Privacy Policy

Section 01

Introduction

pet939 ("we", "us", "the Operator", "the Platform") operates the online gambling platform accessible at https://pet939.cam. We are committed to protecting the privacy and security of all personal data we handle in connection with the operation of that platform.

This Privacy Policy applies to all users of the pet939 website and associated services, including registered account holders, visitors who browse without registering, and any other individuals whose personal data we process in connection with the platform ("you", "User", "Data Subject").

This Policy should be read alongside our Terms & Conditions, which govern your use of the platform as a whole. By accessing, registering on or using pet939, you acknowledge that you have read and understood this Privacy Policy and consent to the data-processing activities described herein to the extent that consent is the applicable legal basis.

Pakistan Users: The Prevention of Electronic Crimes Act, 2016 (PECA) and the Personal Data Protection Bill (in various stages of legislative process at the time of this policy's publication) reflect Pakistan's evolving data protection landscape. We handle all Pakistani user data with respect for applicable privacy principles, regardless of the current legislative status. This Policy does not constitute legal advice — users should consult applicable local law.

Section 02

Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

"Personal Data"

Any information relating to an identified or identifiable natural person — including name, email address, CNIC number, date of birth, IP address, device identifiers and financial transaction records.

"Processing"

Any operation or set of operations performed on personal data, whether automated or manual, including collection, recording, storage, organisation, retrieval, use, disclosure and deletion.

"Data Controller"

The entity (pet939 / the Operator) that determines the purposes and means of processing personal data.

"Data Processor"

A third party that processes personal data on behalf of the Data Controller under a written agreement, such as KYC verification providers or payment gateway processors.

"Consent"

Freely given, specific, informed and unambiguous indication of a Data Subject's agreement to the processing of their personal data for a stated purpose.

"KYC Documents"

Identity and address verification documents submitted by a User for account verification purposes, such as a Pakistani CNIC, passport or proof-of-address statement.

"Sensitive Data"

A category of personal data warranting heightened protection, including biometric identifiers, financial account details and identity document numbers.

Section 03

Data We Collect

We collect different categories of personal data depending on how you interact with the pet939 platform. The following table sets out the principal categories of data we collect and the context in which each arises.

Data Category	Examples	Context of Collection
Identity Data	Full name, date of birth, CNIC or passport number, nationality	Account registration; KYC verification
Contact Data	Email address, mobile number, city of residence	Registration; support communications
Financial Data	Deposit/withdrawal transaction records, payment method reference (e.g. wallet type), PKR amounts	Payments processing; AML compliance
KYC Documents	Scanned CNIC, passport photograph page, selfie, proof-of-address statement	Identity and age verification
Technical Data	IP address, browser type, device identifier, operating system, session timestamps	Platform access; fraud detection; analytics
Usage Data	Pages visited, bets placed, games played, session duration, feature interactions	Platform improvement; responsible gambling monitoring
Communications Data	Support chat logs, email correspondence, complaint records	Customer support; dispute resolution
Marketing Preferences	Opt-in / opt-out status for promotional communications	Direct marketing management

We do not collect full payment card numbers, CVV codes or bank account login credentials. Payment transactions are processed by third-party payment processors who hold their own data security certifications. pet939 receives only transaction reference data and status confirmations.

Section 04

How We Collect Your Data

We collect personal data through the following channels and mechanisms:

4.1 Direct Collection

Data you provide directly when you register an account, complete KYC verification, make a deposit, contact our support team, or respond to a survey or promotion. This includes all form fields completed on the platform and documents uploaded through the secure verification portal.

4.2 Automated Technical Collection

When you access the platform, our servers automatically record technical data including your IP address, device type, browser version, referring URL and session activity logs. This data is collected using server-side logging, cookies and similar tracking technologies (see Section 8).

