we939 Privacy Policy

1 Who We Are

This Privacy Policy is issued by we939, the operator of the online casino and sports betting platform accessible at we939.net. we939 acts as the data controller in respect of the personal information you provide when registering an account, making transactions, or otherwise interacting with the we939 platform.

References in this Policy to "we939", "we", "us", or "our" refer to the operating entity responsible for the we939 platform. References to "you", "your", or "member" refer to any individual who accesses, registers on, or transacts through the we939 platform.

This Privacy Policy should be read in conjunction with the we939 Terms & Conditions, which govern the broader contractual relationship between you and we939.

2 Data We Collect

we939 collects personal data across several categories depending on how you interact with the platform. The table below summarises what we collect and why:

3 How We Collect Data

we939 collects your personal data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the we939 platform, including through cookies, server logs, and similar tracking technologies (see Section 8 for cookie details).
• Third-party verification services: Identity and fraud-check data received from KYC verification providers, payment processors (including JazzCash and EasyPaisa APIs), and financial crime screening services.
• Public sources: In limited circumstances, we may cross-reference publicly available information — such as sanctions lists or politically exposed persons (PEP) databases — as part of our regulatory compliance obligations.

4 Purpose & Legal Basis

we939 processes your personal data only when a valid legal basis exists to do so. The primary bases on which we rely are as follows:

• Contract performance: Processing necessary to open and maintain your we939 account, process deposits and withdrawals, and deliver the gaming and betting services you have signed up for.
• Legal obligation: Processing required to comply with anti-money-laundering (AML) regulations, KYC obligations, age verification requirements, and reporting obligations to relevant regulatory authorities.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics — provided these interests are not overridden by your own rights and freedoms.
• Consent: Processing for optional marketing communications, where you have explicitly opted in. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

5 Data Sharing & Disclosure

we939 does not sell, rent, or commercially trade your personal data. We share your information only in the limited circumstances described below:

• Payment processors: Your financial data is shared with our nominated payment service providers — including JazzCash, EasyPaisa, and partner banks — solely to process your deposit and withdrawal instructions. These providers operate under strict contractual data protection obligations.
• KYC and identity verification providers: Identity documents and supporting information are shared with our accredited KYC verification partners for the sole purpose of fulfilling our age verification and identity confirmation obligations.
• Fraud prevention and AML screening services: Technical and financial data may be shared with fraud detection platforms and financial crime screening databases to protect the integrity of the we939 platform and comply with AML regulations.
• Game software providers: Certain usage data (such as game session IDs and wager amounts) may be shared with we939's licensed game software providers for technical reconciliation, RNG certification, and dispute resolution purposes.
• Regulatory and law enforcement authorities: we939 will disclose personal data to competent regulatory bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or regulatory direction. Where legally permissible, we939 will notify you of such disclosure.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or part of we939's business, personal data held by we939 may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third parties with whom we939 shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose beyond the specific service they provide to we939.

6 International Transfers

As an internationally operated platform serving members in Pakistan and other regions, we939 may transfer your personal data to servers or service providers located outside your country of residence. Where such transfers occur, we939 ensures that adequate safeguards are in place — including standard contractual clauses or equivalent data transfer mechanisms — to protect your personal data to a standard no less rigorous than the protections described in this Policy.

7 Data Retention

we939 retains your personal data for as long as your account remains active and for such additional periods as are required by applicable law and our regulatory obligations. Specific retention periods apply as follows:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, as required by AML and gaming regulatory obligations.
• Transaction records: Retained for a minimum of five (5) years following the date of the relevant transaction.
• Customer support communications: Retained for three (3) years following case closure, or longer if the communication is relevant to an ongoing dispute or regulatory inquiry.
• Technical and usage logs: Retained for up to twelve (12) months from the date of collection unless a longer retention period is required for security investigations or regulatory reporting.
• Marketing consent records: Retained for the duration of your opt-in consent and for two (2) years following withdrawal of consent, as proof of compliance.

