Privacy Policy — bat949 Platform

1 Introduction

This Privacy Policy ("Policy") is issued by bat949 ("bat949", "we", "us", "our") and applies to all personal data collected, processed and stored in connection with your use of the bat949 online betting and casino platform accessible at https://bat949.cam (the "Platform").

bat949 is an English-language platform designed primarily for users based in Pakistan. We recognise that privacy is of particular importance to our user base. Whether you are accessing the Platform from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar or any other location, we apply the same consistent data protection standards to your personal information.

bat949 does not hold a local Pakistani government licence and does not claim authorisation or oversight by the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, or any other Pakistani regulatory body. Nothing in this Policy constitutes legal advice applicable to your specific situation under Pakistani law. Users are responsible for understanding the laws applicable to them in their jurisdiction.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, IP address, device identifiers, financial information and behavioural data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. bat949 acts as Data Controller in respect of user data collected through the Platform.
• "Data Processor" means a third party that processes Personal Data on behalf of bat949 under a contractual arrangement, such as KYC verification providers and payment technology partners.
• "KYC" means Know Your Customer — identity, age and source-of-funds verification procedures.
• "Cookie" means a small data file placed on your device by a website to store information about your browsing session or preferences.
• "Account" means the registered user profile created on the Platform.

3 Data Controller

bat949 acts as Data Controller in respect of all Personal Data collected directly from users through the Platform registration process, account management, betting activity, customer support interactions and platform analytics.

Where bat949 engages third-party service providers — such as KYC verification specialists, payment technology providers, game content studios or analytics platforms — those providers operate as Data Processors under contractual data processing agreements that impose equivalent data protection obligations.

4 Data We Collect

bat949 collects the following categories of personal data, depending on how you interact with the Platform:

bat949 does not collect sensitive special-category data (such as health information, religious beliefs or political opinions) unless it is directly volunteered by the user in the context of a responsible gambling support request, in which case it is handled with heightened confidentiality.

5 How We Collect Data

bat949 collects Personal Data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC, making deposits or withdrawals, contacting support, or submitting responsible gambling tool requests.
• Automated technical collection: Technical and behavioural data collected automatically when you access the Platform, including via cookies, log files and platform analytics.
• Third-party verification providers: Identity and age verification data returned by third-party KYC providers when you submit verification documents.
• Payment technology providers: Transaction confirmation and payment status data returned by payment processing integrations. bat949 references familiar Pakistani payment rails (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) as contextual references; actual payment method data processing is governed by the applicable payment provider's own privacy policy.
• Device and browser data: Technical information collected automatically, including IP address, device identifiers, browser type and version.

6 Legal Basis for Processing

bat949 processes Personal Data on the following legal bases, depending on the purpose of processing:

• Contractual necessity: Processing required to fulfil the Terms & Conditions agreement between bat949 and the user — including account management, transaction processing, and delivery of platform services.
• Legal obligation: Processing required to comply with applicable legal requirements, including KYC/AML (anti-money laundering) obligations, age verification and responsible gambling compliance under the operator's license framework.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gambling monitoring, analytics and product improvement, where those interests are not overridden by your privacy rights.
• Consent: For non-essential cookies and marketing communications where consent is expressly given by the user. Consent may be withdrawn at any time without affecting the legality of prior processing.

7 How We Use Your Data

bat949 uses Personal Data for the following purposes:

• Account registration and management: Creating, verifying and maintaining your user account on the Platform.
• Identity and age verification (KYC): Confirming your identity, age and eligibility to use the Platform in accordance with applicable compliance requirements.
• Transaction processing: Processing deposits, withdrawals and recording PKR transaction history accurately.
• Platform delivery: Providing access to sports betting markets, live casino games, slots and other Platform services.
• Responsible gambling compliance: Monitoring gambling patterns, applying responsible gambling tools (deposit limits, session timers, loss caps, self-exclusion), and identifying indicators of problem gambling behaviour.
• Fraud prevention and security: Detecting and preventing fraudulent activity, unauthorised account access, money laundering and terms-of-service violations.
• Customer support: Responding to support tickets, live chat queries and email correspondence.
• Legal compliance: Fulfilling applicable legal obligations under the operator's license jurisdiction, including record-keeping and reporting requirements.
• Platform analytics and improvement: Understanding how users interact with the Platform to improve usability, performance and features — based on aggregated and anonymised analytics data where possible.
• Marketing communications (consent-based): Sending promotional offers, bonus notifications and platform news, where you have expressly consented to receive such communications. You may opt out at any time.

8 Data Sharing & Disclosure

bat949 does not sell, rent or trade your Personal Data to third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• KYC and identity verification providers: Third-party services engaged to verify your identity and age as required under the operator's compliance obligations.
• Payment technology partners: Payment processing integrations used to facilitate deposits and withdrawals. The identity of specific providers is determined by the operator and may change.
• Game content and technology providers: Third-party game studios and live dealer providers that deliver game content through the Platform. These providers receive only the technical data necessary to deliver their services.
• Analytics and fraud prevention services: Platform analytics and security tools used to monitor performance, detect fraud and prevent terms-of-service violations.
• Legal and regulatory authorities: Applicable regulatory bodies, law enforcement agencies or courts where disclosure is required by law, court order or a valid legal process. bat949 will notify users of such disclosures where legally permissible to do so.
• Corporate transactions: In the event of a merger, acquisition or sale of bat949 or its assets, Personal Data may be transferred to the acquiring entity, subject to equivalent data protection obligations being maintained.

