Privacy Policy

1 Introduction

Win939 ("Win939", "we", "us", "our") operates the online gaming and sports betting information platform accessible at https://win939.cam (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who access or use the Platform ("you", "your", "User").

This Privacy Policy ("Policy") describes how Win939 collects, uses, stores, shares and protects personal data in connection with your use of the Platform. It also sets out the rights available to you in relation to your personal data and how you may exercise those rights.

By accessing or using the Win939 Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree with any part of this Policy, you should cease using the Platform immediately.

2 Definitions

In this Policy, the following definitions apply:

• "CNIC" means Computerised National Identity Card — the primary identity document issued to Pakistani citizens by NADRA.
• "Controller" means the entity that determines the purposes and means of processing personal data — in this case, Win939.
• "Personal Data" means any information relating to an identified or identifiable natural person, including names, email addresses, CNIC numbers, IP addresses and device identifiers.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure or deletion.
• "Processor" means a third party that processes personal data on behalf of Win939 in accordance with this Policy and applicable data-processing agreements.
• "Sensitive Data" means personal data revealing racial or ethnic origin, political opinions, religious beliefs, health data or biometric data used for unique identification.
• "User" means any individual who accesses, browses or uses the Win939 Platform, whether or not they are registered.

3 Data We Collect

Win939 collects personal data in the following categories:

3.1 Registration & Account Data

When you create an account on Win939, we collect:

• Full legal name;
• Date of birth;
• Residential address (including city — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar);
• Email address;
• Phone number (where provided);
• Username and encrypted password hash.

3.2 Identity Verification (KYC) Data

To comply with KYC and AML obligations, we may collect copies of identity and address verification documents, which may include:

• CNIC (both sides) or valid Pakistani passport;
• Proof-of-address document (e.g., utility bill or bank statement);
• Selfie photograph or liveness-check image for facial verification.

3.3 Financial Transaction Data

We collect records of deposits, withdrawals and associated transaction metadata. Where payment method references are involved (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah), we record the method type and transaction reference — not full account credentials. These payment names are contextual references only and do not imply endorsement of gambling by those providers.

3.4 Technical & Usage Data

We automatically collect technical data when you use the Platform, including:

• IP address and approximate geolocation derived from IP;
• Browser type, version and operating system;
• Device type and device identifiers;
• Pages visited, session duration and clickstream data;
• Referring URL and search terms (where applicable).

3.5 Communications Data

When you contact Win939 support via email or live chat, we retain a record of the communication, including the content of your message and any supporting information you provide, for the purposes of responding to your query and maintaining our support records.

3.6 Data We Do Not Collect

Win939 does not intentionally collect sensitive data categories (such as health data, religious beliefs or political opinions) and does not collect full payment card numbers or bank account credentials. If you inadvertently submit sensitive data, we will delete it promptly upon becoming aware.

4 How We Process Your Data

Win939 processes your personal data for the following purposes:

• Account management: creating, maintaining and administering your Win939 account;
• Identity and age verification: conducting KYC checks to confirm your identity, age and eligibility;
• Transaction processing: facilitating deposits and withdrawals;
• AML and fraud prevention: monitoring transactions and user activity to detect and prevent money laundering, fraud and other prohibited conduct;
• Responsible gambling: monitoring account activity to identify patterns consistent with problem gambling and to enforce responsible gambling controls;
• Customer support: responding to queries, complaints and support requests;
• Platform improvement: analysing usage data to improve the performance, security and functionality of the Platform;
• Legal and regulatory compliance: complying with applicable legal, regulatory and reporting obligations;
• Marketing communications: sending promotional information about Win939 offers where you have opted in and subject to your preferences.

5 Legal Basis for Processing

Win939 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: processing required to perform our contractual obligations to you under the Terms and Conditions, including account management and transaction processing;
• Legal obligation: processing required to comply with applicable legal and regulatory requirements, including KYC, AML and fraud-prevention obligations;
• Legitimate interests: processing necessary for Win939's legitimate business interests, including Platform security, fraud prevention and business analytics, where those interests are not overridden by your fundamental rights and freedoms;
• Consent: processing based on your freely given, specific and informed consent, such as for direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

6 Sharing Your Data

Win939 does not sell your personal data to third parties. We may share your personal data only in the following circumstances:

6.1 Service Providers and Processors

We engage trusted third-party service providers to support the operation of the Platform — including KYC verification partners, payment processing infrastructure, cloud hosting providers, analytics services and customer support tools. These providers process personal data only on Win939's instructions and are bound by data-processing agreements that require them to maintain appropriate security standards.