4.3 Third-Party Sources

We may receive data about you from third-party identity verification providers (for KYC), fraud-prevention services, payment processors and, where applicable, publicly available sources consulted for AML due-diligence purposes. Such third-party sharing is conducted under contractual data-processing agreements.

4.4 Responsible Gambling Monitoring

We monitor usage patterns — session duration, deposit frequency, loss amounts and betting behaviour — to support our responsible gambling obligations. This monitoring is a function of our licensing and player-protection commitments, not a commercial profiling exercise.

Section 05

Legal Basis for Processing

We process your personal data on one or more of the following lawful bases, which we identify in relation to each processing activity:

Contractual necessity: Processing required to fulfil our contractual obligations to you under the Terms & Conditions — including account management, payment processing and customer support.
Legal obligation: Processing necessary to comply with applicable law, including AML obligations, KYC requirements and licensing-authority mandates.
Legitimate interests: Processing carried out in pursuit of our legitimate business interests — such as fraud detection, platform security and improvement of our services — where those interests are not overridden by your rights.
Consent: Processing based on your freely given, specific and informed consent — principally for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.
Vital interests: In exceptional circumstances, processing to protect the vital interests of a data subject or another person — for example, where we have a serious safeguarding concern.

Section 06

How We Use Your Data

We use the personal data we collect for the following specific purposes. We do not use personal data for any purpose incompatible with those listed below without obtaining fresh consent or establishing a new lawful basis.

6.1 Account Management

To register, maintain and administer your pet939 account; to authenticate your identity on login; to manage password resets and security alerts; and to process account closure requests.

6.2 Payment Processing

To process deposits and withdrawal requests via available payment channels — which may include mobile wallet services and bank transfers familiar to Pakistani users such as Easypaisa, JazzCash, Raast, and transfers from or to accounts at HBL, UBL, Meezan Bank and Bank Alfalah. Payment provider names are mentioned here as contextual references only and do not imply endorsement of gambling activity by any provider.

6.3 KYC & Compliance

To verify your identity and age; to conduct AML screening; to comply with our obligations under the Operator's licensing framework; and to satisfy reporting requirements where legally mandated.

6.4 Platform Security & Fraud Prevention

To detect, investigate and prevent fraudulent transactions, collusion, bonus abuse, money laundering and other prohibited conduct. Technical data including IP addresses and device fingerprints are integral to this function.

6.5 Responsible Gambling

To monitor player behaviour for indicators of problem gambling; to apply limits set by the user; to action self-exclusion requests; and to refer users to appropriate support resources where warranted.

6.6 Customer Support

To respond to account queries, payment disputes, technical issues and complaints. Support communications are logged and retained to maintain accurate records of the assistance provided.

6.7 Marketing Communications (Consent-Based)

Where you have opted in to receive marketing communications, we may use your email address to send promotional information about pet939 offers, bonuses and platform updates. You may unsubscribe at any time by following the instructions in any marketing email or by contacting support.

6.8 Platform Improvement & Analytics

To understand how users interact with the platform, identify performance issues, test new features and improve the overall user experience. Analytics are conducted on aggregated or pseudonymised data wherever technically feasible.

Section 07

Data Sharing & Disclosure

We do not sell your personal data to any third party. We share personal data only in the following circumstances, and only to the extent necessary for the stated purpose:

KYC & Identity Verification Providers: Third-party providers contracted to perform identity checks, liveness verification and document authentication as part of our KYC process. These providers process data under our instructions and are bound by data-processing agreements.
Payment Processors: Payment service providers and gateway operators who facilitate deposit and withdrawal transactions. Transaction data shared with processors is limited to what is necessary for payment execution and reconciliation.
Fraud & AML Screening Services: Third-party screening tools used to detect prohibited conduct, verify source-of-funds information and comply with AML obligations.
Licensing & Regulatory Authorities: Our licensing authority or other competent regulatory body, where we are legally required to disclose information as a condition of our operating licence or in response to a lawful regulatory request.
Law Enforcement & Legal Process: Competent law enforcement authorities or courts, where we are legally compelled to disclose data pursuant to a court order, warrant or equivalent legal instrument.
Professional Advisers: Legal counsel, auditors and compliance advisers engaged in connection with the operation of the platform, subject to strict confidentiality obligations.
Business Transfers: In the event of a merger, acquisition, reorganisation or sale of the Operator's business, personal data may be transferred to the relevant successor entity, subject to equivalent privacy protections being maintained.

