399bit Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 399bit ("the Company," "we," "us," or "399bit") collects, uses, stores, discloses, and protects the personal data of individuals ("Players," "Users," or "you") who access or use the 399bit online gaming and sports betting platform, accessible at 399bit.im and any associated mobile-optimised versions thereof.

399bit is committed to processing personal data responsibly, transparently, and in accordance with applicable data protection legislation. We recognise that Pakistani players entrust us with sensitive personal and financial information, and we take that responsibility seriously. This Policy is designed to give you a complete and honest picture of how your data is handled at every stage of your relationship with 399bit.

This Policy should be read alongside the 399bit Terms and Conditions and the 399bit Responsible Gaming Policy, both of which are incorporated by reference and available on this platform. In the event of any conflict between this Policy and the Terms and Conditions with respect to data handling, this Privacy Policy shall prevail.

2 Data Controller

399bit is the data controller in respect of all personal data collected through the 399bit platform. As data controller, 399bit determines the purposes and means by which personal data is processed. Where 399bit engages third-party processors (for example, KYC verification providers or payment processors), those parties act under instructions from 399bit and are bound by data processing agreements that impose obligations consistent with this Policy.

For all data protection enquiries, requests to exercise your data rights, or concerns about how 399bit handles your personal data, please contact our Data Protection team as described in Section 17 of this Policy.

3 Categories of Personal Data We Collect

399bit collects the following categories of personal data in connection with the operation of the platform:

3.1 Identity Data

Full legal name, date of birth, nationality, CNIC number (for Pakistani players), passport number (where provided for enhanced verification), and profile photograph where submitted for KYC purposes.

3.2 Contact Data

Email address, Pakistani mobile telephone number, residential address including city (Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, or elsewhere in Pakistan), and postal code.

3.3 Financial Data

JazzCash account details, EasyPaisa wallet identifiers, bank account numbers (HBL, UBL, Meezan Bank, or other financial institutions), card details (last four digits and card type only — full card numbers are never stored by 399bit), and USDT TRC20 wallet addresses where applicable.

3.4 Transaction Data

Records of all deposits, withdrawals, wagers, game results, bonus credits, and account balance changes associated with your 399bit account.

3.5 Technical Data

IP address, device identifiers, browser type and version, operating system, screen resolution, session duration, pages visited, and referring URLs. This data is collected automatically when you access the 399bit platform.

3.6 Behavioural Data

Game preferences, wagering patterns, session frequency, sport and market preferences (e.g., PSL cricket, football, UFC), and response to promotional offers. This data is used to improve the 399bit platform and, where you have opted in, to personalise marketing communications.

3.7 Communications Data

Records of your interactions with 399bit customer support, including live chat transcripts, email correspondence, and any complaints or disputes raised through the 399bit support system.

4 How We Collect Your Personal Data

399bit collects personal data through the following channels:

• Direct provision by you: Information you submit during account registration, KYC verification, payment processing, customer support interactions, and completion of any surveys or promotional forms on the 399bit platform.
• Automated collection: Technical and behavioural data collected automatically through cookies, server logs, and similar technologies when you access and use the 399bit platform. See Section 11 for details on cookies.
• Third-party sources: Identity verification data received from third-party KYC providers engaged by 399bit; fraud and AML screening data received from industry-standard screening services; publicly available information relevant to account verification or fraud investigation.
• Payment providers: Transaction confirmation data received from JazzCash, EasyPaisa, banking institutions, Visa, Mastercard, and cryptocurrency network records for USDT TRC20 transactions.

