but 939 Privacy Policy — How We Protect Your Data

but 939 is an online sports betting and gaming platform operated specifically for players in Pakistan. When we say "but 939," "we," "us," or "our," we mean the but 939 platform and its operating team. When we say "you" or "your," we mean any person who registers an account, visits the website, or uses any service provided under the but 939 brand.

but 939 is the data controller for all personal information collected through the platform. This means we are responsible for deciding how and why your data is collected, stored, and used. We take that responsibility seriously — your trust in but 939 depends on us handling your information with integrity.

but 939 collects personal data through several routes: information you provide directly during registration and account use, information generated automatically by your use of the platform, and in limited cases, information from third-party payment processors for verification purposes.

but 939 does not collect sensitive personal data such as racial or ethnic origin, religious beliefs, or health data except where specifically relevant to responsible gaming safeguards, in which case it is handled with heightened security and restricted access.

but 939 collects and processes personal data only where there is a valid reason for doing so. We do not collect data speculatively or for purposes we haven't thought through carefully. The main reasons we process your data are:

• To provide the service: We need your name, contact details, and payment information to create and manage your but 939 account, process deposits and withdrawals in PKR, and deliver the betting and gaming services you've signed up for. Without this data, we simply cannot run your account.
• To verify your identity: CNIC and date of birth are collected to confirm that you are who you say you are and that you are at least 18 years old. This protects both you and the integrity of the platform. Identity verification may be required before processing withdrawal requests above certain thresholds.
• To detect and prevent fraud: Activity data and technical data are analysed by but 939's security systems to identify unusual patterns that may indicate account compromise, bonus abuse, money laundering, or other fraudulent activity. This protects all players on the platform.
• To comply with legal obligations: Certain data retention and identity verification requirements exist because of legal and regulatory obligations applicable to financial services platforms. but 939 maintains records as required by these obligations.
• To provide customer support: Communications data — support chat transcripts and emails — are retained so that our support team can provide continuity of service and resolve ongoing issues.
• To improve the platform: Aggregated, anonymised activity data is used to understand how players use but 939 and to improve features, performance, and user experience. This analysis never identifies individual players.

but 939 is very clear about this: we do not sell your personal data to anyone. We do not share your data with advertisers, data brokers, or marketing companies. The people and organisations who may receive your data are those who need it to help us run the platform — and only for that purpose.

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, banks, and card networks receive only the data needed to process your specific transaction. They operate under their own privacy policies and data security standards.
• Identity verification services: In certain cases but 939 uses third-party KYC verification providers to confirm identity documents such as CNIC. These providers are bound by data processor agreements with but 939 and may not use your data for any other purpose.
• Technology infrastructure providers: Cloud hosting, database, and security service providers may process data as part of delivering the platform's technical infrastructure. All such providers are under contractual obligations to maintain data security.
• Law enforcement and regulators: but 939 will share data with law enforcement or regulatory authorities if required to do so by a valid legal obligation — for example, in response to a court order or law enforcement investigation. We will inform you of such disclosure where legally permitted to do so.
• Fraud prevention networks: Industry-standard fraud prevention databases may be used to cross-check certain account registration details. This is to protect all players from fraudulent accounts on the platform.

All deposits and withdrawals on but 939 are processed in Pakistani Rupees (PKR). The platform accepts Easypaisa, JazzCash, NayaPay, SadaPay, bank transfers (IBFT), and Visa/Mastercard. Here's specifically how we handle payment-related data:

• but 939 stores references to your payment transactions — transaction IDs, amounts, timestamps, and payment method type. We do not store full card numbers, CVV codes, or mobile wallet PINs.
• Payment information is transmitted using SSL encryption. It is never transmitted or stored in plain text.
• Transaction records are retained for accounting, fraud prevention, and legal compliance purposes in line with Section 7 of this policy.
• If you request a withdrawal to a payment method, but 939 may verify that the method belongs to you before processing. This is to protect you from unauthorised withdrawals.

but 939 uses cookies and similar technologies to make the platform work properly, to keep you logged in during your session, and to understand how the platform is being used so we can improve it. We do not use cookies for cross-site advertising tracking.

