bat399 Privacy Policy

Introduction

bat399 ("we", "us", "our") operates the online casino and sports betting platform accessible at bat399.onl (the "Platform"). In providing this Platform to Players in Pakistan and internationally, bat399 necessarily processes personal data about registered Players and, in limited circumstances, about visitors who browse the Platform without registering.

This Privacy Policy has been prepared in accordance with the data protection obligations applicable under bat399's international gaming licence and reflects globally recognised standards for the handling of personal data, including principles of transparency, data minimisation, purpose limitation, and data subject rights.

By registering a bat399 account, making a deposit, or otherwise using the Platform, you acknowledge that you have read this Privacy Policy in full and consent to the collection and use of your personal data as described herein. If you do not consent, you must not register or continue to use bat399.

Personal Data We Collect

bat399 collects personal data through several channels — directly from you during registration and account use, automatically through your interactions with the Platform, and from third-party verification and payment service providers. The categories of personal data we collect are as follows:

2.1 Registration & Identity Data

• Full legal name (as it appears on your CNIC or passport)
• Date of birth (used for mandatory 21+ age verification)
• Residential address in Pakistan (street, city, province)
• Pakistani mobile number (used for account authentication and communications)
• Email address (used for account notifications and support correspondence)
• Username and encrypted password (account access credentials)

2.2 Identity Verification (KYC) Data

• Scanned or photographed copy of your Pakistani CNIC or passport
• Proof of address documentation (utility bill or bank statement dated within 90 days)
• Payment method documentation (where required by anti-money laundering obligations)
• Selfie or liveness verification image (where required by KYC procedures)

2.3 Financial Transaction Data

• Deposit amounts, dates, and payment method references (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast/1LINK)
• Withdrawal requests, amounts, and destination payment method references
• PKR account balance history and bonus credit/debit records
• Chargeback or dispute records where applicable

2.4 Gaming Activity Data

• Bet history, game session records, wagering amounts, and outcomes across all casino and sports betting products
• Bonus participation records and wagering requirement progress
• Responsible gaming tool settings (deposit limits, self-exclusion status, session reminders)
• PSL and cricket betting market selections and stake history

2.5 Technical & Device Data

• IP address at the time of registration, login, and each gaming session
• Device type, operating system, and browser version
• Geolocation data (country and city level, derived from IP address)
• Session timestamps and duration
• Cookie identifiers and tracking pixel data (see Section 5)

2.6 Communications Data

• Content of emails, live chat transcripts, and support tickets submitted to bat399
• Responses to surveys or promotions where you have voluntarily participated
• Marketing preference records (opt-in and opt-out history)

2.7 Data Collected as a Table Reference

Legal Basis for Processing

bat399 processes your personal data only where a valid legal basis exists for doing so. The legal bases applicable to our processing activities are as follows:

• Contractual Necessity: The majority of our processing — including account registration, KYC verification, transaction processing, and game session recording — is necessary for the performance of our contract with you as a registered Player on bat399.
• Legal Obligation: bat399 is required by its gaming licence and applicable anti-money laundering regulations to collect, retain, and in certain circumstances disclose personal data. This includes identity verification records, financial transaction logs, and responsible gaming documentation.
• Legitimate Interests: bat399 processes certain technical data (IP addresses, device identifiers, session logs) on the basis of its legitimate interests in maintaining platform security, preventing fraud, and ensuring fair gaming. We have assessed these interests against your privacy rights and are satisfied that they do not override your fundamental data protection rights.
• Consent: Where bat399 sends you direct marketing communications (promotional emails, bonus notifications), we do so on the basis of your freely given and specific consent at the point of opt-in. You may withdraw this consent at any time without affecting your ability to use the Platform.

How We Use Your Personal Data

bat399 uses your personal data for the following specific purposes:

4.1 Account Management & Platform Access

To create, maintain, and secure your bat399 account; to verify your identity and age before activating withdrawal access; to authenticate your login sessions; and to communicate essential account notifications such as deposit confirmations, withdrawal status updates, and security alerts.

4.2 Transaction Processing

To process PKR deposits and withdrawals via JazzCash, EasyPaisa, Raast/1LINK, HBL, UBL, Meezan Bank, and retail cash deposit channels; to reconcile your account balance; to investigate and resolve payment disputes; and to comply with anti-money laundering record-keeping requirements.