5 Legal Basis for Processing

399bit processes personal data on the following legal bases:

6 How 399bit Uses Your Personal Data

399bit uses your personal data for the following specific purposes:

• To create, maintain, and manage your 399bit player account;
• To process PKR deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, Mastercard, USDT TRC20, and SadaPay;
• To process withdrawal requests to your verified payment methods;
• To verify your identity in compliance with 399bit's KYC obligations under its international gaming license;
• To monitor transactions for anti-money laundering (AML) compliance and to report suspicious activity where required by law;
• To detect and prevent fraud, cheating, multi-accounting, and other prohibited conduct;
• To provide customer support and to investigate and resolve disputes;
• To operate responsible gaming tools including deposit limits, loss limits, session controls, and self-exclusion;
• To enforce the 399bit Terms and Conditions;
• To improve the 399bit platform, games library, and user experience based on aggregated and anonymised analytics data;
• To send service communications regarding your account, transactions, and changes to 399bit policies;
• To send promotional communications, bonus offers, and personalised recommendations where you have provided explicit consent and not subsequently withdrawn it.

7 Sharing Your Personal Data

399bit shares personal data with the following categories of recipients, strictly on a need-to-know basis and subject to contractual data protection obligations:

7.1 KYC and Identity Verification Providers

399bit engages licensed third-party identity verification providers to conduct KYC checks on new and existing players. These providers receive the identity documents and personal details necessary to complete the verification and return a verification result to 399bit. They are contractually prohibited from using this data for any other purpose.

7.2 Payment Processors

Transaction data is shared with the relevant payment service providers (including JazzCash, EasyPaisa, card networks, and banking partners) to facilitate the processing of deposits and withdrawals. Payment processors receive only the data necessary to complete the specific transaction.

7.3 Game Providers

Where game-specific data (such as a player session token) is required by 399bit's game providers to operate live dealer games, casino games, or sports betting markets, such data is shared under strict technical and contractual controls. Game providers do not receive full player identity or financial data.

7.4 Fraud Prevention and AML Screening Services

399bit uses industry-standard third-party fraud prevention and AML screening tools. Limited player data (including name, date of birth, and in some cases CNIC) may be checked against sanctions lists and fraud databases as part of these screening processes.

7.5 Legal and Regulatory Authorities

399bit will disclose personal data to law enforcement agencies, regulatory bodies, or other government authorities when required to do so by applicable law, court order, or the requirements of 399bit's international gaming license. 399bit will, where legally permitted, notify affected players of such disclosures.

8 International Data Transfers

Given the international nature of 399bit's operations and the global presence of some of our technology and service partners, your personal data may be transferred to and processed in countries outside of Pakistan. Where such transfers occur, 399bit ensures that appropriate safeguards are in place to protect your data, including contractual clauses that impose obligations on recipient parties equivalent to those applied within 399bit's own data handling processes.

399bit does not transfer personal data to any jurisdiction that does not provide an adequate level of protection for personal data, unless appropriate contractual or technical safeguards have been implemented to address the differential.

9 Data Retention

399bit retains personal data for the following periods:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data. Where data is anonymised rather than deleted, the anonymised data set may be retained indefinitely for aggregate analytics purposes.

10 Your Data Protection Rights

As a 399bit player, you hold the following rights in respect of your personal data. To exercise any of these rights, please contact the 399bit Data Protection team as described in Section 17:

• Right of Access: You have the right to request a copy of the personal data 399bit holds about you, along with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate personal data 399bit holds about you. Where data has been shared with third parties, 399bit will notify those parties of the correction where feasible.
• Right to Erasure: In certain circumstances, you have the right to request deletion of your personal data. This right is subject to 399bit's legal and regulatory retention obligations — data that must be retained under gaming license or AML requirements cannot be deleted until the applicable retention period expires.
• Right to Restrict Processing: You have the right to request that 399bit restrict the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data.
• Right to Data Portability: You have the right to receive a copy of the personal data you provided to 399bit in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where that processing is based on 399bit's legitimate interests. You also have an unconditional right to object to your personal data being used for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

399bit will respond to valid data rights requests within 30 days. In cases of complexity or high volume, this period may be extended by a further 30 days, of which you will be notified.

