bat399 Privacy Policy —
How We Protect Your Data

1 Data Controller

For the purposes of this Privacy Policy, the data controller responsible for the personal information of bat399 users is the bat399 platform, operated at bat399.vu under international gaming license authorization. When this policy refers to "bat399", "we", "us", or "our", it refers to the data controller entity operating the bat399 gambling and casino platform.

bat399 is responsible for determining the purposes and means by which personal data belonging to registered users — including Pakistani players across Karachi, Lahore, Faisalabad, Islamabad, Rawalpindi, Multan, and elsewhere — is processed through the platform's systems.

2 Personal Data We Collect

bat399 collects the following categories of personal data from users, depending on the nature of their interaction with the platform:

2.1 Registration & Identity Data

• Full legal name as it appears on your national identity document
• Date of birth (required for 21+ age verification)
• Gender (optional, for platform personalisation purposes)
• Residential address (city, province, Pakistan)
• Registered mobile number (used for account verification and OTP delivery)
• Email address (used for account communications and security notifications)
• CNIC number or passport number (required for KYC verification)

2.2 Financial & Transaction Data

• JazzCash or EasyPaisa mobile wallet number used for deposits and withdrawals
• Bank account details (IBAN, account title) for HBL, UBL, Meezan Bank, or other bank transfer transactions
• Raast or 1LINK identifier where applicable
• Complete transaction history: deposit amounts, withdrawal amounts, dates, and payment method used
• PKR wallet balance and transaction audit log

2.3 Betting & Gaming Activity Data

• Full record of all bets placed, markets wagered on, stake amounts, and settlement outcomes
• Casino game play history including game titles, session duration, bet sizes, and win/loss outcomes
• Bonus claims, wagering requirement progress, and promotional history
• Responsible gaming tool settings: deposit limits, session limits, self-exclusion status

2.4 Technical & Device Data

• IP address at time of registration and at each login
• Device type, operating system, and browser or application version
• Mobile device identifier (for app users)
• Session timestamps, login and logout records
• Geolocation data (city-level, where consented to or required for compliance)

2.5 Communications Data

• Records of all live chat conversations with bat399 support agents
• Email correspondence with bat399 customer service or compliance teams
• Complaint and dispute records

3 How We Collect Personal Data

bat399 collects personal data through the following channels and mechanisms:

• Directly from you — via account registration forms, KYC document submission, deposit and withdrawal requests, support chat conversations, and any forms completed on the bat399 platform or mobile application.
• Automatically through platform use — via server logs, cookies, session tracking technology, and the bat399 mobile application's device permission framework (see Section 6 for cookie details).
• From payment providers — when you initiate a deposit or withdrawal via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, or 1LINK, we receive transaction confirmation data from the relevant payment processor.
• From identity verification services — where bat399 uses third-party identity verification tools to validate CNIC details or cross-reference identity data, we may receive confirmation results from those providers.
• From fraud and compliance monitoring tools — bat399 operates automated risk monitoring systems that generate internal risk scores and flag patterns of potentially irregular activity.

4 Legal Basis for Processing

bat399 processes personal data under one or more of the following lawful bases, depending on the category of data and purpose of processing:

5 How bat399 Uses Your Personal Data

bat399 uses the personal data collected from users for the following specific purposes:

1. Account management: Creating, maintaining, verifying, and administering your bat399 account, including processing all deposits, withdrawals, and bonus allocations in PKR.
2. Identity and age verification: Confirming that you are who you say you are, and that you meet the 21+ age requirement for access to bat399's gambling and casino services.
3. Platform operation: Providing you with access to sports betting markets, live casino games, slots, and all other bat399 services — and ensuring those services function correctly on your device.
4. Security and fraud prevention: Detecting and preventing unauthorised account access, multi-accounting, bonus abuse, money laundering, and other activities prohibited under the bat399 Terms & Conditions.
5. Responsible gaming administration: Recording and enforcing the responsible gaming limits, cooling-off periods, and self-exclusion settings you have activated on your account.
6. Regulatory compliance: Fulfilling bat399's obligations under its international gaming license, including AML reporting, player data record-keeping, and cooperation with licensing authority audits.
7. Support services: Enabling bat399's Urdu and English support team to assist you effectively with account queries, technical issues, and complaints.
8. Promotional communications: Sending you information about bat399 bonuses, cricket betting offers, PSL promotions, and other relevant updates — but only where you have opted in to receive such communications.
9. Platform improvement: Analysing aggregated, anonymised usage data to understand how Pakistani players use the bat399 platform and to prioritise future features and improvements.

6 Cookies & Tracking Technologies

bat399 uses cookies and similar tracking technologies on its website and mobile application to operate essential platform functions and to understand how users interact with the platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for core platform functionality, including maintaining your login session, processing transactions, and enabling the responsible gaming tool settings on your account. These cookies cannot be disabled without impairing platform use.
• Functional Cookies: Used to remember your preferences — such as language settings, last-visited game category, or preferred payment method — to provide a more personalised experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate the bat399 platform. This data helps us identify popular features, performance issues, and areas requiring improvement. No individual user is identified through analytics data.
• Security Cookies: Used to detect and prevent fraudulent sessions, account takeover attempts, and other security threats. These are essential to the platform's fraud prevention infrastructure.

