At det939, protecting the personal data of our Pakistani players is a core obligation — not an afterthought. This Privacy Policy explains exactly what information we collect, why we collect it, how we use and store it, who we share it with, and what rights you have over your own data.
These principles guide how det939 handles every piece of personal information entrusted to us by players across Pakistan.
det939 collects only the personal data that is strictly necessary for operating your account, processing payments, completing KYC verification, and complying with applicable regulatory obligations. We do not collect data speculatively or for purposes we cannot justify.
det939 does not sell, rent, or trade your personal information to any third party for their own independent marketing or commercial purposes. Your CNIC details, mobile number, payment history, and gameplay data remain within the det939 ecosystem and its approved service partners only.
All personal data transmitted between your device and det939 servers is encrypted using industry-standard TLS protocols. Data stored on det939 infrastructure — including CNIC scans, payment method records, and account credentials — is encrypted at rest using AES-256 standard encryption.
det939 provides genuine, exercisable data rights to every registered player. You can request a copy of your data, ask us to correct inaccurate records, request deletion of your data (subject to legal retention requirements), and opt out of direct marketing communications at any time.
det939 retains personal data only for as long as it is necessary for the purpose for which it was collected, or as required by law. KYC documentation is retained for a minimum of 5 years following account closure to satisfy anti-money laundering obligations. Marketing data is deleted promptly upon opt-out.
In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, det939 will notify affected players without undue delay — and within 72 hours of becoming aware of the breach — providing clear information on what data was affected and what steps are being taken.
1.1 This Privacy Policy ("Policy") describes how det939 ("det939", "we", "us", or "our") collects, uses, stores, discloses, and otherwise processes personal data relating to individuals ("you", "your", or "Player") who access or use the det939 online casino and sports betting platform available at det939.net and associated mobile applications and services (collectively, the "Platform").
1.2 This Policy applies to all personal data processed by det939 in connection with the Platform, regardless of whether you are a registered account holder, a visitor browsing the Platform without an account, or a former Player whose account has been closed. It applies to data collected online and, where applicable, offline in connection with Platform use.
1.3 This Policy should be read alongside the det939 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference and together form the complete framework governing your relationship with det939.
1.4 det939 is committed to handling personal data in a manner that respects the dignity and privacy of Pakistani players and that is consistent with internationally recognised data protection standards, including the principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.
2.1 For the purposes of this Privacy Policy, the data controller responsible for your personal data is det939, the operator of the Platform at det939.net. As data controller, det939 determines the purposes and means by which your personal data is processed.
2.2 det939 has designated a Privacy Contact responsible for overseeing compliance with this Policy and handling data-related enquiries and requests from Players. Contact details for the Privacy Contact are set out in Section 15 of this Policy.
2.3 Where det939 engages third-party service providers to process personal data on its behalf (such as KYC verification partners and payment processors), those third parties act as data processors under det939's instructions and may not use the data for their own independent purposes.
3.1 det939 collects the following categories of personal data in connection with the Platform:
4.1 det939 collects personal data through the following channels and methods:
| Collection Channel | Data Collected | When It Occurs |
|---|---|---|
| Account Registration Form | Name, CNIC number, date of birth, mobile number, email, username, password | When you create a new det939 account |
| KYC Submission Portal | CNIC photographs, selfie images, payment method proof documents | During identity verification (at registration or withdrawal trigger) |
| Cashier and Payment Interface | Payment method identifiers, transaction amounts, timestamps | Each time you deposit or withdraw funds |
| Platform Gameplay Activity | Game sessions, bets, outcomes, session duration, RG tool usage | Continuously while you are logged in and active |
| Cookies and Tracking Technologies | Device identifiers, IP address, browser data, session tokens | Automatically upon accessing the Platform (see Section 9) |
| Customer Support Interactions | Communication content, account-related information shared voluntarily | When you contact det939 via live chat or email |
| Third-Party KYC Partners | Identity verification results, fraud risk scores | When your submitted documents are processed for verification |
4.2 det939 does not purchase personal data lists from third-party data brokers or marketing list providers. All personal data held by det939 is collected directly from Players or from approved verification and payment partners in connection with your use of the Platform.
5.1 det939 processes your personal data only where it has a valid legal basis for doing so. The following table sets out the primary purposes for which det939 processes personal data and the corresponding legal basis for each purpose:
| Purpose | Legal Basis |
|---|---|
| Creating and managing your det939 account | Performance of a contract (the Terms & Conditions you accepted at registration) |
| Processing deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, IBFT, and cards | Performance of a contract; compliance with financial services obligations |
| KYC identity and age verification (21+ requirement) | Legal obligation; legitimate interest in preventing underage gambling and fraud |
| Anti-money laundering (AML) and fraud prevention monitoring | Legal obligation; legitimate interest in maintaining platform integrity |
| Responsible gaming monitoring and intervention | Legitimate interest; legal obligation where applicable regulatory framework requires it |
| Providing customer support via live chat and email | Performance of a contract; legitimate interest |
| Sending transactional communications (deposit confirmations, withdrawal notifications, security alerts) | Performance of a contract; legitimate interest |
| Sending promotional communications about bonuses and new games | Consent (you may withdraw consent at any time — see Section 10) |
| Platform analytics and performance optimisation | Legitimate interest in improving the Platform for Pakistani players |
| Compliance with regulatory investigations and law enforcement requests | Legal obligation |
5.2 Where det939 relies on legitimate interest as its legal basis, it has carried out a balancing assessment to confirm that its legitimate interests are not overridden by your interests, rights, or freedoms. You may request further information about any such assessment by contacting det939's Privacy Contact.
