393bat Privacy Policy

This Privacy Policy ("Policy") is published by the operator of the 393bat platform ("393bat", "we", "us", "our"), accessible at https://393bat.cam and any associated mobile interfaces or applications (collectively, the "Platform"). It applies to all individuals who visit, register on or interact with the Platform ("User", "you", "your").

393bat is committed to processing personal data responsibly, transparently and in accordance with applicable data protection legislation. This Policy describes what personal information we collect, why we collect it, how we use it, with whom we share it and how long we keep it — and it explains the rights you hold in relation to your data.

By registering an Account or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform.

For the purposes of this Policy, the following terms have the meanings assigned below:

The Data Controller responsible for your Personal Data in connection with the 393bat Platform is the operator entity identified in the Terms and Conditions. For enquiries about how your data is processed, or to exercise any of the rights described in Section 12 of this Policy, please contact the support team using the details provided in Section 16.

393bat does not represent itself as being regulated by, affiliated with, or endorsed by any Pakistani governmental body, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan (SBP), or any Pakistani provincial authority for data-protection purposes. Users should be aware that data-protection oversight in their jurisdiction may differ from the framework applied by the operator.

393bat collects Personal Data across several categories, depending on the nature of your interaction with the Platform:

4.1 Registration Data

• Full name as provided during registration.
• Date of birth (used for age verification).
• Email address and/or mobile telephone number.
• Username and encrypted password credentials.
• Country of residence and city (for example, Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar).

4.2 KYC and Identity Verification Data

• Government-issued photo identification (CNIC, passport or driving licence — document number, issuing authority, expiry date and photograph).
• Proof of residential address (utility bill, bank statement or similar, dated within three months).
• Source-of-funds documentation where required by our compliance framework.

4.3 Financial and Transaction Data

• Deposit and withdrawal transaction records including amounts (denominated in PKR), timestamps and payment-method type references.
• Partial payment identifiers where provided by payment processors (393bat does not store full card numbers, full mobile wallet account numbers or banking credentials).

4.4 Usage and Technical Data

• IP address and approximate geolocation derived from IP.
• Device type, operating system, browser version and screen resolution.
• Session start and end times, pages visited, sports markets or game types accessed.
• Wagering activity records — bet history, stake amounts, outcomes — required for responsible gambling monitoring and dispute resolution.

4.5 Communications Data

• Content of live chat, email or support ticket communications you initiate with the 393bat support team.
• Records of consent given (for example, acceptance of Terms or marketing preferences).

Personal Data collected by 393bat is used for the following purposes:

393bat does not use your Personal Data to build advertising profiles, deliver targeted third-party advertising or sell data to data brokers or marketing agencies.

Where internationally recognised data protection frameworks apply, 393bat relies on the following legal bases to process your Personal Data:

• Contractual necessity: Processing required to enter into and perform the User Agreement with you — including account registration, payment processing and wagering operations.
• Legal obligation: Processing required to comply with applicable regulatory, AML, KYC and age-verification requirements binding on the operator.
• Legitimate interests: Processing for fraud detection, security monitoring, platform improvement and responsible gambling enforcement, where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where processing is based on consent — for example, optional analytics cookies or marketing communications — you may withdraw consent at any time by contacting the support team or adjusting your account preferences. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

393bat does not sell or rent your Personal Data. We may share your data with the following categories of recipient only to the extent necessary for the stated purpose:

• Payment Processors: Third-party payment facilitators (which may include gateways associated with Easypaisa, JazzCash, Raast, bank networks and crypto processors) receive the transaction and identity data strictly required to process your deposit or withdrawal. These processors operate under their own privacy policies and data protection terms.
• KYC and Identity Verification Providers: Specialist third-party document verification services that assist with age verification and identity checks. Data shared is limited to what is required to complete the verification check.
• Game Content Providers: Where game software is provided by third-party studios, session and gameplay data may be transmitted to those providers solely for game delivery, RTP calculation and fair-play audit purposes.
• Regulatory and Law Enforcement Authorities: Where required by a lawful order or applicable regulatory obligation, we may disclose Personal Data to competent authorities. We will notify you of such disclosure where legally permitted to do so.
• Professional Advisors: Legal, audit and compliance advisors bound by professional confidentiality obligations, where access is necessary to provide advisory services to 393bat.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of the operator's business, Personal Data may be transferred to the successor entity subject to equivalent privacy protections.

8.1  The 393bat Platform may operate infrastructure or engage service providers located outside Pakistan. As a result, your Personal Data may be transferred to, stored in or processed in a jurisdiction other than the one in which you reside.

