Privacy Policy

bat339 ("bat339", "we", "us", "our") operates the online gaming information platform accessible at https://bat339.cam (the "Platform"). We are committed to protecting the privacy of all individuals who access or use the Platform ("Users", "you", "your").

This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read this Policy carefully to understand our practices in relation to your personal data and how we will handle it.

bat339 is an English-language informational platform providing guides, news and resources related to online sports betting and casino gaming, primarily targeting users in Pakistan. The Platform does not itself accept wagers, process financial transactions or operate as a gambling service. Any personal data processing described in this Policy relates to bat339's own informational operations only — not to any third-party operator's separate data processing activities.

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
• "Processing" means any operation or set of operations performed on Personal Data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, restriction, erasure or destruction.
• "Data Controller" means the natural or legal person, public authority, agency or other body which determines the purposes and means of processing Personal Data. bat339 is the Data Controller in respect of Personal Data processed through the Platform.
• "Data Processor" means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Data Controller.
• "Cookies" means small text files placed on your device by a website server. Cookies contain information that is transferred to your device's storage and retrieved by the server on subsequent visits.
• "KYC" (Know Your Customer) means identity and age-verification procedures that may be required by bat339 or third-party operators prior to enabling certain platform features or processing withdrawals.
• "Applicable Law" means all laws, regulations and regulatory guidance in force in the jurisdiction(s) applicable to bat339's operations or to the User's location, including any applicable data protection legislation.

bat339 may collect and process the following categories of Personal Data:

bat339 does not deliberately collect Special Category Data (including health data, racial or ethnic origin, religious beliefs, political opinions or biometric data used for identification purposes) through the Platform's standard operations. Where KYC processes may incidentally involve such data — for example, where a CNIC photograph reveals national origin — such data is processed solely for identity verification purposes and is not used for any other purpose.

bat339 collects Personal Data through the following means:

• Direct interactions: Data you provide when creating an Account, completing a KYC verification, contacting our support team, submitting a complaint, participating in a survey or responding to a communication from bat339.
• Automated technical collection: Technical and Usage Data collected automatically when you access the Platform through cookies, server logs, web beacons and similar tracking technologies. See Section 9 for details on our Cookie Policy.
• Third-party sources: In limited circumstances, bat339 may receive Personal Data from third-party identity verification service providers engaged to support KYC processes, or from fraud-detection and anti-money-laundering (AML) screening services. Any such sharing is governed by data processing agreements with those providers.

bat339 processes Personal Data only where there is a lawful basis for doing so. The primary purposes for which we process Personal Data, and the corresponding legal basis for each purpose, are set out below:

• Account management and platform operation — processing is necessary for the performance of a contract between you and bat339 (i.e., the provision of Platform access under our Terms and Conditions).
• Identity and age verification (KYC) — processing is necessary for compliance with legal obligations applicable to bat339 and/or the relevant operator's licence requirements, including AML obligations.
• Customer support and complaint handling — processing is in bat339's legitimate interests to resolve User enquiries, maintain service quality and keep records of interactions for dispute resolution purposes.
• Platform security and fraud prevention — processing is in bat339's legitimate interests to protect the Platform, its users and its business from fraudulent, abusive or unauthorised activity.
• Platform analytics and improvement — processing is in bat339's legitimate interests to understand how the Platform is used, to identify technical issues and to improve user experience, content quality and navigational structure.
• Responsible gambling monitoring — processing is in bat339's legitimate interests and in your vital interests to identify patterns of use that may indicate problem gambling behaviour, and to take appropriate protective action.
• Direct marketing communications — where you have given your express consent to receive marketing communications from bat339, we process your contact information to send such communications. You may withdraw consent at any time.
• Legal compliance and regulatory obligations — processing is necessary to comply with applicable legal obligations, including data protection legislation, court orders and regulatory requirements.

bat339 does not sell, rent or trade your Personal Data to third parties for commercial gain. We may share your Personal Data with the following categories of recipients, strictly for the purposes described in this Policy:

• Service providers and data processors: Third-party companies engaged by bat339 to provide technical, operational or analytical services — including hosting providers, analytics platforms, email delivery services, identity verification providers and customer support tools. All such providers operate under data processing agreements that restrict their use of your data to the specific service being provided.
• Law enforcement and regulatory authorities: Where bat339 is legally required to do so by applicable law, court order, subpoena, regulatory directive or governmental request, or where disclosure is necessary to prevent or report suspected criminal activity, fraud or AML violations.
• Professional advisers: Legal counsel, auditors, accountants and insurers where necessary in the context of professional advice, dispute resolution, audit proceedings or insurance coverage assessment.
• Business succession: In the event of a merger, acquisition, restructuring, sale of assets or other corporate transaction involving bat339, your Personal Data may be transferred to the acquiring entity as part of that transaction. Users will be notified of any change of data controller.

bat339 operates globally and may transfer your Personal Data to, or store it on, servers located in countries outside of Pakistan. Not all such countries will provide the same level of data protection as Pakistani data protection law (to the extent applicable) or other jurisdictions from which you may access the Platform.

