1. About This Policy
This Privacy Policy ("Policy") applies to all personal data collected and processed by 399be in connection with the provision of its online casino and sports betting services at 399be.asia and associated subdomains and mobile interfaces (collectively, the "Platform").
This Policy forms part of the contractual relationship between 399be and all registered players, and should be read alongside our Terms & Conditions and Responsible Gaming Policy. By creating an Account or using the 399be Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.
Plain-Language Summary:
This Policy tells you what data 399be holds about you, what it is used for, who can see it, and how you can take control of it. We have tried to write it as clearly as possible — but if anything is unclear, our support team at
[email protected] is happy to explain.
2. Data Controller
For the purposes of this Policy, 399be (the entity operating the 399be.asia platform under its applicable gaming licence) is the data controller responsible for your personal data. As data controller, 399be determines the purposes and means by which your personal data is processed.
If you have any questions about how 399be handles your personal data, wish to exercise your data rights, or wish to make a complaint about data processing practices, please contact our Data Protection contact via the support channels specified in Section 15 of this Policy.
3. Data We Collect
399be collects personal data across the following categories, all of which are detailed with examples, purposes, and retention periods in the table provided in the section above. A summary of each category is provided here for reference:
- Identity Data: Information that identifies you personally, including your full legal name, date of birth, and government-issued identity document details such as your Pakistani CNIC or passport number.
- Contact Data: Your Pakistani mobile number, email address, and residential address, used for account communications, transaction alerts, and support correspondence.
- Financial Data: Payment method details (JazzCash mobile number, EasyPaisa account, HBL / UBL / Meezan Bank details, or card details), deposit and withdrawal transaction records, and your PKR account balance history.
- Identity Documents: Scanned copies or photographs of identity documents submitted during the KYC verification process, including your CNIC, passport, and proof of address documents.
- Technical Data: IP address, device identifier, browser type, operating system version, and session log data collected automatically when you access the 399be Platform.
- Usage Data: Records of your activity on the Platform, including games played, bets placed, sports markets accessed, session times, and feature usage patterns.
- Communications Data: The content of any communications you send to or receive from the 399be support team, including live chat transcripts, email correspondence, and support tickets.
- Marketing Preferences: Records of your communication channel preferences, promotion opt-ins, and any opt-out requests you have submitted.
4. How We Collect Your Data
4.1 Information You Provide Directly
The majority of personal data 399be holds is provided directly by you during account registration, the KYC verification process, deposits and withdrawal requests, and your communications with the support team. This includes all Identity Data, Contact Data, Financial Data, and Identity Documents.
4.2 Automatically Collected Data
When you access and use the 399be Platform, certain Technical Data and Usage Data is collected automatically through standard web and application logging technology. This includes your IP address, device and browser details, session start and end times, pages visited, and feature interactions. This data is collected through first-party analytics tools and server logs operated by 399be.
4.3 Cookies and Similar Technologies
399be uses cookies and similar tracking technologies on the Platform to maintain session state (allowing you to stay logged in), measure platform performance, and personalise certain aspects of your experience. For full details of the cookies we use and how you can manage your cookie preferences, please refer to Section 10 of this Policy.
4.4 Third-Party Sources
In limited circumstances, 399be may receive personal data about you from third parties, including payment service providers (for transaction verification), identity verification service providers (for KYC purposes), and fraud prevention services. Such data is used solely in connection with the legitimate purpose for which it was obtained and is handled in accordance with this Policy.
5. How We Use Your Data
399be uses the personal data it collects for the following purposes:
- Account management: Creating, operating, and maintaining your 399be account, including login authentication and account settings management.
- Transaction processing: Processing PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard, and maintaining accurate transaction records.
- KYC and identity verification: Verifying your identity and age in compliance with our licensing obligations and applicable anti-money laundering requirements.
- Fraud and security: Detecting, investigating, and preventing fraudulent activity, money laundering, account takeover, and other security threats to the Platform and its players.
- Responsible gaming: Monitoring betting patterns to identify potential indicators of problem gambling, applying responsible gaming tools where appropriate, and complying with our responsible gaming obligations under applicable licence conditions.
- Customer support: Providing assistance via live chat and email, investigating complaints, and resolving disputes.
- Legal and regulatory compliance: Complying with obligations under our gaming licence, anti-money laundering regulations, and any other applicable laws.
