663bat Privacy Policy – How We Handle Your Personal Data

1. Introduction & Data Controller Identity

This Privacy Policy ("Policy") is issued by 663bat ("663bat," "we," "us," or "our") and applies to all personal data processed in connection with the 663bat platform and associated services available at 663bat.app (the "Platform").

663bat acts as the data controller in respect of the personal data of players, registered account holders, and visitors to the Platform. As data controller, 663bat determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is lawful, fair, and transparent.

This Policy should be read alongside the 663bat Terms & Conditions and Responsible Gaming Policy, both of which are available on the Platform. By registering an account with 663bat or accessing the Platform, you acknowledge that you have read and understood this Policy.

If you have any questions about this Policy or about how 663bat processes your personal data, please contact us at [email protected].

2. Personal Data We Collect

663bat collects personal data from you in the following categories, depending on how you interact with the Platform:

2.1 Registration & Account Data. When you create a 663bat account, we collect your full name (as it appears on your identity document), email address, date of birth, residential address, Pakistani mobile number, and the account password you create. This data is required to open and maintain your account.

2.2 Identity Verification Data. To comply with age verification and Know Your Customer (KYC) requirements, 663bat may collect copies of your CNIC (Computerised National Identity Card), passport, driving licence, proof of address documents, and other identity or source-of-funds documentation. This data is processed strictly for verification and regulatory compliance purposes.

2.3 Financial & Transaction Data. 663bat records all financial transactions on your account including deposits (via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, USDT TRC20, Skrill, Neteller), withdrawals, wager amounts, winnings, and bonus credits. Payment instrument details (such as your JazzCash or Easypaisa mobile number) are collected to process transactions and for AML monitoring.

2.4 Betting & Gaming Activity Data. We record all bets placed on the Platform, including market selection, stake amounts, odds accepted, bet settlement outcomes, casino game sessions, slot game play history, and session duration data.

2.5 Technical & Device Data. When you access the Platform, we automatically collect technical data including your IP address, device type, operating system, browser type and version, screen resolution, and unique device identifiers. This data is used for security monitoring, fraud prevention, and platform optimisation.

2.6 Communications Data. We retain records of communications between you and 663bat's support team, including live chat transcripts, email correspondence, and any complaints or feedback you submit.

2.7 Responsible Gaming Data. Data relating to your use of responsible gaming tools (deposit limits set, self-exclusion requests, cooling-off periods) is recorded and maintained for compliance purposes.

3. How 663bat Uses Your Personal Data

663bat processes your personal data for the following purposes:

• Account creation and management: Opening, maintaining, and administering your 663bat account; processing login and authentication; managing account settings.
• Service delivery: Enabling you to place bets, play casino games, access slots, make deposits and withdrawals via JazzCash, Easypaisa, and other supported payment methods, and receive winnings.
• Identity verification and KYC: Verifying your age (18+ requirement), identity, and address in compliance with applicable requirements.
• Financial transaction processing: Processing PKR deposits, withdrawals, and internal account transfers; reconciling transactions; detecting and preventing payment fraud.
• Anti-money laundering (AML) compliance: Monitoring transactions for suspicious activity; filing reports as required by applicable law; maintaining transaction records.
• Responsible gaming: Monitoring gambling behaviour for indicators of problem gambling; enforcing player-set limits, cooling-off periods, and self-exclusion requests.
• Security and fraud prevention: Detecting, investigating, and preventing fraudulent activity, cheating, collusion, and unauthorised account access.
• Customer support: Responding to your enquiries, resolving disputes, and communicating account-related information.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may withdraw marketing consent at any time.
• Platform improvement: Analysing aggregated usage data to improve the Platform's performance, product offering, and user experience.
• Legal compliance: Meeting 663bat's legal obligations under applicable law.

