Privacy Policy

Document Version: 2026 Edition — Please read carefully before using the be399 platform

1. Introduction

This Privacy Policy (hereinafter "Policy") has been prepared by be399 ("we", "us", "the Operator", "the Platform") and sets out in detail how we collect, use, store, disclose and otherwise process personal data relating to users ("you", "User", "Player") of the be399 online gaming and sports betting platform accessible at be399.cam and any associated applications or services (collectively, the "Service").

be399 is committed to processing personal data responsibly, transparently and in a manner consistent with applicable data protection law and sound privacy practice. This Policy is designed to give you clear, meaningful information about how your data is used so you can make informed decisions about your use of the Service.

By registering an account, making a deposit, using the Service or submitting any personal data to be399 in any form, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with the terms of this Policy, you must not use the Service.

This Policy should be read together with our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated herein by reference. In the event of any conflict between this Policy and the Terms & Conditions in relation to data privacy matters, this Policy shall prevail.

2. Definitions

For the purposes of this Policy:

"Controller" means the entity that determines the purposes and means of processing personal data — in this context, be399 or its designated operating entity.
"Data Subject" means any identified or identifiable natural person to whom personal data relates — in this context, you as a registered or prospective user of be399.
"KYC Data" means identity verification documentation and information collected in connection with Know Your Customer procedures, including copies of government-issued identity documents such as a CNIC or passport, and proof of address or source of funds.
"Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, financial account details and device identifiers.
"Processing" means any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, transfer and deletion.
"Processor" means any third party that processes personal data on behalf of be399 under a contractual arrangement and in accordance with this Policy.
"Sensitive Data" means personal data that warrants a higher level of protection by reason of its nature, including financial data and identity documentation.

3. Categories of Personal Data We Collect

3.1 Identity and Registration Data

When you register an account with be399, we collect: your full legal name; date of birth; username; email address; and, where required for verification purposes, copies of government-issued identity documents such as a valid CNIC (Computerised National Identity Card) or passport. This information is necessary to create and maintain your account and to carry out mandatory identity verification.

3.2 Contact Data

We collect your email address and, where provided, your telephone number for the purpose of account communications, support correspondence and, where you have opted in, marketing communications.

3.3 Financial and Transaction Data

We collect records of deposits, withdrawals and gaming transactions conducted through your be399 account, together with details of the payment method references used (for example, references to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah as familiar Pakistani payment contexts). We do not store full payment credentials on our servers; payment processing is handled by authorised payment processing partners. Financial transaction records are retained for anti-money laundering (AML) compliance and audit purposes.

3.4 KYC and Verification Data

In connection with our identity verification obligations, we may collect copies of your government-issued identity document, proof of residential address and, where required, documentation evidencing your source of funds. KYC data is processed for regulatory compliance and fraud prevention purposes only and is not used for marketing.

3.5 Gaming Activity Data

We record details of your gambling activity on the platform, including games played, bets placed, wagers settled, bonus claims and gaming session duration. This data is used to manage your account, administer promotions, enforce responsible gambling limits and fulfil regulatory obligations.

3.6 Technical and Device Data

We collect technical information about the devices you use to access be399, including IP address, browser type and version, operating system, device identifiers, time zone settings and approximate geographic location data (country and city-level) derived from IP address. This data is used for security monitoring, fraud detection and service optimisation.

3.7 Communications Data

We retain records of communications between you and our customer support team, including live chat transcripts and email correspondence. These records are maintained for quality assurance, dispute resolution and regulatory compliance purposes.

4. How We Collect Your Personal Data

We collect personal data through the following means:

Direct provision: Information you provide during registration, KYC verification, cashier transactions, support interactions or when completing any form on the platform.
Automated collection: Technical data collected automatically when you access the Service, including via cookies, web beacons and server log files.
Third-party sources: Identity verification data from KYC service providers; fraud and risk data from third-party risk management services; payment confirmation data from payment processing partners.

5. Legal Basis for Processing

be399 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

Contractual necessity: Processing required to fulfil our obligations to you under the Terms & Conditions, including account management, transaction processing and customer support.
Legal obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC, anti-money laundering requirements and responsible gambling obligations.
Legitimate interests: Processing carried out in the pursuit of our legitimate business interests, such as fraud prevention, security monitoring, platform improvement and analytics — provided such interests are not overridden by your fundamental rights.
Consent: Where we rely on your consent for specific processing activities — such as the sending of direct marketing communications — you retain the right to withdraw your consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Personal Data

be399 uses your personal data for the following purposes:

To register and maintain your account and to verify your identity in accordance with KYC requirements.
To process deposits, withdrawals and gaming transactions and to maintain accurate financial records.
To administer bonuses, promotions and loyalty programme benefits in accordance with applicable terms.
To operate responsible gambling tools — including deposit limits, loss limits, session time caps and self-exclusion — and to monitor gaming behaviour for indicators of problem gambling.
To provide customer support via live chat and email, and to maintain records of communications for quality assurance and dispute resolution.
To detect, investigate and prevent fraud, money laundering, identity theft and other illegal or prohibited activity.
To send you account-related notifications (e.g., deposit confirmations, withdrawal status updates) and, where you have consented, promotional communications.
To analyse platform usage, improve Service functionality and optimise the user experience for players accessing be399 from Pakistan and other permitted jurisdictions.
To comply with applicable legal and regulatory obligations.

Marketing Communications: If you have consented to receive promotional communications from be399, you may opt out at any time by contacting our support team at [email protected] or by using the unsubscribe mechanism included in any marketing email. Opting out of marketing communications does not affect the delivery of transactional account notifications.

7. Disclosure and Sharing of Personal Data

7.1 Service Providers and Processors

We may share your personal data with carefully selected third-party service providers who assist us in operating the Service. These include: identity verification and KYC service providers; payment processing partners; fraud detection and risk management providers; cloud hosting and infrastructure services; customer support technology providers; and analytics service providers. All such third parties are contractually bound to process your data only in accordance with our instructions and in compliance with applicable data protection obligations.

7.2 Regulatory and Legal Disclosure

We may disclose your personal data to regulatory authorities, law enforcement agencies, courts or other public authorities where required to do so by applicable law, court order or other legal obligation. Such disclosures are made only to the extent strictly required.

7.3 Business Transfers

In the event of a merger, acquisition, business transfer or reorganisation involving be399, personal data held by the Platform may be transferred to the relevant successor entity. You will be notified of any such transfer and, where required, given the opportunity to exercise applicable rights.

7.4 No Sale of Data

be399 does not sell, rent, license or otherwise transfer your personal data to unaffiliated third parties for their independent marketing, advertising or commercial purposes.

8. International Data Transfers

be399 operates on an international basis and your personal data may be processed by us or our service providers in countries outside of Pakistan. Where personal data is transferred internationally, we take steps to ensure that appropriate safeguards are in place to protect your data in a manner consistent with applicable data protection standards, including where relevant through the use of standard contractual clauses or equivalent transfer mechanisms.

By using the Service, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Pakistan that may apply different data protection standards to those in effect locally.

9. Data Retention

We retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with our legal and regulatory obligations, and to resolve disputes and enforce our agreements. The following general retention principles apply:

Account data: Retained for the duration of your account and for a period thereafter as required by applicable anti-money laundering, regulatory and record-keeping obligations.
KYC documentation: Retained for a minimum period as required by applicable regulatory obligations, typically five (5) years from the date of the last transaction or account closure.
Transaction records: Retained for audit and compliance purposes for a minimum period as required by applicable law.
Communications data: Support communications retained for a minimum of two (2) years for dispute resolution and quality assurance purposes.
Technical and analytics data: Retained in anonymised or aggregated form after the relevant retention period where continued use for analytics or platform improvement is required.

When personal data is no longer required for any lawful purpose, it will be securely deleted or anonymised in accordance with our data destruction procedures.

