Data Protection · Your Rights · Security Commitment

399bat Privacy Policy
How We Protect Your Personal Data

Your privacy matters to us. This Privacy Policy explains exactly what personal information 399bat collects from Pakistani members, why we collect it, how we keep it safe, and what rights you have over your own data. We have written it in plain, clear language because you deserve to understand it.

Privacy at a Glance

The most important things to know about how 399bat handles your data

We Collect Only What We Need

399bat collects personal data only for defined, legitimate purposes – account management, payments, fraud prevention and regulatory compliance. We do not collect data out of habit or store it indefinitely.

We Never Sell Your Data

399bat does not sell, rent or trade your personal information to any third party for marketing or commercial purposes. Your data stays within the 399bat ecosystem and its verified service partners.

Industry-Standard Security

All personal data stored by 399bat is protected with encryption, access controls and regular security audits. Payment data is handled through certified secure channels and is never stored in plain text.

Your Rights Are Real

You have the right to access your data, correct inaccurate information, request deletion and object to certain processing. 399bat will respond to all data rights requests within 30 days.

Data Is Not Kept Forever

Personal data is retained only for as long as necessary for the purposes it was collected or as required by applicable regulatory obligations, then securely deleted or anonymised.

Contact Us Any Time

Questions, requests or concerns about your privacy can be directed to 399bat at any time via support@399bat.click or through the live chat on the platform. We aim to respond within 24 hours.

399bat
Last updated: January 2025

1. Who We Are

This Privacy Policy is issued by 399bat ("we", "us", "our"), the operator of the online betting and gaming platform available at 399bat.click. We are the data controller in respect of the personal information collected and processed through the platform and any associated communications.

399bat is a platform built specifically for Pakistani players. Everything we do with your data – the way we collect it, the way we store it, the way we use it – reflects the reality that you are a Pakistani member using a platform that runs entirely in PKR, with Pakistani payment methods, operated for and by people who understand the local context. Data privacy is not a technicality to us; it is part of our commitment to treating every member with respect.

This Privacy Policy applies to personal data collected through the 399bat website, mobile interface, communications channels including live chat, WhatsApp and email, and any other interactions you have with 399bat as a registered member or prospective member.

This Privacy Policy should be read alongside the 399bat Terms and Conditions and the Responsible Gaming Policy. Together they form the complete agreement governing your use of the platform.

2. Personal Data We Collect

399bat collects personal data that falls into the following categories. We collect only what is necessary for the purposes described in this Policy.

Category Specific Data Points
Identity Data Full name, date of birth, national identity card number (CNIC) or passport number (collected during verification)
Contact Data Email address, Pakistani mobile number, WhatsApp contact (if provided for support)
Account Data Username, account creation date, account status, login history, session timestamps, device identifiers used to access the account
Financial Data Deposit and withdrawal records, payment method identifiers (e.g., Easypaisa or JazzCash account number – last digits only), transaction history, balance history
Betting & Gaming Data Bet history across all products (sports, casino, poker, esports), wager amounts, results, bonus usage history, VIP Club point accumulation and tier history
Technical Data IP address, browser type and version, operating system, device type, screen resolution, referring URL, pages visited on the platform, time spent per session
Communications Data Records of live chat, email or WhatsApp communications with the 399bat support team, including the content of messages and timestamps
Responsible Gaming Data Deposit limits set, session reminders configured, cooling-off periods requested, self-exclusion records

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data or health information. Where identity verification requires us to review a government-issued identity document, the document is reviewed for verification purposes only and the data extracted is limited to name, date of birth and ID number.