6.1 det939 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. Personal data is shared with third parties only in the following specific and limited circumstances:
det939 shares CNIC images, selfie photographs, and identity details with approved KYC verification service providers for the purpose of confirming your identity and age. These partners are contractually bound to process data solely for verification purposes and must maintain appropriate security standards.
Transaction data is shared with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, Mastercard, and IBFT processing partners as strictly necessary to process your deposit and withdrawal instructions. det939 does not store full card numbers — card transactions are processed via tokenised payment systems.
Where you access third-party games hosted on the det939 Platform (including live casino, slot, and sports data providers), your account session identifier and stake information may be shared with those providers for the purpose of delivering the game. These providers are contractually bound by data confidentiality obligations.
det939 may disclose personal data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, court order, or regulatory direction. det939 will, where legally permitted, notify affected Players of such disclosure requests.
det939 may share account identifiers and transaction patterns with approved fraud prevention and anti-money laundering intelligence networks where it has reasonable grounds to suspect fraudulent activity or money laundering. Such disclosures are made solely for the purpose of preventing financial crime.
7.1 det939 retains personal data for no longer than is necessary for the purpose for which it was collected, subject to any overriding legal or regulatory retention obligation. The following retention periods apply:
| Data Category | Retention Period | Reason |
|---|---|---|
| KYC documents (CNIC scans, selfies, proof of payment method) | 5 years from account closure | Anti-money laundering regulatory obligation |
| Financial transaction records (deposits, withdrawals, bonus history) | 5 years from account closure | Financial records regulatory obligation |
| Gameplay and betting history | 3 years from account closure | Dispute resolution; responsible gaming monitoring |
| Customer support interaction records | 3 years from last interaction | Dispute resolution; service quality review |
| Marketing consent and preference records | Until consent is withdrawn, then 1 year for proof of consent | Demonstration of lawful marketing basis |
| Technical and access logs (IP, session, device) | 12 months from generation | Security monitoring; fraud investigation |
| Self-exclusion and responsible gaming tool records | Minimum 6 years from last interaction | Regulatory requirement; duty of care obligations |
7.2 Upon expiry of the applicable retention period, det939 will securely delete or anonymise your personal data such that it can no longer be associated with your identity. Anonymised data may be retained for statistical and analytical purposes without limitation.
8.1 det939 implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key measures include:
8.2 While det939 takes all reasonable precautions to safeguard your personal data, no online system is completely immune from security risks. You are responsible for maintaining the confidentiality of your own account credentials and for notifying det939 promptly if you suspect any unauthorised access to your account.
9.1 det939 uses cookies and similar tracking technologies on the Platform to support essential functionality, improve performance, and (where you have consented) deliver relevant promotional content. The following categories of cookies are used:
| Cookie Category | Purpose | Consent Required? |
|---|---|---|
| Strictly Necessary | Session management, authentication tokens, security protections, load balancing. These cookies are essential for the Platform to function and cannot be disabled. | No — essential to Platform operation |
| Performance / Analytics | Measuring page load times, identifying broken features, understanding which pages Pakistani players visit most frequently, and improving Platform performance. | Yes — opt-in via cookie consent banner |
| Functional | Remembering your language preference, game display settings, and responsible gaming tool configurations between sessions. | Yes — opt-in via cookie consent banner |
| Marketing / Targeting | Delivering personalised bonus offers and game recommendations based on your gaming preferences and behaviour on the Platform. | Yes — explicit opt-in required |
9.2 You can manage your cookie preferences at any time through the Cookie Settings panel accessible via the footer of the det939 Platform. Withdrawing consent for non-essential cookies will not affect your ability to use core Platform features, but may result in a less personalised experience.
9.3 det939 does not use cross-site tracking cookies that follow your browsing activity across websites not operated by det939. Third-party game providers embedded within the Platform may set their own functional cookies subject to their own privacy policies, which are made available within each game's information panel.
10.1 With your prior consent, det939 may send you promotional communications by SMS to your registered Pakistani mobile number and by email to your registered address. These communications may include information about new bonuses, game releases, PSL cricket betting promotions, seasonal offers, and loyalty programme updates.
10.2 You may withdraw your consent to receive direct marketing communications at any time by:
10.3 Withdrawal of marketing consent will be processed within 5 business days. You may continue to receive transactional and service communications (such as deposit confirmations, withdrawal notifications, and security alerts) regardless of your marketing preferences, as these are necessary for the operation of your account.
10.4 det939 does not send marketing communications to individuals who have self-excluded from the Platform or who are subject to an active cooling-off period. Our responsible gaming systems are designed to suppress all promotional communications to accounts with active responsible gaming restrictions.
