we939 Privacy Policy

1.1 we939 is committed to protecting the privacy of every player who uses the we939 platform. This Privacy Policy has been prepared to give players across Pakistan — including those in Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and Multan — a clear, honest, and complete understanding of how their personal data is handled when they interact with we939.

1.2 This Privacy Policy applies to all personal data collected through the we939 website at we939.com, through any we939 mobile browser experience, through the we939 Login portal, and through any direct communications between players and the we939 support team.

1.3 This Privacy Policy is incorporated by reference into the we939 Terms & Conditions. By accepting the we939 Terms & Conditions, you also accept this Privacy Policy in its entirety. If you do not agree with the terms of this Privacy Policy, you must not register an account or use the we939 platform.

1.4 we939 may update this Privacy Policy from time to time. Updated versions will be published on this page with a revised effective date. Continued use of the platform following any such update constitutes your acceptance of the revised policy.

2.1 For the purposes of this Privacy Policy, we939 is the data controller responsible for the personal data of all registered players on the we939 platform. As data controller, we939 determines the purposes and means by which your personal data is processed.

2.2 If you have any questions about how we939 processes your personal data or wish to exercise any of your data subject rights as described in Section 11 of this Policy, you may contact the we939 Data Protection contact at the email address provided in Section 16.

3.1 we939 collects the following categories of personal data from players:

3.2 we939 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data (other than CNIC photograph for identity verification purposes), or health data, except where strictly required by applicable law or regulatory obligation.

4.1 we939 collects personal data through the following means:

• Direct submission: Data you provide when registering your we939 account, completing KYC verification, making a deposit or withdrawal, or contacting the we939 support team.
• Automated technical collection: Data collected automatically when you visit the we939 platform, including IP address, device identifiers, browser fingerprint, and session activity logs. This data is collected via cookies and server-side logging systems.
• Payment processor data: Transaction confirmation data received from payment processors including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Raast following successful deposit or withdrawal processing.
• KYC verification partners: Identity verification data returned by third-party KYC service providers used to confirm the authenticity of documents submitted during account verification.
• Communications: Data included in emails, live chat messages, or other correspondence you initiate with the we939 support or compliance teams.

5.1 we939 processes your personal data only where there is a lawful basis for doing so. The following table sets out the primary purposes for which we939 processes personal data and the corresponding legal basis:

5.2 Where we939 relies on legitimate interests as the legal basis for processing, we939 has assessed that its legitimate interests are not overridden by your interests or fundamental rights and freedoms. You have the right to object to processing based on legitimate interests — see Section 11 for details of how to exercise this right.

6.1 we939 does not sell, rent, or trade your personal data to any third party for commercial marketing purposes. Personal data is shared with third parties only in the following limited and controlled circumstances:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Raast receive the minimum personal data necessary to process your deposit and withdrawal transactions securely.
• KYC & Identity Verification Partners: Third-party identity verification service providers receive copies of documents you submit for KYC purposes in order to authenticate your identity and confirm your age eligibility.
• Game Software Providers: Game providers whose titles appear on the we939 platform may receive anonymised or pseudonymised session and wagering data for the purposes of game performance monitoring and RNG certification compliance. No personally identifiable data is shared with game providers beyond what is strictly necessary.
• Regulatory and Law Enforcement Authorities: we939 will disclose personal data to regulatory bodies, law enforcement agencies, or other competent authorities where required to do so by applicable law, court order, or regulatory directive.
• Professional Advisers: Lawyers, auditors, and compliance consultants engaged by we939 may access personal data on a strictly need-to-know basis and are bound by professional confidentiality obligations.

6.2 All third parties with whom we939 shares personal data are required to maintain appropriate technical and organisational security measures to protect that data and are prohibited from using it for any purpose beyond the scope of the services they provide to we939.

7.1 we939 takes particular care with financial data given the sensitivity of payment information and the PKR amounts involved in gaming transactions. The following principles govern how we939 handles payment data:

• we939 does not store full JazzCash or EasyPaisa wallet credentials, full bank account numbers, or any card data on its own servers.
• All payment transactions are processed through encrypted, tokenised connections with our payment service providers. we939 retains only transaction references, amounts, timestamps, and verified account identifiers required for withdrawal processing and financial record-keeping.
• Financial transaction records are retained for a minimum period of five (5) years in compliance with applicable financial record-keeping requirements.
• Proof of payment method ownership submitted during KYC verification is stored securely and used solely for the purpose of verifying that deposits and withdrawals are processed to and from accounts in the player's own name.

8.1 The we939 platform uses cookies and similar tracking technologies to deliver a functional, secure, and personalised experience. The following categories of cookies are used:

• Essential Cookies: Required for the we939 platform to function. These include session authentication cookies that keep you logged into your we939 account and security cookies that protect against cross-site request forgery. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and display options to personalise your we939 experience across sessions.
• Analytical Cookies: Collect anonymised data about how players navigate the we939 platform — including pages visited, time on page, and navigation paths — to help we939 identify performance issues and improve the user experience.
• Responsible Gaming Cookies: Track session duration and activity thresholds to support the delivery of reality check notifications and session limit enforcement where these tools have been activated by the player.