3. How We Collect Your Data

399bat collects personal data through the following means:

  • Direct provision by you: When you register for an account, complete identity verification, make a deposit or withdrawal, contact support, or participate in a promotion, you directly provide us with personal data.
  • Automated collection: When you use the 399bat platform, technical data including your IP address, device information and session behaviour is automatically recorded by our systems. This happens every time you visit the website or use the app, whether or not you are logged in.
  • Cookies and similar technologies: 399bat uses cookies and similar tracking technologies to recognise returning users, maintain session state, record platform usage patterns and support fraud detection. Full details are provided in the Cookies section below.
  • Payment processors: When you make a deposit or withdrawal via Easypaisa, JazzCash, NayaPay, SadaPay or bank transfer, the payment processor confirms the transaction and provides 399bat with transaction reference data. We do not receive or store your full payment account credentials.
  • Third-party verification services: Where identity verification is required, we may use a third-party identity verification provider to check the authenticity of identity documents. These providers are bound by confidentiality agreements and data processing agreements with 399bat.
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4. How We Use Your Personal Data

399bat uses personal data for the following specific purposes. We do not use personal data for any purpose that is incompatible with the purpose for which it was collected.

  • Account creation and management: Creating and maintaining your 399bat account, verifying your identity and age, managing your account settings and preferences, and responding to account-related queries.
  • Processing bets and financial transactions: Enabling you to place bets, receive winnings, make deposits and request withdrawals. All financial transaction processing requires accurate identity and payment data.
  • Regulatory compliance and fraud prevention: Complying with applicable anti-money laundering (AML) and know-your-customer (KYC) requirements, detecting and preventing fraudulent activity, and maintaining records as required by applicable law.
  • Responsible gaming: Monitoring betting patterns to identify members who may be showing signs of problem gambling behaviour, and providing responsible gaming tools and interventions where appropriate.
  • Platform improvement: Analysing aggregated, anonymised usage data to understand how members use the platform and to improve the user experience, product offering and technical performance.
  • Customer support: Responding to your queries, complaints and requests through live chat, email and WhatsApp. Support communications are recorded for quality assurance and dispute resolution purposes.
  • Promotions and VIP Club: Administering bonus offers and the VIP Club programme, including calculating points, managing tier status and delivering personalised offers to eligible members.
  • Marketing communications: Sending you promotional communications about 399bat offers and products, subject to your marketing preferences as described in the Marketing section of this Policy.

399bat does not use personal data for automated decision-making that produces legal or similarly significant effects on members, except in the context of fraud detection where automated flags always trigger a human review before any action is taken on an account.

5. Legal Basis for Processing

Every use of your personal data by 399bat is grounded in one of the following legal bases:

  • Contract performance: Processing necessary to provide the services you have requested by registering as a 399bat member and placing bets – including account management, bet processing and payment handling.
  • Legal obligation: Processing required to comply with applicable legal and regulatory obligations, including AML/KYC requirements, age verification, record-keeping obligations and responses to lawful requests from regulatory or law enforcement authorities.
  • Legitimate interests: Processing necessary for the legitimate interests of 399bat, including fraud detection and prevention, platform security, customer support, responsible gaming monitoring and platform improvement – provided those interests are not overridden by your privacy rights.
  • Consent: Processing for marketing communications and non-essential cookies is based on your consent, which can be withdrawn at any time.

6. Sharing Your Personal Data

399bat does not sell, rent or trade your personal data to any third party. We share data with third parties only in the following limited and controlled circumstances:

  • Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, banking institutions and card payment processors receive the transaction data necessary to process your deposits and withdrawals. These providers process data under their own privacy policies and applicable financial services regulations.
  • Identity verification providers: Where required for KYC compliance, your identity data may be shared with a certified third-party verification provider. These providers are bound by strict data processing agreements with 399bat and cannot use your data for any other purpose.
  • Technology and infrastructure providers: 399bat uses third-party cloud hosting, cybersecurity and platform infrastructure services. These providers have access to data only to the extent necessary to provide their services and are contractually bound to protect it.
  • Game content providers: Live casino and card game content from third-party game studios may involve data processing by those studios in connection with the specific game session. No personal data beyond what is necessary for game operation is shared.
  • Legal and regulatory authorities: 399bat may be required to disclose personal data to government agencies, law enforcement authorities or regulatory bodies in response to a lawful request, court order or where disclosure is otherwise required by applicable law.

In all cases where data is shared with third parties, 399bat requires those parties to handle the data securely, use it only for the specified purpose, and not to share it further without authorisation.

