Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by bat989 ("Platform", "we", "us", "our"), the operator of the online gaming platform accessible at https://bat989.cam. This Policy sets out how bat989 collects, uses, stores, shares and protects the personal information of individuals who access or register on the Platform ("Users", "you", "your").

By registering an account on bat989 you acknowledge that you have read this Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference.

2 Definitions

In this Policy the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, device identifiers and financial data.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, erasure and destruction.
• "Data Controller" — bat989, as the entity that determines the purposes and means of Processing Personal Data collected on the Platform.
• "Data Processor" — a third party that processes Personal Data on behalf of bat989 under a data processing agreement.
• "KYC" — Know Your Customer; the identity verification procedure required to activate full account functionality.
• "Cookie" — a small text file placed on your device by the Platform for identification, session management and analytics purposes.
• "PKR" — Pakistani Rupee; the currency in which Account balances are displayed.

3 Data We Collect

bat989 collects the following categories of personal data from Users:

4 How We Collect Data

bat989 collects personal data through the following mechanisms:

• Direct submission: Information you provide when registering an account, completing KYC, contacting support or submitting a responsible gambling request.
• Automated technical collection: Device data, IP addresses and session information collected automatically when you access the Platform.
• Cookies and similar technologies: See Section 9 for full details of our cookie practices.
• Third-party verification providers: Identity and age verification data returned by KYC service providers used by the Platform.
• Payment processing: Transaction confirmations and status updates provided by payment processors in connection with your deposits and withdrawals.

5 Data Processing

bat989 processes your personal data for the following purposes:

• Account management: Creating, maintaining and securing your registered account.
• Identity and age verification: Completing KYC checks to confirm you are eligible to use the Platform (18+ or higher minimum as required).
• Transaction processing: Facilitating deposits, withdrawals and bonus allocation in PKR.
• Fraud prevention and security: Detecting unauthorised account access, multi-accounting and financial crime.
• Regulatory compliance: Meeting anti-money laundering (AML), counter-terrorism financing (CTF) and responsible gambling obligations under applicable licensing requirements.
• Responsible gambling: Monitoring account activity to identify potential problem gambling behaviours and delivering limit tools or self-exclusion where requested.
• Customer support: Responding to queries, complaints and technical issues submitted by registered users.
• Platform improvement: Analysing aggregated usage data to improve the functionality, design and content of bat989.
• Marketing communications: Sending promotional communications where you have consented to receive them. You may withdraw this consent at any time by contacting support.

6 Legal Basis for Processing

bat989 processes your personal data on the following legal bases, which vary depending on the nature of the processing activity:

• Contractual necessity: Processing required to provide the services set out in our Terms & Conditions, including account management and transaction processing.
• Legal obligation: Processing required to comply with applicable anti-money laundering, KYC and licensing obligations.
• Legitimate interests: Processing for fraud prevention, security monitoring and platform improvement, where those interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications, where you have provided explicit consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7 Data Sharing

bat989 does not sell, rent or trade your personal data to third parties. Your data may be shared with third parties only in the following circumstances:

• Service providers: KYC verification providers, payment processors, fraud detection services and hosting infrastructure providers acting as Data Processors under binding data processing agreements.
• Gaming software providers: Game platform providers may receive technical session data required to operate their games within the bat989 environment.
• Regulatory authorities: Where required by applicable law, licensing obligations or a valid legal request from a competent authority.
• Legal proceedings: Where disclosure is necessary to establish, exercise or defend legal claims.
• Business transfers: In the event of a merger, acquisition or sale of the Platform, personal data may transfer to the successor entity subject to the same privacy protections.

All third-party service providers engaged by bat989 are subject to contractual obligations that require them to maintain appropriate security standards and to process your data only for the purpose for which it was shared.

8 Data Retention

bat989 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. General retention principles applied by the Platform are as follows:

• Active account data is retained for the duration of your registration plus any mandatory post-closure retention period required by applicable licensing or AML legislation.
• KYC documentation is retained for a minimum period determined by the Platform's regulatory obligations in its licensing jurisdiction.
• Financial transaction records are retained to meet AML reporting and audit requirements.
• Support communications are retained for a reasonable period to enable dispute resolution and quality assurance.
• Marketing consent records are retained until consent is withdrawn, plus a reasonable period to evidence withdrawal.

When data is no longer required and no legal obligation mandates its retention, bat989 will securely delete or anonymise it.

9 Cookies & Tracking Technologies

bat989 uses cookies and similar tracking technologies to operate the Platform, maintain session state, detect fraud and analyse usage. The categories of cookies in use are:

• Strictly Necessary Cookies: Essential to the operation of the Platform, including session authentication and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences (such as language settings and display options) to provide a more personalised experience.
• Analytics Cookies: Collect aggregated, anonymised data about how users navigate the Platform, used to improve performance and content.
• Fraud Detection Cookies: Support the identification of suspicious activity, multiple accounts and bot usage.

You may manage non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform. bat989 does not use third-party advertising or behavioural targeting cookies.

10 International Data Transfers

bat989 may transfer your personal data to jurisdictions outside your country of residence in connection with the operation of the Platform, including to service providers or hosting infrastructure located in other countries. Where such transfers occur, bat989 takes appropriate steps to ensure that your data receives a level of protection consistent with applicable data protection standards, including through contractual safeguards with Data Processors.

If you are a Pakistani resident, please note that data transferred outside Pakistan may be processed in a jurisdiction with different data protection laws. By registering on bat989, you acknowledge this transfer and consent to the processing of your data in those jurisdictions for the purposes described in this Policy.

11 User Rights

Subject to applicable law and our regulatory obligations, you hold the following rights in respect of your personal data held by bat989:

To exercise any of the above rights, please contact the bat989 support team at [email protected]. We will respond within a reasonable timeframe in accordance with applicable requirements. Identity verification may be required before a request is actioned.

12 Minors & Age Verification

bat989 is strictly an adults-only platform. We do not knowingly collect personal data from individuals under the age of 18, or the higher minimum age required by the Platform's licensing jurisdiction. Age verification is a mandatory step during KYC.

If bat989 becomes aware that personal data has been collected from a minor without parental consent, that data will be deleted promptly and the associated account will be closed immediately. All balances associated with a minor's account will be handled in accordance with applicable law.

13 Data Security

bat989 implements technical and organisational measures appropriate to the risk associated with the processing of your personal data. These measures include but are not limited to:

• SSL/TLS encryption for all data in transit between your device and the Platform.
• Encrypted storage for sensitive personal and financial data at rest.
• Role-based access controls limiting internal access to personal data on a need-to-know basis.
• Regular security assessments of Platform infrastructure.
• Two-factor authentication (2FA) available for all registered accounts.

Notwithstanding these measures, no online system can be guaranteed to be completely secure. bat989 cannot warrant the absolute security of data transmitted over the internet and you use the Platform at your own risk. You are responsible for maintaining the confidentiality of your login credentials.

14 Policy Amendments

bat989 reserves the right to update this Privacy Policy at any time. Where material changes are made, registered users will be notified via the Platform or by email. Continued use of bat989 following the publication of a revised Policy constitutes acceptance of those changes.

We encourage you to review this page periodically. The date of the most recent revision is displayed at the top of this document.

15 Contact Us

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a privacy concern, please contact the bat989 team using the details below:

All privacy-related requests are handled by our dedicated support team. We aim to acknowledge receipt within two business days and to respond substantively within a reasonable timeframe. Identity verification may be required before personal data is disclosed or deleted.