Cross-Border Data Transfers: Some of our third-party processors and service providers are located outside Pakistan. Where personal data is transferred to processors in other jurisdictions, we implement appropriate safeguards — such as standard contractual clauses or equivalent measures — to ensure the data receives a level of protection consistent with the principles of this Policy.

Section 08

Cookies & Tracking Technologies

pet939 uses cookies and similar tracking technologies to operate the platform, maintain session continuity, detect fraud and understand user behaviour. Cookies are small data files stored on your browser or device.

8.1 Essential Cookies

Strictly necessary for the platform to function. These cookies manage session authentication, maintain your login state across pages and support security features such as CSRF protection. They cannot be disabled without impairing platform functionality.

8.2 Functional Cookies

Enable the platform to remember your preferences — such as language settings and responsible-gambling limit configurations — across sessions. Disabling these cookies may affect your personalised experience.

8.3 Analytics Cookies

Used to collect aggregated data on how users navigate the platform — which pages are visited, where users spend the most time and which features are most used. This data informs platform improvement decisions and is processed on a pseudonymised basis where possible.

8.4 Security & Fraud-Detection Technologies

Device fingerprinting and IP-based tracking are used as part of our fraud-prevention and AML controls. These technologies help identify suspicious access patterns, duplicate account attempts and geolocation inconsistencies.

You may manage cookie preferences through your browser's settings. Disabling essential cookies will prevent you from using the platform. For third-party cookie tools or analytics scripts integrated into the platform, please refer to the respective provider's cookie policy for further information on their data practices.

Section 09

Data Retention

We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law or our licensing obligations. The following general retention principles apply:

Account data: Retained for the duration of your account's active status, plus a minimum post-closure retention period required by our licensing framework (typically five to seven years depending on applicable AML and audit requirements).
KYC documents: Retained for the period required by applicable AML regulations, which may extend beyond account closure. Exact retention periods are determined by the requirements of our licensing jurisdiction.
Financial transaction records: Retained for the period required by our licensing framework and applicable accounting and AML standards — typically a minimum of five years from the date of each transaction.
Support communications: Retained for a commercially reasonable period sufficient to maintain accurate complaint and dispute resolution records — typically up to three years from the date of each communication, unless a longer period is required by a specific legal or regulatory obligation.
Marketing data: Retained until you withdraw consent or opt out of marketing communications, at which point marketing-specific data is suppressed from active use.
Technical and usage logs: Retained for a short-term operational period for security and fraud-detection purposes, subject to any longer retention required for a specific investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

Section 10

Data Security

We implement a range of technical and organisational security measures to protect personal data against unauthorised access, loss, alteration, disclosure or destruction. These measures include, but are not limited to:

TLS/SSL encryption for all data in transit between your browser or device and our servers;
Encryption at rest for sensitive stored data, including KYC documents and financial records;
Access controls limiting internal access to personal data to authorised personnel on a need-to-know basis;
Multi-factor authentication for administrative access to production systems;
Regular security assessments and penetration testing of platform infrastructure;
Incident response procedures to detect, contain and notify affected parties of any data breach in accordance with applicable obligations.

Your security responsibilities: The security of your account also depends on you. Keep your login credentials confidential. Do not share your password with any third party, including anyone claiming to represent pet939 support. If you suspect your account has been accessed without authorisation, contact [email protected] immediately. Equally, never send KYC documents via unencrypted channels — always use the secure portal within your account settings.