Upon expiry of the applicable retention period, we939 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

8 Cookies & Tracking Technologies

we939 uses cookies and similar technologies (such as local storage objects and session tokens) on the we939 platform. These technologies serve the following specific purposes:

• Essential cookies: Required for the platform to function correctly, including maintaining your logged-in session, storing your language and display preferences, and enabling secure transactions. These cookies cannot be disabled without impairing platform functionality.
• Performance cookies: Used to measure how members interact with the platform — such as page load times, error rates, and navigation patterns — to allow we939 to identify and fix technical issues.
• Security cookies: Used to detect and prevent fraudulent login attempts, bot activity, and session hijacking.

we939 does not use advertising cookies, retargeting pixels, or cross-site tracking technologies. We do not share cookie data with advertising networks or data brokers.

You may disable non-essential cookies through your web browser settings at any time. Please note that disabling essential cookies will affect the functionality of your we939 account session.

9 Security Measures

we939 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the we939 platform.
• AES-256 encryption for personal and financial data stored in we939's database infrastructure.
• Role-based access controls limiting internal access to personal data strictly to authorised personnel with a documented operational need.
• Continuous automated monitoring and intrusion detection across we939's server infrastructure.
• Regular independent security audits and penetration testing of the we939 platform.
• Multi-factor authentication (MFA) requirements for administrative access to systems holding personal data.

10 Your Rights

Depending on the data protection laws applicable in your jurisdiction, you may hold some or all of the following rights in respect of your personal data held by we939:

• Right of access: You may request a copy of the personal data we939 holds about you, along with information about how it is being processed.
• Right to rectification: You may request correction of inaccurate or incomplete personal data held by we939.
• Right to erasure: You may request deletion of your personal data where we939 no longer has a lawful basis to retain it. Note that this right is subject to overriding legal and regulatory retention obligations.
• Right to restrict processing: You may request that we939 limit the processing of your personal data in certain circumstances — for example, while the accuracy of data you have contested is being verified.
• Right to data portability: You may request that we939 provide your personal data in a structured, machine-readable format for transfer to another controller, where technically feasible.
• Right to object: You may object to processing of your personal data where we939 relies on legitimate interests as the legal basis, unless we939 can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact the we939 support team via live chat or the contact details in Section 14. we939 will respond to verified data rights requests within 30 calendar days of receipt.

11 Children & Minors

The we939 platform is strictly intended for adults aged 21 and above. we939 does not knowingly collect personal data from any person under the age of 21. The platform employs mandatory age verification at the point of registration and at the withdrawal stage.

If we939 becomes aware that personal data has been collected from an individual under 21 years of age, we will immediately suspend the relevant account, void any associated balances or winnings, and securely delete the minor's personal data from our systems. Any deposits received from a minor will be returned to the source payment method.

If you believe that a minor has registered a we939 account, please notify our support team immediately via live chat so that we can investigate and take prompt action.

12 Third-Party Links

The we939 platform may contain references or links to third-party services — such as payment providers or game software suppliers — which operate under their own privacy policies. we939 is not responsible for the privacy practices of third-party operators and encourages you to review the privacy policy of any third-party service you interact with directly.

The presence of a third-party reference on the we939 platform does not constitute an endorsement of that party's data practices by we939.

13 Policy Amendments

we939 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes to this Policy will be communicated to registered members via email notification or a prominent notice on the we939 platform prior to the effective date of the change, where reasonably practicable.

The most current version of this Privacy Policy will always be available at we939.net/privacy-policy. The "Last Updated" date at the top of this document indicates when the most recent revision was made. Continued use of the we939 platform following publication of an updated Policy constitutes your acceptance of the revised terms.

14 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data we939 holds about you, please contact us through the following channels:

• Live Chat: Available 24/7 directly through the we939 platform — average response time under 3 minutes.
• Email: [email protected]

we939 will acknowledge privacy-related correspondence within 48 hours and will endeavour to resolve all data rights requests within 30 calendar days. Where a request is complex or we have received a high volume of requests, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

If you are unsatisfied with we939's handling of your personal data or your data rights request, you have the right to lodge a complaint with the relevant supervisory authority or independent dispute resolution body in your jurisdiction.