8.2 Non-essential cookies are set only with your consent, which is obtained through the cookie consent mechanism displayed upon your first visit to the we939 platform. You may withdraw cookie consent or adjust your cookie preferences at any time through your browser settings. Note that disabling certain functional cookies may affect the performance of parts of the we939 platform.

8.3 we939 does not use third-party advertising cookies or cross-site tracking technologies that follow you across other websites.

9.1 we939 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following indicative retention periods apply:

• Active account data: Retained for the lifetime of your we939 account.
• Closed account data (identity and KYC documents): Retained for a minimum of five (5) years following account closure to comply with applicable anti-money-laundering and financial record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years following each transaction.
• Support and communications records: Retained for two (2) years following the resolution of the relevant query or complaint.
• Technical and session data (logs): Retained for twelve (12) months, after which they are anonymised or deleted.
• Marketing consent records: Retained for the duration of your account and for two (2) years following account closure or opt-out, as evidence of consent.

9.2 Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised such that it can no longer be attributed to an identified or identifiable individual.

10.1 we939 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the we939 platform.
• Encryption of sensitive data at rest, including KYC documents and financial records.
• Access controls ensuring that personal data is accessible only to we939 staff and authorised third parties who require it to perform their designated functions.
• Regular security assessments and penetration testing of the we939 platform infrastructure.
• Staff training on data protection obligations and secure data handling practices.
• Incident response procedures that ensure prompt identification, containment, and notification in the event of a data security incident.

10.2 In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we939 will notify affected players without undue delay and in accordance with applicable notification obligations.

10.3 While we939 takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. Players are also responsible for maintaining the security of their own we939 Login credentials and should use a strong, unique password and not share their login details with any third party.

11.1 As a we939 player, you have the following rights in respect of your personal data:

• Right of Access: You have the right to request a copy of all personal data we939 holds about you. we939 will respond to verified access requests within 30 days.
• Right to Rectification: You have the right to request the correction of any inaccurate or incomplete personal data we939 holds about you.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to we939's legal retention obligations. Note that certain data — particularly KYC and financial records — must be retained for legally mandated periods even after account closure.
• Right to Restrict Processing: You have the right to request that we939 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to processing based on legitimate interests.
• Right to Data Portability: Where processing is based on your consent or on performance of a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing of your personal data where we939 relies on legitimate interests as the legal basis. we939 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent — for example, for marketing communications — you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

11.2 To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Subject Rights Request" and include your registered account username and a description of your request. we939 will acknowledge your request within 5 business days and respond substantively within 30 days.

11.3 we939 may require verification of your identity before processing a data subject rights request to ensure that personal data is not disclosed to or amended at the request of an unauthorised party.

12.1 The we939 platform is strictly restricted to individuals who are 21 years of age or older. we939 does not knowingly collect personal data from individuals under the age of 21. If we939 discovers that personal data has been collected from a minor, it will immediately close the relevant account and delete all associated personal data.

12.2 Age verification is a mandatory component of the KYC process for all we939 players. No withdrawal will be processed until the player's age has been verified as meeting the 21+ requirement. If you are a parent or guardian and believe that a minor in your care has accessed the we939 platform, please contact the we939 support team immediately at [email protected].

13.1 we939 may send you promotional communications about bonuses, new games, PSL season promotions, deposit match offers, and platform updates via email or SMS. These communications will only be sent where you have provided your explicit consent to receive them during the registration process or at a later point.

13.2 You may opt out of we939 marketing communications at any time by:

• Clicking the "Unsubscribe" link in any we939 promotional email.
• Updating your communication preferences within your we939 account settings.
• Contacting the we939 support team at [email protected] with a request to be removed from all marketing lists.

13.3 Opting out of marketing communications will not affect your ability to receive essential transactional communications from we939, including deposit confirmations, withdrawal notifications, security alerts, and KYC verification requests. These communications are necessary for the operation of your account and cannot be opted out of while your account remains active.

14.1 In order to deliver its services, we939 may transfer personal data to third-party service providers whose servers or operations are located outside Pakistan. Where such transfers occur, we939 ensures that appropriate safeguards are in place to protect the transferred data to a standard equivalent to that required under applicable data protection principles.

14.2 Appropriate safeguards for international transfers may include contractual data processing agreements incorporating standard data protection clauses, adequacy assessments of the destination country's data protection framework, and technical security measures applied to data in transit and at rest.

14.3 If you require further information about the specific safeguards applied to international transfers of your personal data, you may contact the we939 data protection team at [email protected].

15.1 we939 reserves the right to update or amend this Privacy Policy at any time to reflect changes in data processing practices, legal obligations, platform functionality, or regulatory requirements. Any material changes to this Policy will be communicated to registered players via email and/or through a prominent notice on the we939 platform prior to the changes taking effect.

15.2 The revised Privacy Policy will be published on this page with an updated effective date. Your continued use of the we939 platform after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you must cease using the we939 platform and may request account closure in accordance with the we939 Terms & Conditions.

16.1 If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which we939 handles your personal data, please contact the we939 data protection team using the details below:

16.2 we939 takes all privacy complaints seriously. Upon receiving a complaint, we939 will investigate the matter thoroughly and respond with the outcome of the investigation and any remedial actions taken within the timeframes stated above.

16.3 If you are not satisfied with the way in which we939 has handled your privacy complaint, you retain the right to escalate your complaint to the relevant data protection authority or regulatory body applicable in your jurisdiction.