Despite these measures, no system can be guaranteed to be completely secure. We cannot provide an absolute assurance that data will never be accessed by an unauthorised party. In the event of a material data breach affecting your personal data, we will notify you in accordance with our obligations under applicable law.

Section 11

Your Rights

Subject to applicable law and any overriding legal obligations (including our AML and KYC retention requirements), you have the following rights in relation to your personal data held by pet939:

Right of Access

You have the right to request a copy of the personal data we hold about you. We will respond to verified access requests within a commercially reasonable timeframe. We may need to verify your identity before releasing data.

Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. Some corrections may require verification through our KYC process — for example, changes to your registered name or date of birth.

Right to Erasure ("Right to Be Forgotten")

You may request deletion of your personal data in certain circumstances — for example, where processing is no longer necessary for the purpose it was collected and no legal obligation requires its retention. Note that AML and KYC retention obligations may override deletion requests for specific data categories.

Right to Restrict Processing

You may request that we restrict the active processing of your data in certain circumstances — for example, while the accuracy of data is being contested or while an objection to processing is being considered.

Right to Object

You may object to processing carried out on the basis of legitimate interests. We will assess whether compelling grounds exist to continue processing. You have an absolute right to object to direct marketing processing, which we will action without delay.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. Withdrawal of consent for marketing communications does not affect your account's operational status.

To exercise any of these rights, please contact us in writing at [email protected], marking your subject line "Data Rights Request". We will acknowledge your request and respond within a reasonable timeframe. We may ask you to verify your identity before processing the request.

Section 12

Minors & Age Verification

pet939 is strictly an adults-only platform. We do not knowingly collect or process the personal data of individuals under 18 years of age, or the higher minimum age required by the Operator's licensing jurisdiction.

As part of our KYC process, all registered users are required to verify their age. Any account found — at registration or at any later point — to belong to an individual below the applicable minimum age will be suspended immediately. All funds in such an account will be reviewed, and deposited funds will be returned to the originating payment source following investigation. Any winnings accumulated by an underage user will be voided.

If you are a parent or guardian and believe that a minor under your care has registered an account on pet939, please contact us immediately at [email protected]. We will investigate and act promptly.

Section 13

International Data Transfers

As an internationally operating platform, pet939 and its third-party service providers may store and process personal data in jurisdictions outside Pakistan. This may include jurisdictions in Europe, North America or Asia where our technology infrastructure, KYC providers or payment processors are based.

Where personal data is transferred internationally, we take steps to ensure that adequate protections are in place — including, where applicable, standard contractual data-transfer clauses, adequacy-based transfer mechanisms or other appropriate safeguards recognised under the data protection framework applicable to our licensing jurisdiction.

By using pet939, you acknowledge that your data may be processed in jurisdictions outside Pakistan, and that the data protection standards in those jurisdictions may differ from those applicable domestically. We remain responsible for ensuring that all transfers are conducted with appropriate care and contractual protections in place.

Section 14

Policy Amendments

We reserve the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data-processing practices or the services we offer. Where changes are material, we will notify registered users by email or by a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this document reflects the most recent revision. We encourage you to review this Policy periodically. Your continued use of the platform after the effective date of any amendment constitutes your acknowledgement of the updated Policy.

Section 15

Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or our data-processing practices, please contact our team using the details below. All privacy-related enquiries are handled in English as standard; Urdu assistance is available on request.

Privacy & Data Protection Enquiries

Email: [email protected]
Please mark your subject line clearly as "Privacy Enquiry" or "Data Rights Request".
Available: 24 hours a day, 7 days a week.
Response target: within one business day for standard enquiries; up to five business days for formal data-rights requests requiring identity verification.

Data Breach Reports

If you believe you have identified a data security vulnerability or potential breach affecting pet939 user data, please contact us urgently at the same email address with the subject line "Security Report". We take all such reports seriously and will investigate promptly.