11.1 The det939 Platform is strictly for adults aged 21 and over. det939 does not knowingly collect or process personal data belonging to individuals under the age of 21. Age verification is a mandatory component of the KYC process, and accounts found to belong to persons under 21 will be immediately closed with deposited funds returned subject to applicable requirements.
11.2 If det939 becomes aware that personal data has been collected from a person under the age of 21 — whether through registration fraud, misrepresentation of date of birth, or any other means — that data will be securely deleted from det939's active systems as soon as practicable, subject only to any mandatory retention obligations under anti-money laundering law.
11.3 Parents and guardians in Pakistan who believe that a minor may have accessed the det939 Platform using false identity information are encouraged to contact det939 support immediately. det939 will cooperate fully with such reports and take prompt action to investigate and close any account identified as belonging to a minor.
12.1 det939 recognises and upholds the following data protection rights for all registered Players. To exercise any of these rights, contact det939's Privacy Contact as described in Section 15:
You have the right to request a copy of the personal data that det939 holds about you, including your registration data, KYC records (subject to security limitations), transaction history, gameplay history, and communication preferences. det939 will respond to verified access requests within 30 days.
If any personal data det939 holds about you is inaccurate or incomplete, you have the right to request correction. For identity data such as your name or CNIC number, det939 may require supporting documentation before making corrections to ensure account integrity.
You may request that det939 delete your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been processed unlawfully. Note that deletion requests may be partially declined where det939 has a legal obligation to retain certain data (e.g., AML retention requirements of 5 years).
You may request that det939 restrict the processing of your personal data in certain circumstances — for example, while a rectification request is being assessed, or where you have objected to processing and det939 is assessing the legitimacy of that objection.
Where processing is based on your consent or on contract performance, you have the right to receive your personal data in a structured, commonly used, machine-readable format (such as CSV or JSON), and to have that data transmitted to another controller where technically feasible.
You have the right to object to the processing of your personal data where det939 relies on legitimate interest as its legal basis — including profiling for responsible gaming monitoring and direct marketing. det939 will cease processing unless it can demonstrate compelling legitimate grounds that override your interests.
Where det939 uses automated systems to make decisions that significantly affect you — such as account suspension based on fraud detection algorithms or responsible gaming intervention triggers — you have the right to request human review of that decision, to express your point of view, and to contest the outcome.
12.2 det939 will respond to all verified data rights requests within 30 calendar days of receipt. Where a request is complex or where det939 receives a high volume of requests simultaneously, this period may be extended by a further 60 days, with notification to you within the initial 30-day window.
12.3 det939 may request proof of identity before processing a data rights request to ensure that data is not disclosed to or amended at the request of an unauthorised individual.
13.1 det939 primarily processes and stores personal data on infrastructure located in data centres that meet internationally recognised security standards. In certain circumstances — particularly where third-party KYC partners, game providers, or payment processors are involved — your personal data may be transferred to or accessed from servers located outside Pakistan.
13.2 Where such international transfers occur, det939 ensures that appropriate safeguards are in place to protect your personal data to a standard at least equivalent to the protections described in this Policy. These safeguards may include contractual data processing agreements incorporating internationally recognised standard contractual clauses, or transfers to organisations certified under recognised international data protection frameworks.
13.3 det939 does not transfer personal data to countries or territories that det939 considers to provide an inadequate level of data protection without implementing additional safeguards. If you would like further information about the specific safeguards applied to any international transfer of your data, please contact the Privacy Contact identified in Section 15.
14.1 det939 reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, our data processing practices, or the services available on the Platform. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent amendment.
14.2 Where an amendment is material — meaning it significantly affects your rights or the way det939 processes your personal data — det939 will provide advance notice by posting a notice on the Platform and, where practicable, by sending a notification to your registered email address or Pakistani mobile number at least 14 days before the amendment takes effect.
14.3 Your continued use of the det939 Platform after the effective date of any amendment to this Privacy Policy constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you should discontinue your use of the Platform and submit an account closure request to det939 support.
14.4 Previous versions of this Privacy Policy are available upon request by contacting the Privacy Contact identified in Section 15. det939 maintains an internal archive of all prior Policy versions with effective dates for audit and compliance purposes.
15.1 For all privacy-related enquiries, data rights requests, or complaints regarding det939's handling of your personal data, please contact our Privacy Contact through the following channels:
15.2 det939 commits to acknowledging all privacy-related requests within 48 hours of receipt and to providing a substantive response within 30 calendar days. Where a request requires more time to process, det939 will notify you within the initial 30-day window with an explanation and revised timeline.
15.3 If you are not satisfied with det939's response to your privacy complaint or data rights request, you have the right to escalate the matter to the relevant data protection supervisory authority or dispute resolution body applicable under the regulatory framework governing det939's operations. det939 will cooperate fully with any such escalation.
Your data is protected, your identity is secure, and your privacy matters. Join thousands of verified Pakistani players on det939 — cricket betting, live casino, slots, and more, all in PKR.
21+ only. For entertainment purposes only. Please gamble responsibly.