7. Cookies and Tracking Technologies

399bat uses cookies – small text files stored on your device – and similar tracking technologies to provide a functional, secure and personalised experience on the platform. The categories of cookies used on 399bat are as follows:

  • Essential cookies: Required for the basic functionality of the platform, including maintaining your login session, remembering your language preference and enabling the bet placement flow. These cannot be disabled without breaking core platform features.
  • Security cookies: Used to detect and prevent fraudulent access attempts, identify unusual session behaviour and protect your account from unauthorised access.
  • Analytics cookies: Used to collect anonymised data about how members use the platform – which pages are visited, how long sessions last, which products are most used – to improve the platform experience. This data is aggregated and does not identify individual users.
  • Preference cookies: Used to remember your settings and preferences so that you do not have to reconfigure them every time you visit, such as notification preferences and responsible gaming tool settings.

You can control non-essential cookies through the cookie settings panel accessible from the footer of the 399bat website. Disabling analytics or preference cookies will not prevent you from using any core betting or gaming feature. Disabling essential or security cookies may impair platform functionality and is not recommended.

399bat does not use third-party advertising cookies or cross-site tracking technologies for the purpose of serving targeted advertising on external websites. Our cookie use is limited to what is necessary for platform operation, security and internal analytics.

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8. Data Security

399bat takes the security of your personal data seriously and implements a layered set of technical and organisational security measures to protect it against unauthorised access, disclosure, alteration and destruction.

TLS Encryption in Transit

All data transmitted between your device and 399bat servers is encrypted using TLS (Transport Layer Security). This prevents interception of your login credentials, payment data and personal information while in transit.

Encrypted Data at Rest

Personal data stored in 399bat databases is encrypted at rest. Sensitive fields including identity document data are subject to additional field-level encryption beyond standard database encryption.

Access Controls

Access to personal data within 399bat is restricted on a strict need-to-know basis. Staff are granted access only to the data categories required for their specific role and all access is logged and audited.

Regular Security Audits

399bat's infrastructure and application security are reviewed regularly by internal security teams and, on a scheduled basis, by independent third-party security auditors. Identified vulnerabilities are remediated with priority.

Fraud and Anomaly Detection

Automated monitoring systems analyse account activity in real-time to detect unusual patterns that may indicate unauthorised access, account takeover attempts or fraudulent payment activity.

Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, 399bat will notify affected members without undue delay and will take immediate steps to contain and remediate the breach.

While 399bat implements robust technical security, your account security also depends on your own practices. Use a strong, unique password for your 399bat account, never share your login details with anyone, and enable two-factor authentication where available. If you suspect your account has been compromised, contact 399bat support immediately.

9. How Long We Keep Your Data

399bat does not keep personal data for longer than necessary. The retention periods applied to different categories of data are as follows:

  • Account and identity data: Retained for the lifetime of your active account and for a period of five years following account closure, to meet regulatory record-keeping requirements applicable to gambling operators and financial service providers.
  • Financial transaction data: Retained for a minimum of five years following the transaction date, in line with AML record-keeping obligations.
  • Betting and gaming history: Retained for the lifetime of your active account and for three years following account closure. Aggregated, anonymised betting statistics may be retained indefinitely for platform analytics purposes.
  • Support communications: Retained for three years from the date of the last communication in a support thread, to enable dispute resolution and quality assurance review.
  • Technical and log data: Retained for a rolling period of 12 months, after which it is automatically deleted or anonymised.
  • Marketing consent records: Retained for the period during which you are subscribed to marketing communications, plus three years following unsubscription to evidence your consent history.

At the end of the applicable retention period, personal data is securely deleted or permanently anonymised. Anonymised data – data from which you cannot be identified in any way – may be retained and used for statistical analysis beyond these retention periods.

10. Your Data Rights

As a member of 399bat, you have the following rights in relation to your personal data. These rights are real and exercisable, and 399bat will respond to all valid requests within 30 days.

Right of Access

You have the right to request a copy of all personal data that 399bat holds about you. We will provide this in a structured, readable format.

Right to Rectification

If personal data that 399bat holds about you is inaccurate or incomplete, you have the right to request that it be corrected without undue delay.

Right to Erasure

In certain circumstances you have the right to request deletion of your personal data. This right may be limited by regulatory obligations that require us to retain certain records.

Right to Restriction

You have the right to request that processing of your data be restricted in certain circumstances – for example, while you are challenging the accuracy of the data we hold.

Right to Object

You have the right to object to processing based on legitimate interests, including profiling for marketing purposes. 399bat will stop the processing unless it can demonstrate compelling grounds that override your interests.

Right to Portability

Where processing is based on consent or contract, you have the right to receive your personal data in a structured, machine-readable format and to transfer it to another controller.

To exercise any of these rights, contact 399bat at support@399bat.click with the subject line "Data Rights Request". Please provide enough information to identify your account. We will acknowledge your request within 5 working days and respond in full within 30 days. Where a request is complex or involves a large volume of data, this period may be extended by a further 30 days with notification.

Some rights are not absolute. The right to erasure, for example, may be limited where 399bat is required to retain data to comply with AML/KYC regulatory obligations. In such cases, we will explain the limitation in our response to your request.

11. Marketing Communications

399bat may send you promotional communications about platform offers, new products, VIP Club benefits and upcoming events. These communications are sent by email, SMS and WhatsApp (where applicable) only where you have indicated that you are happy to receive them.

You can manage your marketing preferences at any time through the communications settings in your 399bat account dashboard, or by clicking the unsubscribe link in any marketing email. You can also contact support@399bat.click to request that your marketing preferences be updated.

Please note that opting out of marketing communications does not affect your receipt of transactional communications – such as deposit confirmations, withdrawal notifications, account security alerts and support responses. These are necessary service communications and cannot be disabled while your account is active.

399bat does not share your contact details with third-party marketing companies. All marketing communications you receive will come from 399bat directly. If you receive what appears to be a marketing communication from 399bat that you did not expect, contact support to verify its authenticity before clicking any links.

12. Children and Minors

399bat is strictly an 18+ platform. We do not knowingly collect personal data from anyone under the age of 18. Age verification measures are applied during account registration and may be requested at any time during account use.

If 399bat becomes aware that personal data has been collected from a person under the age of 18, that data will be deleted immediately, the account will be permanently closed and any funds in the account will be handled in accordance with the Terms and Conditions applicable to underage accounts.

If you believe that a minor may have created a 399bat account, please contact us immediately at support@399bat.click with the relevant account details so we can investigate and take appropriate action without delay.

13. Changes to This Privacy Policy

399bat may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law or platform features. When a material change is made – one that significantly affects how we process your personal data – we will notify you by email to the address registered on your 399bat account and post the updated Policy on the platform with a revised effective date.

For minor changes – such as clarifications of existing practices that do not affect your rights – we will update the Policy and revise the "last updated" date at the top of the page without direct notification. We recommend reviewing this Policy periodically to stay informed of how your data is handled.

Continued use of the 399bat platform after a revised Privacy Policy has been posted constitutes your acceptance of the updated practices described in that Policy. If you do not agree to the revised Policy, you must stop using the platform and contact support to request account closure.

14. Contact and Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, want to report a privacy concern, or have a complaint about how 399bat has handled your personal data, please contact us through any of the following channels:

  • Email: support@399bat.click – subject line: "Privacy Enquiry" or "Data Rights Request"
  • Live Chat: Available 24/7 through the platform
  • WhatsApp: Contact details available in your account dashboard

399bat will acknowledge all privacy-related enquiries within 24 hours. Formal data rights requests will be responded to in full within 30 days. Complaints about data handling will be investigated and responded to within 15 working days.

If you are not satisfied with how 399bat has responded to a privacy complaint, you have the right to escalate your complaint in writing to the senior privacy team at the same email address, clearly marked "Escalated Privacy Complaint".

Your Privacy Is Our Commitment

399bat is committed to handling your personal data with integrity, transparency and security. If you ever have a concern about how your data is being used, please do not hesitate to contact us. We are available 24/7 at support@399bat.click or via live chat. For the full picture of your rights and our obligations, visit the Terms and Conditions page.

Join 399bat – Your Data is Safe With Us

Now you know exactly how 399bat handles your personal data. Register free, deposit in PKR via Easypaisa or JazzCash, and start betting on the platform that was built for Pakistani players from day one.

Data never sold TLS encrypted PKR only – no conversion