4.3 Gaming Operations & Fair Play

To deliver casino games and sports betting markets; to record bet history and settle wagers; to apply bonus credits and track wagering requirement progress; to detect patterns of collusion, automated betting, or other prohibited conduct; and to enforce the Platform's responsible gaming tools including deposit limits and self-exclusion periods.

4.4 Regulatory Compliance & Anti-Fraud

To fulfil bat399's obligations under its gaming licence, including suspicious transaction reporting, player due diligence, and record retention requirements; to detect, investigate, and prevent fraud, money laundering, and other financial crimes; and to respond to lawful requests from regulatory authorities, financial intelligence units, or law enforcement bodies.

4.5 Customer Support

To respond to your support queries, complaints, and KYC submissions; to maintain records of communications for quality assurance and dispute resolution purposes; and to train support staff using anonymised interaction data where consent has been obtained.

4.6 Marketing & Promotions (Consent-Based Only)

Where you have opted in, to send you personalised promotional communications about bat399 bonuses, PSL cricket betting markets, new slot releases, and seasonal offers. bat399 will never sell your personal data to third-party marketers, and we will never send you marketing communications from unrelated businesses.

4.7 Platform Improvement & Analytics

To analyse aggregated and anonymised usage data to improve Platform performance, user experience, game selection, and the overall quality of the bat399 service. Individual Players are not identified in these analytics processes.

Cookies & Tracking Technologies

bat399 uses cookies and similar tracking technologies to enable core Platform functionality, maintain your logged-in session, and collect anonymised analytics data. The categories of cookies used on bat399.onl are as follows:

5.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be disabled. They include session authentication tokens, CSRF protection cookies, and load-balancing cookies. Without these cookies, core features such as login, deposit, and game loading will not function correctly.

5.2 Functional Cookies

These cookies remember your preferences, such as your selected game lobby filters, preferred language, and responsible gaming tool settings. They persist across sessions to improve your experience on the Platform.

5.3 Analytics Cookies

bat399 uses anonymised analytics cookies to understand aggregate user behaviour on the Platform — including which game categories are most popular, how Players navigate the lobby, and where technical errors most commonly occur. This data is used exclusively to improve the bat399 service and is never shared with third-party advertisers.

5.4 Managing Cookies

You may configure your browser to refuse or delete non-essential cookies at any time. Please note that disabling functional or analytics cookies will not prevent you from using the Platform, but may affect the persistence of your preferences. Disabling strictly necessary cookies will prevent login and is not recommended.

Data Sharing & Third-Party Disclosure

bat399 does not sell, rent, or trade your personal data to any third party. We share your personal data only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose:

• Payment Service Providers: We share transaction data (name, amount, payment reference) with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Raast/1LINK solely for the purpose of processing your deposits and withdrawals. These providers are contractually bound to process your data only for this purpose.
• KYC & Identity Verification Providers: bat399 uses a licensed third-party identity verification provider to assist with document review and biometric liveness checks during the KYC process. This provider processes your identity documents under a strict data processing agreement and does not retain your data beyond the verification period.
• Game Software Suppliers: Third-party game providers who supply casino games on the bat399 Platform receive limited session and bet data necessary to deliver and settle the game. These providers are licensed by recognised gaming authorities and are bound by their own privacy and data protection obligations.
• Regulatory Authorities: bat399 may be required to disclose Player data to its licensing authority, a financial intelligence unit, or law enforcement agency in response to a lawful order, regulatory investigation, or statutory reporting obligation. bat399 will notify you of such disclosure where legally permitted to do so.
• Fraud Prevention & AML Services: bat399 may share data with industry fraud prevention and anti-money laundering databases to screen for known fraudulent identities, sanctioned individuals, or politically exposed persons (PEPs). Such sharing is conducted under bat399's legal compliance obligations.
• Responsible Gaming Bodies: Where a Player has applied for self-exclusion or where bat399 is legally required to do so, we may share limited account status information with recognised responsible gaming networks to prevent circumvention of self-exclusion across multiple platforms.

Data Retention

bat399 retains your personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law and licensing obligations. The specific retention periods applicable to the principal categories of personal data are as follows:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with bat399's data destruction procedures. Anonymised aggregate data (from which no individual can be identified) may be retained indefinitely for statistical and analytics purposes.