10. Cookies and Tracking Technologies

10.1 What We Use

be399 uses cookies, web beacons, pixel tags and similar tracking technologies to collect technical and usage data when you access the Service. Cookies are small data files stored on your device that help us recognise you, maintain your session, analyse usage patterns and deliver a more personalised experience.

10.2 Types of Cookies

Strictly necessary cookies: Required for the Service to function correctly, including session management, security and fraud prevention. These cannot be disabled.
Functional cookies: Used to remember your preferences and settings to improve your experience on subsequent visits.
Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the platform, enabling us to improve functionality and content.
Marketing cookies: Where you have consented, used to deliver relevant promotional content and measure the effectiveness of marketing communications.

10.3 Managing Cookies

You can control non-essential cookie categories via your browser settings. Disabling certain cookies may affect the functionality of the Service. Strictly necessary cookies cannot be disabled as they are essential to platform operation.

11. Your Data Rights

Depending on the data protection laws applicable in your jurisdiction, you may have the following rights in relation to your personal data held by be399:

Right of Access

You have the right to request a copy of the personal data we hold about you, together with information about how it is processed.

Right to Rectification

You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may also update certain information directly from your account settings.

Right to Erasure

In certain circumstances, you may request deletion of your personal data. Note that we may be required to retain certain data to comply with legal and regulatory obligations notwithstanding such a request.

Right to Restriction

You may request that we 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 consent or contractual necessity and carried out by automated means, you may request receipt of your personal data in a structured, commonly used and machine-readable format.

Right to Object

You may object to processing carried out on the basis of legitimate interests, including profiling for direct marketing purposes. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.

To exercise any of the above rights, please contact us at [email protected]. We will respond to valid requests within a reasonable timeframe, subject to identity verification and any applicable legal constraints. We reserve the right to charge a reasonable administrative fee for manifestly unfounded or excessive requests.

12. Children's Privacy

The Service is strictly for adults aged 18 years or over — or the higher minimum age required by the applicable operator or license jurisdiction. be399 does not knowingly collect, use or retain personal data from individuals below the applicable minimum age. If we discover that personal data has been submitted by an individual who does not meet the minimum age requirement, we will promptly delete all associated data and close the relevant account, subject to any data retention obligations imposed by applicable law.

If you believe that a minor has registered an account or provided personal data to be399, please notify us immediately at [email protected].

13. Security Measures

be399 implements a range of technical and organisational measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

TLS (Transport Layer Security) encryption for all data transmitted between your device and our servers.
Industry-standard hashing for stored account credentials.
Access controls limiting internal access to personal data to authorised personnel with a legitimate business need.
Regular security assessments and monitoring of platform infrastructure.
Data breach detection and response procedures.

Notwithstanding the above, no method of electronic transmission or storage is completely secure. While we take all reasonable steps to protect your personal data, we cannot guarantee absolute security. In the event of a data breach that is likely to affect your rights and freedoms, we will notify you and, where required, the relevant supervisory authority without undue delay.

Your Responsibility: You are responsible for keeping your account credentials confidential and for ensuring that your devices are adequately protected against unauthorised access. If you suspect any unauthorised use of your account, contact us immediately at [email protected].

14. Updates to This Privacy Policy

be399 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or platform functionality. Material changes will be communicated to registered Users via the email address on file or by way of a prominent notice on the platform prior to the change taking effect.

Your continued use of the Service following notification of any material amendment constitutes your acceptance of the revised Policy. If you do not agree with an amended Policy, you must cease using the Service and contact us to request account closure.

15. Contact Us — Data Queries

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by be399, please contact us:

Support Email: [email protected]
Subject Line: Please include "Privacy Query" or "Data Request" in the subject line of your email to ensure prompt routing to the relevant team.
Live Chat: Available 24/7 via the platform (operator-provided — subject to change)
Response Time: We aim to acknowledge data-related requests within 5 business days and to provide a substantive response within 30 calendar days, subject to the complexity of the request.

For general account queries or responsible gambling support, please also visit our FAQ and Responsible Gambling pages.

Data Minimisation

Secure Processing

Your Rights

No Data Selling

Data We Process

Contents