Section 1
Introduction
This Privacy Policy describes how Game 939 ("Game 939", "we", "us", "our") collects, processes, stores, and protects the personal information of players who register and use the Game 939 platform at game939.app ("the Platform"). It applies to all registered players, including those who have registered but not yet made a deposit, and to visitors who browse the Platform without registering.
Game 939 is committed to protecting your privacy and processing your personal data in a responsible, transparent manner. We comply with applicable data protection laws and maintain strict internal policies governing how personal data is accessed and used within the organisation.
This policy was last updated on 1 June 2025. We recommend reading it in full, but the key highlights are covered in the summary section at the top of this page. If you have any questions after reading, contact us at support@game939.app.
Plain English commitment: We have written this policy to be as clear and readable as possible for Game 939 players in Pakistan. Legal language has been kept to a minimum. Where technical or legal terms are unavoidable, we have explained them in plain terms alongside.
Section 2
Personal Data We Collect
Game 939 collects personal data through several channels: directly from you when you register or use the Platform, automatically when you browse or play, and from third-party services we use to operate the Platform. Here is a breakdown of what is collected and from which source:
| Data Category |
Examples |
Source |
| Identity Data |
Full name, date of birth, CNIC number, passport number |
Provided by you at registration or KYC verification |
| Contact Data |
Mobile number, email address, city of residence |
Provided by you at registration |
| Financial Data |
JazzCash or Easypaisa account number, bank account IBAN, card last four digits |
Provided by you when making deposits or withdrawal requests |
| Account Activity Data |
Login history, game history, bet amounts, session duration, bonus usage |
Automatically collected when you use the Platform |
| Technical Data |
IP address, device type, operating system, browser type, screen resolution |
Automatically collected via browser and server logs |
| Communications Data |
Support chat transcripts, email correspondence, complaint records |
Generated when you contact Game 939 support |
| Verification Documents |
Scanned CNIC, selfie photographs, utility bills |
Provided by you during identity verification |
Game 939 does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information. If such information is incidentally included in a document you submit for verification purposes, it is not recorded separately and is not used for any purpose other than confirming the authenticity of the document.
Section 3
How Game 939 Uses Your Personal Data
Game 939 uses the personal data it collects for clearly defined purposes. We do not use your data for any purpose not listed here, and we do not use it in a way that would be incompatible with the purpose for which it was collected.
- Account Management: To create and maintain your Game 939 account, verify your identity, process your login, and manage your account settings and preferences.
- Payments Processing: To process your deposits and withdrawal requests accurately, reconcile transactions, and investigate and resolve any payment disputes.
- Identity Verification (KYC): To verify that you are who you say you are, that you are of legal age to gamble, and to satisfy anti-money laundering obligations as required by applicable regulations.
- Platform Personalisation: To remember your preferred language, stake settings, and game history so that your Game 939 experience is consistent across sessions and devices.
- Fraud and Security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, bonus abuse, and other security threats to the Platform and to other players.
- Responsible Gaming: To monitor account activity for signs of problem gambling and to enforce deposit limits, cooling-off periods, and self-exclusion settings that you have configured.
- Customer Support: To receive and respond to your support requests, complaints, and queries, and to maintain a record of communications for quality assurance.
- Legal Compliance: To comply with applicable laws, regulatory requirements, and lawful requests from government authorities or law enforcement agencies.
- Marketing Communications: To send you promotional emails or in-platform messages about Game 939 bonuses, new games, and relevant offers — but only where you have given consent to receive marketing communications. You can withdraw consent at any time.
- Platform Improvement: To analyse aggregated, anonymised usage data to understand how players use the Platform and to improve the user experience, fix bugs, and optimise performance.
Marketing opt-out: If you no longer wish to receive promotional communications from Game 939, you can unsubscribe at any time by clicking the unsubscribe link in any marketing email, or by updating your contact preferences from within your Game 939 account settings. Opting out of marketing does not affect transactional communications such as deposit confirmations, withdrawal notifications, or security alerts.
Section 4
Legal Basis for Processing
Game 939 processes personal data on the following legal grounds:
- Contract Performance: Processing your identity, payment, and account data is necessary to deliver the services you have contracted for by registering a Game 939 account and agreeing to our Terms and Conditions.
- Legal Obligation: Identity verification, anti-money laundering checks, and certain record-keeping obligations are required by law. Game 939 is legally obligated to carry out these activities regardless of individual consent.
