Privacy Policy

bat393, accessible at bat393.cam ("the Platform", "bat393", "we", "us", "our"), is an English-language online betting and casino information platform serving users in Pakistan. bat393 is committed to protecting the privacy of every individual who accesses or interacts with the Platform.

This Privacy Policy ("Policy") describes in detail the types of personal data bat393 may collect when you use the Platform, the purposes for which that data is processed, the legal bases relied upon, and the rights available to you as a data subject. This Policy applies to all pages, features and services made available through bat393.cam.

bat393 does not operate as a gambling operator, financial institution or payment service provider. This Policy therefore concerns only the data collected through the Platform itself — it does not govern data processing conducted by any third-party operator whose services you may independently choose to access.

By accessing or continuing to use bat393, you confirm that you have read, understood and agreed to this Privacy Policy. If you do not accept the terms of this Policy, please discontinue use of the Platform.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, IP address, device identifiers and browsing behaviour on the Platform.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, transmission, deletion or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. For the purposes of this Policy, bat393 acts as the data controller in respect of data collected through the Platform.
• "Data Processor" — a third party that processes personal data on behalf of bat393, acting solely on bat393's instructions.
• "Data Subject" — the individual whose personal data is being processed. In the context of this Policy, this refers to any User of the Platform.
• "User" — any individual who accesses, browses or otherwise uses the Platform, whether or not they have submitted any personal data.
• "Cookies" — small text files placed on a User's device by the Platform to enable certain functionality, analytics and personalisation features.
• "Platform" — the bat393 website accessible at bat393.cam and all associated pages and content.

For the purposes of this Privacy Policy, bat393 is the data controller responsible for personal data collected through the Platform. bat393 determines the purposes and means of processing personal data in connection with the operation of bat393.cam.

bat393 does not hold a Pakistani gambling licence and does not operate as a financial institution. bat393 is not affiliated with any payment provider mentioned on the Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — and does not receive or share user data with those providers in connection with Platform use.

bat393 collects personal data in two primary ways: data provided directly by Users, and data collected automatically through the use of the Platform. The following table sets out the categories of data bat393 may collect:

bat393 does not knowingly collect sensitive personal data such as national identity numbers, financial account details, biometric data or health-related information. If you inadvertently provide such data in a support message, bat393 will not use it for any purpose beyond addressing the specific enquiry and will not retain it beyond that purpose.

bat393 processes personal data only for specific, defined purposes. The following describes the purposes for which your data may be used:

5.1 Platform Operation

Technical and usage data is processed to maintain the security, stability and functionality of the Platform. This includes server monitoring, error detection, load balancing and protection against malicious activity.

5.2 Analytics and Performance

Anonymised or aggregated usage data is processed to understand how Users navigate the Platform, which content is most useful, and how the Platform can be improved. bat393 uses this data to improve the quality of educational content, including betting guides, responsible gambling resources and the FAQ.

5.3 User Communications

Where a User contacts bat393 via support email or any contact channel, the personal data provided in that communication is processed solely for the purpose of responding to and resolving the relevant enquiry. bat393 does not use support communications for marketing purposes without express consent.

5.4 Legal Compliance

bat393 may process and retain certain personal data where required to comply with applicable legal obligations, including responses to lawful requests from competent authorities.

bat393 processes personal data only where a valid legal basis exists. The following legal bases are relied upon in connection with the processing activities described in this Policy:

• Legitimate Interests: Processing of technical and usage data for the purpose of operating, securing and improving the Platform is carried out on the basis of bat393's legitimate interests in maintaining a functioning and secure information service.
• Consent: Where bat393 places non-essential cookies or engages in analytics that require consent under applicable law, such processing is carried out on the basis of explicit consent provided by the User via cookie management tools.
• Contractual Necessity: Where a User contacts bat393 for support, processing of the contact data is necessary to fulfil the implicit agreement to respond to the enquiry.
• Legal Obligation: Where bat393 is required to retain or disclose data by law, such processing is carried out on the basis of compliance with a legal obligation.

bat393 does not sell personal data to any third party. bat393 does not share personal data with advertisers, data brokers or marketing agencies. Personal data may be shared in the following limited circumstances only:

7.1 Service Providers

bat393 may engage trusted third-party service providers — such as web hosting companies, analytics providers and email delivery services — to assist in the operation of the Platform. These providers act as data processors under binding agreements and are permitted to use personal data only as instructed by bat393 and for no independent purpose.