7 Data Sharing & Disclosure

bat399 does not sell, rent, or trade user personal data to any third party. We may share personal data only in the following limited and lawful circumstances:

• Payment processors: When you make a deposit or withdrawal, the relevant transaction data (amount, account identifier) is shared with the applicable payment provider — JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, or 1LINK — solely for the purpose of processing that specific transaction.
• Identity verification providers: Where bat399 uses third-party KYC tools to verify your CNIC or other identity documents, the relevant identity data is processed by the verification provider solely for verification purposes and under strict contractual confidentiality obligations.
• Game software providers: When you play casino games or slots provided by third-party developers (e.g., Evolution Gaming, Pragmatic Play), limited technical session data may be passed to the game provider's servers to operate the game. No financial or identity data is shared with game providers.
• Licensing and regulatory authorities: bat399 may be required to disclose user data to its licensing authority or to law enforcement agencies where legally compelled to do so, including in connection with investigations into money laundering, fraud, or other criminal activity.
• Fraud prevention networks: bat399 participates in shared industry fraud prevention databases. Where a user is identified as posing a fraud or money laundering risk, limited identifying information may be shared with participating operators to prevent harm.

8 Data Security

bat399 implements a multi-layered data security framework designed to protect user personal data against unauthorised access, accidental loss, alteration, or disclosure. The key security measures in place include:

• 256-bit SSL/TLS encryption on all data transmitted between user devices and bat399 servers
• Encryption at rest for all sensitive stored data, including identity documents, payment details, and account credentials
• Two-factor authentication (2FA) available on all bat399 accounts as an additional login security layer
• Access controls ensuring that internal staff access to user data is strictly limited to those with a demonstrated operational need
• Regular security audits conducted by independent security professionals as part of the platform's licensing compliance programme
• Real-time intrusion detection systems monitoring for unusual access patterns or attempted unauthorised access
• Secure data centre infrastructure with physical access controls, redundant systems, and disaster recovery capabilities

9 Data Retention

bat399 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to mandatory retention requirements imposed by our licensing framework. The following retention periods apply:

Once the applicable retention period has expired and there is no ongoing legal obligation to retain the data, bat399 will securely delete or irreversibly anonymise the relevant personal data.

10 Your Data Subject Rights

As a bat399 user whose personal data we process, you hold the following rights in relation to your personal information:

• Right of Access: You may request a copy of all personal data bat399 holds about you. We will provide this within 30 days of a verified request.
• Right to Rectification: Where personal data held by bat399 is inaccurate or incomplete, you have the right to request correction. Account details can also be updated directly through the account settings section of the platform.
• Right to Erasure: You may request deletion of your personal data. Note that where retention is required under licensing obligations (e.g., AML record-keeping), bat399 cannot fulfil an erasure request for that data during the mandatory retention period.
• Right to Restrict Processing: You may request that bat399 restrict the processing of your personal data in certain circumstances, such as while a data accuracy dispute is being resolved.
• Right to Data Portability: You may request that bat399 provides your personal data in a structured, machine-readable format where technically feasible and where processing is based on consent or contractual necessity.
• Right to Object: You may object to processing carried out on the basis of legitimate interest, including marketing communications. Marketing opt-outs take effect immediately upon request.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, contact the bat399 support team via live chat or the support email address in Section 15. All requests will be acknowledged within 5 business days and fulfilled within 30 days unless a legally justified extension applies.

11 Children & Minors

bat399 is a strictly adult gambling platform. No person under the age of 21 years is permitted to register an account or use any bat399 service. bat399 does not knowingly collect personal data from individuals under the age of 21.

bat399 recommends that parents and guardians install appropriate parental control software on shared devices to prevent accidental or deliberate access to gambling platforms by minors. Links to reputable parental control tools are available on our Responsible Gaming page.

12 International Data Transfers

bat399 operates under international gaming license authorization, which means certain data processing activities — including server infrastructure, compliance systems, and game provider integrations — may involve the transfer of personal data to servers or service providers located outside Pakistan.

Where such international transfers occur, bat399 ensures that appropriate data protection safeguards are in place, including contractual obligations on receiving parties to maintain equivalent data protection standards. bat399 does not transfer personal data to any jurisdiction or party that cannot provide adequate data protection assurances.

13 Third-Party Services & Links

The bat399 platform integrates third-party services — primarily game software providers and payment processors — that are necessary for platform operation. These third parties operate under their own privacy policies and data processing agreements with bat399. bat399 requires all data processors to handle user data only as instructed by bat399 and in compliance with applicable data protection standards.

bat399 does not include links to external websites for advertising or commercial purposes. Any links to third-party resources on the bat399 platform (such as responsible gaming support organisations referenced on the Responsible Gaming page) are provided for informational purposes only. bat399 is not responsible for the privacy practices of any external websites.

14 Policy Amendments

bat399 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or platform operations. Where amendments are material — meaning they could significantly affect how your data is processed — bat399 will notify registered users via a prominent notice on the platform and, where possible, via the email address registered on your account.

The "Last Reviewed" date displayed at the top of this policy will be updated whenever the document is amended. Continued use of the bat399 platform following notification of a policy amendment constitutes acceptance of the revised Privacy Policy.

15 Contact & Privacy Complaints

For any questions, concerns, or formal requests relating to this Privacy Policy or the processing of your personal data by bat399, please contact the bat399 support team through the following channels:

• Live Chat: Available 24/7 through the bat399 website and mobile application. Urdu and English language support available. Average response time: 3–5 minutes.
• Support Email: [email protected] (plain text only — not a clickable link). Email responses are provided within 24 hours on business days.

All data subject access requests, rectification requests, erasure requests, and privacy complaints will be acknowledged within 5 business days and resolved within 30 days in accordance with applicable data protection law.

If you are not satisfied with how bat399 has handled your privacy complaint, you may have the right to escalate the matter to the data protection supervisory authority in the jurisdiction where bat399 holds its international gaming license. Contact details for the relevant supervisory authority may be obtained by contacting bat399 support.