- Legitimate Interest: Fraud detection, platform security, and technical data analysis serve the legitimate interests of Game 939 and its player community. These interests do not override the fundamental rights of individual players.
- Consent: Marketing communications are sent only where you have explicitly consented to receive them. You may withdraw this consent at any time without affecting your ability to use the Platform.
Section 5
Sharing Your Data With Third Parties
Game 939 does not sell your personal data. We share it only where necessary to operate the Platform, comply with legal obligations, or protect the security of the platform and its players. The categories of third parties who may receive your data are:
- Payment Processors: JazzCash, Easypaisa, NayaPay, SadaPay, IBFT banking partners, and Visa/Mastercard acquiring banks receive the transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and applicable financial regulations.
- Identity Verification Providers: Third-party KYC and anti-money laundering service providers may receive your identity documents and personal details to perform verification checks on behalf of Game 939. These providers are contractually obligated to process this data only for verification purposes.
- Live Casino Studio Providers: When you play live casino games, the studio provider (such as Evolution Gaming or Pragmatic Play Live) receives your player session data — a pseudonymous player ID, your bets, and game history — to operate the live table. They do not receive your name, CNIC, or payment details.
- Fraud Prevention Services: Specialist fraud detection providers may receive technical data such as IP address, device fingerprint, and account activity patterns to identify and flag suspicious behaviour.
- Legal and Regulatory Authorities: Game 939 may disclose personal data to government bodies, law enforcement agencies, or regulatory authorities where required by law or in response to a valid legal request.
- Professional Advisers: Legal counsel, auditors, and accountants may have access to personal data as part of their professional engagement with Game 939, subject to strict confidentiality obligations.
No advertising networks: Game 939 does not share your personal data with online advertising networks, social media platforms, or any third party for the purpose of targeting you with advertisements on other websites or apps.
Section 6
Payment Data and Financial Information
Game 939 handles financial data with particular care given its sensitive nature. Here is specifically how your payment information is managed on the Game 939 platform:
- Game 939 does not store full card numbers on its own servers. Card payment data is processed and tokenised by our PCI-DSS compliant payment processor. Game 939 retains only the last four digits of a card for display purposes.
- JazzCash and Easypaisa account numbers are stored in encrypted form and are accessible only to the payments operations team for the purpose of processing withdrawal requests.
- All financial transactions are logged with timestamps, amounts, and transaction reference numbers for reconciliation, dispute resolution, and regulatory audit purposes.
- Game 939 does not send any financial data in unencrypted form. All payment data in transit is protected by TLS 1.2 or higher.
If you believe an unauthorised transaction has been made from your Game 939 account, contact support@game939.app immediately. Game 939 will investigate promptly and, where the transaction is confirmed to be fraudulent, take appropriate action including account suspension and law enforcement notification where warranted.
Section 7
How Long We Keep Your Data
Game 939 retains personal data only for as long as necessary to fulfil the purpose for which it was collected or as required by law. Our retention guidelines are as follows:
| Data Type |
Retention Period |
Reason |
| Account registration data |
Duration of active account + 5 years after closure |
Regulatory and anti-money laundering obligations |
| Transaction records |
7 years from transaction date |
Financial record-keeping requirements |
| Identity verification documents |
5 years after account closure |
KYC regulatory requirements |
| Support communications |
3 years from last interaction |
Dispute resolution and quality assurance |
| Technical and device logs |
12 months |
Security monitoring and fraud detection |
| Marketing preference records |
Until consent is withdrawn + 1 year |
Proof of consent for regulatory purposes |
After the applicable retention period, personal data is securely and permanently deleted from Game 939 systems. Anonymised aggregate data — such as total number of bets placed in a month — may be retained indefinitely as it contains no personal identifiers.
Section 8
How We Protect Your Data
Game 939 applies a multi-layered approach to data security. The following measures are in place to protect your personal information:
- Encryption in Transit: All data transmitted between your device and Game 939 servers is encrypted using TLS 1.2 or TLS 1.3. This includes login credentials, payment data, and any personal information you enter on the Platform.
- Encryption at Rest: Personal data stored on Game 939 servers is encrypted using industry-standard algorithms. Even in the unlikely event of a server breach, stored data would not be readable without the encryption keys.
- Access Controls: Access to personal data within the Game 939 organisation is restricted on a need-to-know basis. Staff members can only access the data relevant to their specific job function. All access is logged and reviewed.