Where bat339 transfers Personal Data internationally, we take reasonable steps to ensure that adequate safeguards are in place to protect your data, which may include:

• Transferring data only to countries recognised as providing an adequate level of data protection by relevant regulatory authorities.
• Entering into standard contractual clauses or equivalent data transfer mechanisms approved by applicable data protection authorities.
• Implementing supplementary technical measures — such as end-to-end encryption — where appropriate for the sensitivity of the data being transferred.

bat339 retains Personal Data only for as long as reasonably necessary to fulfil the purposes for which it was collected, to comply with applicable legal obligations and to resolve disputes or enforce agreements. The following general retention periods apply:

Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised in such a manner that it can no longer be associated with an identifiable individual. Anonymised aggregate data may be retained indefinitely for statistical purposes.

bat339 uses cookies and similar tracking technologies (including web beacons, pixel tags and local storage objects) to operate, maintain and improve the Platform. Cookies are small text files stored on your device when you visit the Platform that allow us to recognise your device on return visits and to store certain preferences.

bat339 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These cookies enable core functionality such as session management, security features and user authentication. They cannot be disabled without preventing Platform use.
• Functional Cookies: Allow the Platform to remember choices you have made — such as language settings, cookie consent preferences and display options — to provide a more personalised experience. These are set with your consent.
• Analytics Cookies: Help bat339 understand how visitors interact with the Platform by collecting and reporting anonymised usage data. This information enables us to improve page structure, content organisation and navigation. Set with your consent.

Most web browsers allow you to control cookie settings through the browser preferences menu. You can set your browser to refuse all cookies, to notify you when a cookie is set, or to delete cookies after each session. Please note that restricting cookies may affect the functionality of certain Platform features.

Subject to applicable data protection law and any legal retention obligations, you may have the following rights in respect of your Personal Data held by bat339. To exercise any of these rights, please contact us using the details in Section 15. We will respond to verified requests within 30 calendar days of receipt.

The bat339 Platform is intended exclusively for adults. Users must be at least 18 years of age — or the higher minimum age required by the operator's licence jurisdiction — to register for an Account or access the full features of the Platform. bat339 does not knowingly collect Personal Data from individuals under the age of 18.

If bat339 becomes aware that it has inadvertently collected Personal Data from a child under the applicable minimum age, we will take immediate steps to delete that data from our systems and close the associated Account. Any individual who believes that a minor's data has been submitted to the Platform should contact us immediately using the details in Section 15.

Parents and guardians in Pakistan and elsewhere are encouraged to monitor their children's online activities. If you have concerns about a minor accessing gambling-related content online, we recommend using parental control software and having open conversations about responsible internet use and the risks associated with gambling.

bat339 implements appropriate technical and organisational security measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or unauthorised access. Our security measures include, but are not limited to:

• Transport Layer Security (TLS) encryption for all data transmitted between your browser and the Platform.
• Encryption at rest for stored Personal Data containing sensitive or special-category information.
• Access controls that restrict Personal Data access to authorised personnel on a need-to-know basis, enforced by role-based permissions and multi-factor authentication for administrative systems.
• Regular security assessments, vulnerability scanning and penetration testing of Platform infrastructure.
• Incident response procedures and a dedicated security team responsible for monitoring and responding to potential data security threats.
• Staff training on data protection obligations and information security best practices.

The bat339 Platform may contain references to or descriptions of third-party websites, platforms or operators. bat339 does not control and is not responsible for the content, privacy policies or data practices of any third-party platform. This Privacy Policy applies solely to Personal Data processed by bat339 through the bat339 Platform.

When you navigate from bat339 to a third-party operator's website, that operator's own privacy policy and data processing practices will apply. bat339 strongly recommends that you review the privacy policy of any third-party service before providing your Personal Data to that service. The presence of a reference to or description of any operator on bat339 does not constitute bat339's endorsement of that operator's data protection practices.

bat339 reserves the right to update, modify or replace this Privacy Policy at any time. Material changes — meaning changes that significantly affect the nature of data processing or your rights as a Data Subject — will be communicated to registered users and/or notified prominently on the Platform prior to the change taking effect, where reasonably practicable.

The "Last Updated" date at the top of this Policy will be revised each time the Policy is amended. We encourage you to review this Policy periodically to remain informed of how bat339 processes your Personal Data.

Your continued use of the Platform after the posting of a revised Privacy Policy constitutes your acknowledgement of and, where consent is the applicable legal basis, your consent to the updated data processing practices described therein. If you do not agree to the revised Policy, you must cease using the Platform and may request deletion of your Account and associated data in accordance with Section 10 above.

If you have any questions, concerns or requests relating to this Privacy Policy or bat339's data protection practices — including requests to exercise your rights under Section 10 — please contact us using the details below. All communications must be submitted in English. bat339 will acknowledge data protection requests within 5 business days and endeavour to provide a substantive response within 30 calendar days.