7.2 Legal Requirements

bat393 may disclose personal data where required to do so by law, court order or regulatory directive from a competent authority. bat393 will, where legally permitted, notify the affected User of any such disclosure requirement.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of bat393's assets, personal data held by bat393 may be transferred to the acquiring entity as part of that transaction. Users will be notified of any such transfer and the applicable privacy terms of the successor entity.

bat393 uses cookies and similar tracking technologies to enhance the functionality of the Platform and to understand how it is used. The following categories of cookies may be placed on your device:

You may manage or disable cookies through your browser settings at any time. Please note that disabling essential cookies may affect the functionality of the Platform. bat393 does not use cookies to serve targeted advertising or to track Users across third-party websites.

bat393 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention principles apply:

• Technical / Server Log Data: Retained for up to 90 days for security monitoring and error resolution purposes, after which it is deleted or anonymised.
• Analytics Data: Retained in aggregated, anonymised form for up to 24 months. Individually identifiable analytics data is not retained beyond 12 months.
• Support Communications: Retained for up to 12 months following the resolution of the relevant enquiry, to allow for follow-up if required. Longer retention may apply where a legal or regulatory obligation exists.
• Legal Compliance Records: Retained for the period required by applicable law, which may extend beyond the above periods.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Users may also request deletion of their personal data at any time, subject to any overriding legal obligation that requires retention.

As a User of bat393, you have certain rights in relation to the personal data bat393 holds about you. These rights are described below. To exercise any of these rights, please contact bat393 at [email protected]. bat393 will respond to all verifiable requests within a reasonable timeframe.

bat393 implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include, but are not limited to:

• HTTPS encryption across all Platform pages to secure data in transit between your browser and bat393's servers.
• Access controls limiting internal access to personal data on a need-to-know basis.
• Regular review of security practices and infrastructure to identify and address potential vulnerabilities.
• Prompt response procedures in the event of a suspected personal data breach.

While bat393 takes data security seriously and applies proportionate measures, no internet-based platform can guarantee absolute security against all possible threats. Users are encouraged to exercise caution when sharing personal information online and to use strong, unique passwords for any accounts associated with third-party operators they choose to use.

bat393 is strictly intended for adults aged 18 years and over, or the higher minimum age required by the relevant operator or licensing jurisdiction. bat393 does not knowingly collect personal data from individuals under the age of 18.

If bat393 becomes aware that personal data has been collected from a person under 18 years of age, that data will be deleted promptly and without further processing. If you believe a minor has submitted personal data to bat393, please contact us immediately at [email protected] (plain text — not a clickable link) so that appropriate action can be taken.

bat393 may engage service providers located outside Pakistan to assist in the operation of the Platform, including web hosting and analytics. Where personal data is transferred to service providers in other countries, bat393 takes reasonable steps to ensure that equivalent data protection standards are applied, including through the use of contractual safeguards where appropriate.

Users in Pakistan should note that Pakistan's personal data protection framework is still developing. bat393 applies reasonable international standards of data protection in the absence of a directly applicable local framework, and will update its practices as Pakistani data protection law evolves.

bat393 reserves the right to update or amend this Privacy Policy at any time. Revised versions will be published on this page with an updated "Last Updated" date. The most current version of this Policy shall apply to all personal data processing from the date of publication.

Continued use of the Platform following the publication of a revised Privacy Policy constitutes acceptance of the revised terms. Users are encouraged to review this page periodically to remain informed of how bat393 handles personal data.

Where changes to this Policy are material — such as a change in the purposes for which data is processed or a change in third-party sharing practices — bat393 will take reasonable steps to notify Users, which may include a notice on the Platform homepage.

If you have any questions, concerns or requests relating to this Privacy Policy or to bat393's handling of your personal data, please contact us using the details below. bat393 will respond to all data-related enquiries within a reasonable timeframe.

For requests relating to your personal data — including access, rectification, erasure or objection — please include sufficient detail to allow bat393 to identify your request and respond appropriately. bat393 may request verification of your identity before processing a data subject request.