6.2 Legal and Regulatory Disclosure

We may disclose personal data where required to do so by applicable law, court order, regulatory authority or law-enforcement agency. Where legally permitted, we will notify you of such disclosure in advance.

6.3 AML and Fraud Prevention

In connection with our AML obligations, Win939 may share relevant transaction and account data with designated financial intelligence units or competent authorities where suspicious activity is identified or reporting is otherwise required by law.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of Win939's business or assets, personal data held by Win939 may be transferred to the successor entity, subject to equivalent data protection commitments.

7 Data Retention

Win939 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations.

In practice, retention periods are as follows:

• Account data: retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements;
• KYC documentation: retained in accordance with applicable AML legislation, typically for a minimum of five (5) years from the date of the relevant transaction or the date of account closure, whichever is later;
• Transaction records: retained for a minimum of five (5) years in accordance with applicable AML and financial record-keeping obligations;
• Support communications: retained for up to two (2) years from the date of the relevant communication, unless a longer period is required for ongoing dispute resolution or legal proceedings;
• Technical and usage data: typically retained for up to thirteen (13) months for analytics purposes, after which it is aggregated or deleted.

When personal data is no longer required, it is securely deleted or irreversibly anonymised in accordance with Win939's data retention and disposal procedures.

8 Data Security

Win939 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit;
• Encrypted storage of sensitive data at rest;
• Role-based access controls limiting data access to authorised personnel only;
• Two-factor authentication requirements for staff access to sensitive systems;
• Regular security audits and penetration testing;
• Incident response procedures for data breaches, including user notification obligations where required by law.

Notwithstanding these measures, no method of electronic transmission or storage is completely secure. Win939 cannot guarantee the absolute security of your data and encourages you to maintain strong, unique passwords and to enable two-factor authentication on your account.

9 Cookies & Tracking Technologies

Win939 uses cookies, web beacons, pixel tags and similar tracking technologies on the Platform for the following purposes:

9.1 Essential Cookies

Essential cookies are strictly necessary for the Platform to function. They enable core services such as session management, account authentication and security features. These cookies cannot be disabled without materially affecting Platform functionality.

9.2 Analytics Cookies

Analytics cookies collect aggregated, anonymised information about how users interact with the Platform — such as pages visited, session duration and navigation paths. This data is used to improve Platform performance and user experience.

9.3 Preference Cookies

Preference cookies remember your Platform settings and preferences (such as language or display options) to deliver a more personalised experience across sessions.

9.4 Managing Cookies

You can manage and delete cookies through your browser settings at any time. Please note that disabling certain cookies may affect the availability of some Platform features. Details of how to manage cookies are available in your browser's help documentation.

10 International Data Transfers

As an online platform serving users including those in Pakistan, Win939 may transfer personal data to, and process it in, countries outside your jurisdiction. Where such transfers occur, Win939 ensures that appropriate safeguards are in place to protect your personal data, including contractual obligations on recipients that require data protection standards equivalent to those described in this Policy.

By using the Win939 Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions whose data protection laws may differ from those in your own country.

11 Your Rights

Subject to applicable law and certain legal limitations, you have the following rights in relation to your personal data held by Win939:

To exercise any of the above rights, please contact Win939 using the details set out in Section 15 of this Policy. We will acknowledge your request within a reasonable period and respond within the timeframe required by applicable law. We may need to verify your identity before processing your request.

12 Children & Minors

The Win939 Platform is strictly for adults aged 18 years and above, or the higher minimum age required by the operator's licence jurisdiction. Win939 does not knowingly collect personal data from minors. If we become aware that a minor has provided personal data to us without appropriate parental or guardian consent, we will delete that data promptly and close the relevant account.

If you are a parent or guardian and believe that a minor has registered on or provided personal data to Win939, please contact us immediately at the details set out in Section 15.

13 Third-Party Links & Services

The Win939 Platform may contain references to third-party services or may integrate third-party tools (such as analytics providers). Win939 is not responsible for the privacy practices of any third-party service providers and encourages you to review the privacy policies of any third-party services you access independently.

References to payment method names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on this Platform are made as familiar Pakistani payment context only. None of these providers are responsible for Win939's data practices, and Win939 does not share your Win939 account data with these providers beyond what is strictly necessary to process a specific transaction you have initiated.

14 Changes to This Policy

Win939 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or Platform functionality. When material changes are made, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered Users by email or account notification.

We encourage you to review this Policy periodically. Your continued use of the Win939 Platform following the publication of any revised Policy constitutes your acceptance of those changes.

15 Contact & Data Requests

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a privacy-related concern, please contact Win939's data team using the details below:

For identity verification purposes, we may require you to confirm your identity before actioning a data request. This is to protect your personal data from unauthorised third-party access.