8.2  Where Personal Data is transferred internationally, 393bat takes reasonable steps to ensure that appropriate safeguards are in place — such as contractual data processing agreements — to provide a level of protection that is substantially equivalent to the protections applicable in the data's country of origin.

8.3  By using the Platform, you acknowledge and agree to the international transfer of your Personal Data on the basis described in this section.

9.1  393bat uses cookies and similar technologies on the Platform. Cookies are small text files stored on your device that help the Platform function correctly and enable us to understand how the Platform is used.

The categories of cookies used on 393bat are described below:

9.2  You may control cookie behaviour through your browser settings. Disabling essential or functional cookies may impair the Platform's functionality. Disabling analytics cookies does not affect your ability to use the Platform.

10.1  Personal Data is retained for no longer than is necessary to fulfil the purpose for which it was collected, subject to any applicable legal or regulatory retention obligations that may require or permit extended retention.

10.2  Indicative retention periods are as follows:

• Account and KYC data: Retained for the duration of the Account relationship and for a further period of at least five (5) years following Account closure, consistent with standard AML record-keeping requirements.
• Transaction records: Retained for at least five (5) years from the date of the transaction.
• Support communications: Retained for a reasonable period sufficient to resolve disputes and comply with applicable requirements — typically two (2) to three (3) years.
• Analytics data: Aggregated or anonymised analytics data may be retained indefinitely as it no longer constitutes Personal Data once anonymised.

10.3  On expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be used to identify you.

11.1  393bat implements technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration, accidental loss or destruction. These include, but are not limited to, encrypted data storage, transport layer security (TLS/HTTPS) for data in transit, access controls limiting staff access to Personal Data on a need-to-know basis, and regular security reviews.

11.2  No method of electronic transmission or storage is completely secure. While we apply commercially reasonable measures, we cannot guarantee absolute security and disclaim liability for unauthorised access that occurs despite those measures, except where such access is directly attributable to our own negligence.

11.3  You are responsible for maintaining the security of your Account credentials. You must not share your login details with any third party. In the event of a suspected security breach affecting your Account, please contact the 393bat support team immediately.

Subject to applicable law and the limitations described in this Policy, you may hold the following rights in respect of your Personal Data held by 393bat:

• Right of Access: You may request confirmation of whether we hold Personal Data about you and a copy of that data.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data held about you.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected — subject to our legal retention obligations, which may require us to retain certain data even following such a request.
• Right to Restriction: You may request that processing of your Personal Data be restricted in certain circumstances — for example, while accuracy is being contested.
• Right to Data Portability: Where technically feasible and where processing is based on consent or contractual necessity, you may request a copy of your Personal Data in a structured, machine-readable format.
• Right to Object: You may object to processing based on our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact the 393bat support team using the details in Section 16. We will respond within a reasonable timeframe, and in any event within thirty (30) days of receiving a verifiable request. We may need to verify your identity before processing your request.

The 393bat Platform is strictly for adults aged 18 and above — or the higher minimum age required by the operator or applicable license jurisdiction. We do not knowingly collect Personal Data from persons under the age of 18. If we become aware that Personal Data has been collected from an underage user, we will take immediate steps to delete that data and close the associated Account.

If you believe that a minor has registered on 393bat or has accessed the Platform via your Account, please contact the support team immediately so that the matter can be investigated and addressed.

The 393bat Platform does not contain links to external third-party websites in its main navigation or primary content areas by design. Where references to third-party payment processors, game providers or responsible gambling resources appear on the Platform, those third parties operate under their own privacy policies. 393bat is not responsible for the privacy practices of any third-party service provider and encourages users to review the privacy policy of any third-party service they interact with independently.

15.1  393bat reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered Users via a Platform notification or email to the address associated with your Account, with a reasonable notice period before changes take effect.

15.2  The version of this Policy bearing the most recent "Last reviewed" date displayed at the top of this page is the version currently in force.

15.3  Your continued use of the Platform following the effective date of any material amendment constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you must cease using the Platform and contact support to close your Account.

If you have questions, concerns or requests in relation to this Privacy Policy or the processing of your Personal Data, please contact the 393bat support team through the following channels:

• Live Chat: Available on the Platform as per operator-confirmed hours. Target response time: under 3 minutes during business hours.
• Email (plain text — not a link): [email protected]

When submitting a data rights request, please include your registered username and a clear description of your request to allow prompt and accurate processing. We may need to verify your identity before actioning your request, in order to protect the security of your Account.