Data Security

bat399 implements a layered technical and organisational security framework to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• TLS Encryption in Transit: All data transmitted between your device and bat399.onl is encrypted using Transport Layer Security (TLS 1.2 or higher). This includes login sessions, deposit flows, KYC document uploads, and all API communications.
• Encryption at Rest: Sensitive personal data stored in bat399's databases — including identity documents, payment references, and account credentials — is encrypted at rest using AES-256 or equivalent symmetric encryption.
• Access Controls: Access to Player personal data is restricted to bat399 personnel with a documented operational need. Access is governed by role-based permissions, multi-factor authentication requirements, and a formal access review process conducted quarterly.
• Security Audits: bat399 undergoes periodic security assessments including vulnerability scanning and penetration testing conducted by qualified independent security firms, as required under its gaming licence.
• Incident Response: bat399 maintains a documented data breach response plan. In the event of a security incident that materially affects your personal data, bat399 will notify affected Players and the relevant regulatory authority within the timeframes required by applicable law.
• Password Security: bat399 never stores passwords in plain text. Account passwords are stored as salted cryptographic hashes. bat399 will never ask you to disclose your password via any communication channel.

Your Data Subject Rights

As a data subject whose personal data is processed by bat399, you hold the following rights in relation to your personal information. bat399 is committed to honouring these rights promptly and without undue delay:

• Right of Access: You have the right to request a copy of all personal data bat399 holds about you, together with an explanation of the purposes for which it is processed and the categories of recipients with whom it has been shared.
• Right to Rectification: You have the right to request correction of any personal data held by bat399 that is inaccurate or incomplete. You may update certain account details directly through your bat399 profile; other corrections require a support request.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. Please note that this right is subject to limitations where bat399 has a legal obligation to retain the data (e.g., AML record-keeping requirements).
• Right to Restrict Processing: You have the right to request that bat399 restricts the processing of your personal data in certain circumstances — for example, while you contest the accuracy of data we hold, or while an objection to processing is being assessed.
• Right to Data Portability: You have the right to receive a structured, machine-readable copy of personal data you have provided to bat399, for the purpose of transferring it to another service provider, where technically feasible.
• Right to Object: You have the right to object at any time to the processing of your personal data on the basis of bat399's legitimate interests. You also have an unconditional right to object to processing for direct marketing purposes, which bat399 will honour immediately upon receipt.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, submit a written request to [email protected] with the subject line "DATA SUBJECT REQUEST". bat399 will acknowledge your request within two business days and aim to respond substantively within 30 calendar days. Where a request is complex or numerous, this period may be extended by a further 60 days, in which case bat399 will notify you of the extension and the reasons for it.

Children & Minors

bat399 does not knowingly collect personal data from any person under the age of 21. The Platform is strictly for adult users aged 21 and above. The 21+ minimum age restriction is actively enforced through the KYC verification process, which requires all Players to submit government-issued photo identification before withdrawal access is granted.

If bat399 becomes aware that personal data has been collected from a person under the age of 21, the following steps will be taken immediately:

• The associated account will be permanently closed without prior notice;
• All personal data associated with the underage account will be securely deleted to the extent permissible under applicable law and licensing obligations;
• Any deposits or winnings associated with the account will be handled in accordance with the requirements of the applicable gaming licence authority;
• The matter may be reported to the relevant licensing authority as required by licence conditions.

Updates to This Privacy Policy

bat399 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, licensing requirements, or Platform features. When material changes are made to the Policy, bat399 will notify registered Players by email to their registered address and will display a prominent notification on the Platform for a reasonable period prior to the updated Policy taking effect.

The effective date at the top of this page will be updated to reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how bat399 handles your personal data. Your continued use of the Platform after a revised Policy has been published and notified constitutes your acceptance of the updated terms.

If any update to this Policy materially diminishes your existing privacy rights and you do not accept the revised Policy, you should cease using the Platform and contact support at [email protected] to request account closure and the return of any verified real-money balance in your account.

Contact & Data Enquiries

For all privacy-related enquiries, data subject access requests, consent withdrawals, or complaints relating to bat399's handling of your personal data, please contact us through the following channel:

• Email: [email protected] — mark the subject line "PRIVACY ENQUIRY" or "DATA SUBJECT REQUEST" as appropriate
• Response Time: Acknowledgement within 2 business days; substantive response within 30 calendar days
• Support Hours: 24 hours a day, 7 days a week
• Language: English

If you are not satisfied with bat399's response to a privacy complaint, you have the right to escalate your complaint to the regulatory body under whose licence bat399 operates. Details of the applicable supervisory authority are available upon written request to [email protected].