11 Cookies and Tracking Technologies

11.1 Types of Cookies Used

399bit uses the following categories of cookies and similar technologies on the platform:

• Essential Cookies: Required for the basic operation of the 399bit platform, including maintaining your login session, storing preferences, and ensuring platform security. These cookies cannot be disabled without materially affecting platform functionality.
• Performance and Analytics Cookies: Used to collect anonymised data about how Players interact with the 399bit platform, including which pages are visited most frequently and where errors occur. This data helps 399bit improve the platform experience.
• Functional Cookies: Enable the platform to remember your preferences such as language settings, preferred payment method, and last-visited game categories.
• Security Cookies: Used for fraud detection, bot identification, and protection against cross-site request forgery (CSRF) attacks during 399bit login and payment sessions.

11.2 Cookie Management

You may manage your cookie preferences through your browser settings. Most modern browsers allow you to block, delete, or be notified about cookies. Please note that blocking essential cookies will prevent certain features of the 399bit platform from functioning correctly. 399bit does not use advertising cookies or share cookie data with third-party advertising networks.

12 Security Measures

399bit implements the following technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction:

• TLS 1.3 encryption for all data in transit between your device and 399bit servers;
• AES-256 encryption for sensitive data stored at rest on 399bit systems;
• Multi-factor authentication available for all 399bit player accounts;
• Device fingerprinting and anomaly detection for 399bit login security;
• Regular third-party penetration testing of 399bit platform infrastructure;
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis;
• Formal data breach response procedures, including notification obligations to the relevant regulatory authority and affected players where required by applicable law.

Notwithstanding these measures, no method of electronic transmission or storage is 100% secure. 399bit cannot guarantee absolute security and encourages all players to protect their own account credentials and report any suspicious activity immediately to the 399bit support team.

13 Children's and Underage Player Privacy

The 399bit platform is strictly restricted to individuals who are 21 years of age or older. 399bit does not knowingly collect personal data from individuals under the age of 21. If 399bit becomes aware that personal data has been collected from a person under the age of 21, that account will be immediately suspended, the data will be securely deleted in accordance with applicable legal requirements, and any funds credited to the account will be handled in accordance with the 399bit Terms and Conditions.

If you are a parent or guardian and believe that a person under your care has registered on the 399bit platform, please contact the 399bit support team immediately so the matter can be addressed without delay.

14 Marketing Communications

399bit may send promotional communications, bonus offers, and personalised game recommendations to players who have provided explicit opt-in consent to receive such communications. Marketing communications from 399bit may be sent by email or by notification within the 399bit platform.

You may withdraw your consent to receive marketing communications from 399bit at any time by updating your communication preferences in your account settings, or by contacting the 399bit support team. Following withdrawal of consent, 399bit will cease sending marketing communications within five business days.

Withdrawal of marketing consent does not affect your ability to use the 399bit platform or any service communications related to your account and transactions — you will continue to receive operational communications regardless of your marketing preferences.

15 Third-Party Links and Services

The 399bit platform may contain links to third-party websites or services, for example in the context of game provider information pages or payment method descriptions. This Privacy Policy applies exclusively to data processed by 399bit and does not extend to data processed by third-party websites or services that may be accessible via links from the 399bit platform. 399bit encourages players to review the privacy policies of any third-party services they access.

399bit is not responsible for the privacy practices, content, or data handling of any third-party websites or services.

16 Updates to This Privacy Policy

399bit may update this Privacy Policy from time to time to reflect changes in applicable law, our data processing practices, or the features of the 399bit platform. Where updates are material, 399bit will provide reasonable advance notice to registered players by email or by prominent notice on the platform prior to the changes taking effect.

The effective date displayed at the top of this Policy reflects the date of the most recent revision. The current version of this Policy is always available at 399bit.im/privacy-policy. Your continued use of the 399bit platform following any update to this Policy constitutes your acknowledgement of the updated terms. If you do not agree to any updated Policy, you should cease using the platform and contact support to arrange account closure.

17 Contact — Data Protection Enquiries

For all data protection enquiries, requests to exercise your data rights, concerns about how 399bit processes your personal data, or to report a suspected data security incident, please contact the 399bit Data Protection team: