes to this Policy, we will notify you by posting a prominent notice on the Platform homepage, updating the "Last Updated" date at the top of this document, and where practicable, sending a notification to your registered email address.

Your continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should stop using the Platform and close your account prior to the effective date of the change. We encourage all players across Pakistan to review this page periodically to stay informed of how pet939 is protecting their personal data.

Minor amendments — such as typographical corrections, clarifications of existing provisions, or updates to contact details — may take effect immediately upon publication without prior notice.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to how pet939 processes your personal data, please contact our Data Protection team using any of the following channels. We are committed to handling all privacy-related queries with care and professionalism.