- Two-Factor Authentication: Game 939 supports and recommends enabling two-factor authentication on your account, adding an additional layer of protection against unauthorised access.
- Regular Security Audits: Game 939 conducts regular internal and third-party security assessments to identify and address vulnerabilities before they can be exploited.
- Incident Response: In the event of a data breach that poses a risk to your personal data, Game 939 will notify affected players and relevant authorities within 72 hours of becoming aware of the incident, in line with applicable notification requirements.
Your responsibility: While Game 939 takes every reasonable measure to secure your data on its end, the security of your account also depends on you keeping your login credentials private. Never share your password with anyone. Use a strong, unique password for your Game 939 account and change it immediately if you suspect it has been compromised.
Section 9
Cookies and Tracking Technologies
Game 939 uses cookies and similar tracking technologies to operate the Platform effectively and to improve your experience. Cookies are small text files stored on your device by your browser when you visit a website. Here are the types of cookies Game 939 uses:
Essential Cookies
Required for the Platform to function. These cookies maintain your login session, remember your language setting, and keep your game session active. They cannot be disabled without breaking core functionality. No consent is required for essential cookies.
Analytics Cookies
Used to collect anonymised data about how players use the Platform — which pages are visited most, how long sessions last, where players navigate from. This data helps Game 939 improve the user experience. These cookies require your consent.
Preference Cookies
Remember your personalisation choices such as preferred game category, stake defaults, and display settings. Without these cookies, your preferences would reset every time you log in.
Security Cookies
Used to detect and prevent fraudulent activity. These cookies help identify suspicious login patterns, device spoofing, and other security threats. They are essential for protecting your account and the accounts of other players on Game 939.
You can control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the Game 939 Platform. For full details on managing cookies in your browser, refer to your browser's help documentation.
Section 10
Your Privacy Rights
As a Game 939 player, you have the following rights over your personal data. Most of these can be exercised directly from your account settings without needing to contact support:
Right of Access
Request a copy of all personal data Game 939 holds about you. We will provide this in a readable format within 30 days of a verified request.
Right of Rectification
Request correction of inaccurate or incomplete personal data. You can update most contact details directly from account settings; other corrections require a support request.
Right of Erasure
Request deletion of your personal data where it is no longer necessary for the purpose collected. Note that data required for legal compliance — such as transaction records — cannot be deleted during the mandatory retention period.
Right to Restrict Processing
Request that Game 939 limits the way it uses your data — for example, while a dispute about accuracy is being resolved — without deleting it entirely.
Right to Data Portability
Request your personal data in a structured, machine-readable format that you can transfer to another service. This applies to data you have actively provided to Game 939.
Right to Object
Object to Game 939 processing your data on the basis of legitimate interests, including profiling. You can always object to marketing communications by opting out via account settings or any marketing email.
To exercise any of these rights, submit a request to support@game939.app with the subject line "Privacy Request". Game 939 will verify your identity before processing the request and will respond within 30 days. In complex cases, the response period may be extended to 60 days — you will be informed if this applies to your request.
Section 11
Children and Minors
Game 939 is strictly for adults aged 18 years and over. The Platform is not directed at, and does not knowingly collect personal data from, individuals under the age of 18. Age verification is performed at registration and again before a player's first withdrawal is processed.
If Game 939 discovers that personal data has been collected from an individual under 18 — whether through a false declaration of age or any other means — the account will be immediately closed, all balances forfeited, and the personal data deleted in accordance with our retention policy. Any deposits made to the account will be returned to the payment method used.
If you are a parent or guardian and believe that your child has registered a Game 939 account, please contact support@game939.app immediately with details of the account so that it can be investigated and closed promptly.
Section 12
Changes to This Privacy Policy
Game 939 may update this Privacy Policy from time to time to reflect changes in our practices, applicable laws, or the services we offer. When material changes are made, we will notify registered players by email to their registered address and/or by in-platform notification at least 7 days before the changes take effect.
The "Last Updated" date at the top of this page always reflects the date of the most recent revision. We encourage you to review this policy periodically. Continued use of the Game 939 Platform after a Privacy Policy update constitutes your acceptance of the revised policy. If you do not accept the changes, you should stop using the Platform and may request account closure.
No surprises: Game 939 will never change this policy in a way that reduces your privacy rights without giving you advance notice and the opportunity to close your account before the changes take effect. Your trust matters to us more than any operational convenience.