All third-party Data Processors are engaged under contractual data processing agreements that require them to process data only in accordance with bat949's documented instructions and to apply appropriate security measures.

9 Your Rights

Subject to applicable law and the specific circumstances of your request, you have the following rights in relation to your Personal Data held by bat949:

To exercise any of these rights, contact bat949 support at [email protected]. bat949 will respond to verified requests within a reasonable period, typically 30 days, subject to identity verification requirements.

10 Cookies & Tracking Technologies

bat949 uses cookies and similar tracking technologies to operate the Platform, remember your preferences and analyse platform usage. The following categories of cookies are used:

You can manage non-essential cookie preferences through your browser settings at any time. Disabling non-essential cookies will not prevent you from using the core Platform, but may affect certain functional features. Note that essential cookies cannot be disabled without preventing normal Platform operation.

11 Data Retention

bat949 retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, subject to applicable legal minimum retention requirements. The following general retention principles apply:

• Active Account data: Retained for the duration of your Account and for a defined period following Account closure, to fulfil legal obligations and to handle any post-closure disputes.
• KYC and identity verification documents: Retained for the legally required period under the operator's AML and compliance obligations — typically a minimum of 5 years from the date of last transaction or Account closure, whichever is later.
• Transaction records: Retained for the minimum period required under the applicable financial record-keeping obligations of the operator's license jurisdiction.
• Customer support records: Retained for a period sufficient to handle disputes and ongoing regulatory obligations, typically 2–5 years.
• Analytics data: Aggregated and anonymised analytics data may be retained indefinitely; individual-level behavioural data is anonymised or deleted after the retention period expires.
• Responsible gambling data: Self-exclusion records and problem gambling indicators are retained for the duration required to enforce responsible gambling obligations — retention may extend beyond general account closure periods to prevent circumvention of self-exclusions.

Where data is no longer required for any legitimate purpose, bat949 takes reasonable steps to securely delete or anonymise it.

12 International Data Transfers

bat949 is an international platform. Your Personal Data may be transferred to and processed in countries outside Pakistan, including countries where bat949's infrastructure, KYC providers, payment processors or game content providers are located.

bat949 takes reasonable steps to ensure that cross-border data transfers are carried out with appropriate safeguards in place. Where applicable, such safeguards may include:

• Standard contractual clauses or data transfer agreements with receiving parties.
• Transfers to jurisdictions with data protection frameworks adequate for the purpose of the transfer.
• Binding corporate rules or equivalent protections applicable to intra-group transfers.

bat949 does not claim that these transfers are subject to Pakistani government oversight or approval. Users in Pakistan should be aware that data transferred internationally will be subject to the laws of the receiving jurisdiction, which may differ from Pakistani law.

13 Children's Privacy

bat949 is an adults-only platform. Access is strictly limited to individuals aged 18 years or older, or the higher minimum age required by the operator's license jurisdiction. bat949 does not knowingly collect Personal Data from individuals under the age of 18.

If bat949 discovers that an Account has been registered by a minor, the Account will be immediately suspended, all associated funds will be withheld pending investigation, and the data will be handled in accordance with applicable child protection obligations. The incident will be reported to relevant authorities where required.

If you become aware that a minor may have registered an Account on bat949, please contact our support team immediately at [email protected].

14 Security Measures

bat949 implements technical and organisational security measures appropriate to the risk level of the data being processed. These include:

• TLS encryption for all data transmitted between your device and the Platform.
• Encryption at rest for sensitive stored data, including KYC documents and financial records.
• Access controls restricting internal access to Personal Data on a strict need-to-know basis.
• Two-factor authentication (2FA) for user accounts and internal staff access to data systems.
• Regular security assessments and penetration testing of Platform infrastructure.
• Incident response procedures for identifying, containing and reporting data security incidents where required.

Notwithstanding these measures, no online platform can guarantee absolute security. bat949 encourages users to maintain strong, unique passwords for their accounts and to enable 2FA where available. Report any suspected security incident to [email protected] immediately.

15 Third-Party Links

The bat949 Platform does not include outbound links to external third-party websites as a design principle. Where third-party content is integrated into the Platform (such as game content from third-party studios), those integrations are governed by bat949's contractual data processing arrangements with the relevant providers.

bat949 is not responsible for the privacy practices or content of any external platform, service or application that a user accesses independently in connection with their use of bat949. Users should review the privacy policies of any third-party services they use — including payment providers such as Easypaisa, JazzCash or their banking institution — separately.

16 Amendments to This Policy

bat949 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements or Platform functionality. Where a material change is made, bat949 will publish notice on the Platform with the effective date of the revised Policy.

Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgement of the updated Policy. If you do not agree to the revised terms, you must discontinue use of the Platform and may exercise your right to request Account closure and data deletion as described in Section 9.

The most current version of this Privacy Policy, along with its effective date, will always be accessible on this page at https://bat949.cam/privacy-policy.

17 Contact & Complaints

For any questions, concerns or requests relating to this Privacy Policy or the way bat949 handles your Personal Data, please contact us using the details below:

bat949 will acknowledge data-related requests promptly and will aim to provide a substantive response within 30 days. In cases where additional time is required due to the complexity of the request, we will inform you of the extended timeline.

If you are dissatisfied with bat949's response to a privacy complaint, you may be entitled to escalate the matter to the applicable data protection supervisory authority in the jurisdiction governing bat949's operating licence. Details of the applicable authority are available on request from our support team.

For related policies, please see our Terms & Conditions and our Responsible Gambling page.