- Platform improvement: Analysing aggregated and anonymised usage data to improve the performance, stability, and user experience of the 399be Platform.
- Marketing communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have provided consent to receive such communications, and only through your preferred channels.
6. Legal Bases for Processing
399be processes your personal data under the following legal bases, depending on the specific processing activity:
- Contractual necessity: Processing that is necessary to perform the contract between 399be and you (i.e., to operate your account, process transactions, and deliver the Services). This covers the majority of our processing activities.
- Legal obligation: Processing required to comply with applicable law, including KYC verification, anti-money laundering screening, and data retention obligations under our gaming licence conditions.
- Legitimate interests: Processing for purposes that are in the legitimate interests of 399be, including fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring, where such interests are not overridden by your own privacy rights.
- Consent: Processing for marketing communications, certain cookies, and any other processing activity for which 399be seeks your explicit agreement. Where consent is the legal basis, you have the right to withdraw it at any time.
7. Data Sharing & Third Parties
399be does not sell, rent, or trade your personal data. Personal data is shared with third parties only in the circumstances described below, and only to the extent necessary for the specified purpose:
- Payment service providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard — to process your deposit and withdrawal transactions. Each provider operates under its own privacy policy and applicable financial regulations.
- Identity verification providers: Third-party KYC and AML service providers who assist with identity document verification and sanctions screening in compliance with our licensing obligations.
- IT infrastructure and hosting providers: Cloud infrastructure and hosting service providers who process data on our behalf under binding data processing agreements that require them to maintain appropriate security standards.
- Fraud prevention and security services: Specialist security providers used to detect and prevent fraudulent account activity, suspicious transactions, and platform attacks.
- Regulatory and law enforcement authorities: Where 399be is legally required to disclose data to a regulator, licensing authority, law enforcement agency, or court, it will do so in compliance with applicable law.
- Professional advisers: Legal, financial, and compliance advisers engaged by 399be, who are bound by confidentiality obligations.
All third parties with whom 399be shares personal data are required to handle it in compliance with applicable data protection standards and are permitted to use it only for the purpose for which it was shared.
8. International Data Transfers
As an internationally licensed platform, 399be may store and process personal data on servers located outside of Pakistan. Where personal data is transferred to a jurisdiction that does not provide an equivalent level of data protection to that applicable in your home jurisdiction, 399be ensures that appropriate safeguards are in place — including contractual protections with data processors — to maintain the security and integrity of your personal data throughout its lifecycle.
If you require more information about the specific safeguards applied to international data transfers involving your personal data, please contact us using the details in Section 15.
9. Data Retention
399be retains personal data only for as long as is necessary for the purposes set out in this Policy, or as required by applicable law and licensing regulations. The specific retention periods applicable to each category of personal data are set out in the data categories table above.
In general, financial records (including transaction history and KYC documentation) are retained for a minimum of seven years following account closure to comply with anti-money laundering obligations. Other categories of personal data are retained for shorter periods tied to their specific purpose, after which they are securely deleted or anonymised.
Where an Account is suspended pending investigation, relevant personal data will be retained for the duration of the investigation and for any subsequent legal proceedings, regardless of the standard retention period.
10. Cookies & Tracking Technologies
10.1 What Are Cookies?
Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites work efficiently, to remember your preferences, and to provide usage analytics to website operators.
10.2 Cookies Used by 399be
399be uses the following categories of cookies on the Platform:
- Strictly Necessary Cookies: Required for the Platform to function. These include session management cookies that keep you logged in while you navigate between pages, and security cookies that protect against cross-site request forgery. These cannot be disabled without breaking core platform functionality.
- Functional Cookies: Store your preferences such as language settings, game lobby display preferences, and recent activity. These are not required but improve your experience on the Platform.
- Analytics Cookies: First-party analytics cookies used by 399be to measure platform performance, understand how players navigate the interface, and identify technical issues. Data collected via analytics cookies is aggregated and does not identify individual players.
10.3 Managing Cookies
You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, and set preferences for specific websites. Please be aware that disabling strictly necessary cookies will impair your ability to use the 399be Platform, including your ability to stay logged in.
11. Your Data Rights
Subject to applicable law, you have the following rights in relation to the personal data that 399be holds about you. Requests to exercise any of these rights should be submitted to our support team using the contact details in Section 15. 399be will respond to all valid requests within 30 days, or notify you if an extension is required.