• Essential cookies: Required for the platform to function. These include your session cookie that keeps you logged in during a betting session. You cannot opt out of essential cookies and still use the platform.
• Analytics cookies: Used to understand how pages are used — which sections get the most visits, average session lengths, and navigation paths. This data is aggregated and anonymised. It helps us improve the platform but does not identify individual players.
• Preference cookies: Store your platform preferences such as your chosen odds format (decimal, fractional, American) and language settings so you don't have to reset them each session.

Most browsers allow you to manage cookie settings. Disabling essential cookies will prevent but 939 from working correctly. Disabling analytics cookies will not affect your ability to use the platform.

but 939 does not keep your data longer than necessary. Retention periods depend on the type of data and the purpose for which it was collected:

When retention periods expire, data is securely deleted or permanently anonymised. We do not archive data indefinitely.

but 939 uses multiple layers of security to protect the personal data of Pakistani players. Security is not an afterthought — it is built into every system and process on the platform.

• SSL / TLS encryption: All data transmitted between your browser or app and but 939's servers is encrypted using 256-bit SSL. Your login credentials, financial data, and personal information are never transmitted in plain text.
• Data-at-rest encryption: Stored databases containing personal data are encrypted. Even in the unlikely event of a server breach, data would not be readable without the encryption keys.
• Access controls: Access to player data within but 939 is restricted on a strict need-to-know basis. Support agents can see what they need to help you. They cannot see financial account numbers or full CNIC details without specific authorisation.
• Fraud monitoring: but 939 runs real-time fraud monitoring systems that flag unusual login activity, suspicious transaction patterns, and potential account compromise attempts. Flagged activity triggers immediate review.
• Two-factor authentication: Players are encouraged to enable two-factor authentication (2FA) on their but 939 accounts. 2FA adds a layer of security that significantly reduces the risk of unauthorised account access.

As a player on but 939, you have specific rights regarding your personal data. We take these rights seriously and have processes in place to respond to every request. To exercise any of the rights below, contact support@but939.com with the subject line "Data Rights Request."

Data related to your use of responsible gaming tools on but 939 is treated with heightened care. This includes deposit limits you have set, self-exclusion requests, session time limits, and any welfare-related communications with but 939's responsible gaming team.

• Responsible gaming data is stored separately from your standard account data and is accessible only to specifically authorised staff.
• Self-exclusion data is retained for a minimum of five years after the exclusion period ends to prevent re-registration during any ongoing welfare concern.
• but 939 will never use responsible gaming data to discriminate against a player in terms of service access, game availability, or promotional offers.
• If you have set a self-exclusion on but 939 and attempt to re-register, our systems will flag this automatically and the re-registration will be prevented.

For more information about our responsible gaming tools, including how to set limits, take breaks, or self-exclude, please visit our Responsible Gaming page.

but 939 is strictly for adults aged 18 and over. The platform does not knowingly collect personal data from anyone under 18. Age verification checks are performed as part of the registration process, and additional verification may be requested at any time.

If but 939 becomes aware that personal data has been collected from a person under 18, that account will be suspended immediately. All data associated with the account will be deleted unless retention is required for legal compliance purposes such as documenting the underage access attempt for regulatory purposes.

but 939 reviews this Privacy Policy regularly to ensure it remains accurate and up to date. When material changes are made, we will notify registered players by email and display a prominent notice on the platform the next time you log in. The updated policy will be published on this page with a revised "Last Updated" date.

Continued use of but 939 after a policy update constitutes acceptance of the updated Privacy Policy. If you do not accept the updated policy, you should close your account and contact us to request deletion of your data.

For any questions, concerns, or requests related to your personal data and but 939's privacy practices, our team is available 24/7:

• Email: support@but939.com — use subject line "Privacy Query" for fastest routing
• Live Chat: Available on every page of but 939 around the clock
• Data Rights Requests: Email support@but939.com with subject "Data Rights Request" — acknowledged within 72 hours, full response within 7 working days
• FAQ: Common privacy questions are answered on our FAQ page

Our support and privacy team respond in plain, clear English. If you are not satisfied with our response to a privacy concern, you have the right to escalate your complaint to the relevant data protection authority in your jurisdiction.