4. Legal Basis for Processing

663bat processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and 663bat (i.e., the Terms & Conditions), including account management, bet settlement, and payment processing.
• Legal obligation: Processing required to comply with legal obligations applicable to 663bat, including AML/CFT requirements, age verification obligations, and tax record-keeping.
• Legitimate interests: Processing carried out for 663bat's legitimate interests, including fraud prevention, security monitoring, responsible gaming compliance, and platform improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing based on your explicit consent, including the sending of marketing communications. Where processing is consent-based, you have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Third-Party Processors

663bat does not sell your personal data. We may share your personal data with the following categories of third parties, strictly for the purposes described:

• Payment processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, USDT processing providers, Skrill, and Neteller receive the transaction and payment instrument data necessary to process your deposits and withdrawals.
• Identity verification services: Third-party KYC and age verification providers receive identity document data to perform verification checks on behalf of 663bat.
• AML and compliance services: Transaction monitoring and sanctions screening providers may process financial data to assist 663bat in meeting its AML/CFT obligations.
• IT infrastructure providers: Cloud hosting, database, and security service providers process data on 663bat's behalf under data processing agreements that require them to maintain appropriate security standards.
• Regulatory and law enforcement authorities: 663bat will disclose personal data to competent authorities where required to do so by law, court order, or regulatory instruction.
• Game content providers: Where you play casino games or slots provided by third-party studios, limited session data may be shared with the game provider for game integrity and RNG certification purposes.

All third-party processors are required by 663bat to process personal data only in accordance with 663bat's instructions and to maintain appropriate technical and organisational security measures.

6. Cookies & Tracking Technologies

663bat uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your 663bat account. These cannot be disabled.
• Functional cookies: Remember your preferences (language, odds format, display settings) to improve your experience on the Platform.
• Analytics cookies: Collect aggregated, anonymised data about how visitors use the Platform to help 663bat improve performance and content. No individually identifiable data is shared with analytics providers.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorised login attempts.

You may manage non-essential cookies through your browser settings. Disabling strictly necessary cookies will prevent you from accessing your 663bat account. 663bat does not use third-party advertising or retargeting cookies.

7. Data Retention

663bat retains personal data for the following periods:

• Active account data: Retained for the duration of your account relationship with 663bat.
• Financial transaction records: Retained for a minimum of five (5) years following the transaction date, as required by applicable AML and financial record-keeping obligations.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the closure of your account, or longer where required by regulatory instruction.
• Betting and gaming history: Retained for a minimum of three (3) years following the last activity on the account for dispute resolution and regulatory compliance purposes.
• Support communications: Retained for two (2) years from the date of the communication.
• Self-exclusion records: Retained permanently to prevent re-registration by a self-excluded player.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 663bat's data retention procedures.

8. Data Security

663bat implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the 663bat Platform.
• Encryption of sensitive data fields (including passwords and payment credentials) at rest using industry-standard algorithms.
• Role-based access controls limiting employee access to personal data to those with a legitimate need in the performance of their duties.
• Regular security assessments and penetration testing of the Platform infrastructure.
• Fraud and intrusion detection systems monitoring for unusual account activity and access patterns.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 663bat will notify you without undue delay in accordance with applicable data breach notification requirements.

You are also responsible for maintaining the security of your 663bat account, including using a strong unique password and enabling Two-Factor Authentication. Never share your 663bat login credentials with any third party.

9. Your Data Protection Rights

Subject to applicable law and certain exceptions, you have the following rights in relation to the personal data 663bat holds about you:

• Right of access: You may request a copy of the personal data 663bat holds about you (a "Subject Access Request").
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data in certain circumstances, for example where it is no longer necessary for the purpose for which it was collected. This right does not apply where 663bat is required to retain data by law (e.g., AML record-keeping obligations).
• Right to data portability: You may request your personal data in a structured, commonly used, machine-readable format where processing is based on consent or contractual necessity.
• Right to object: You may object to processing based on legitimate interests, including profiling for marketing purposes. You may unsubscribe from marketing communications at any time.
• Right to restrict processing: You may request that 663bat restricts processing of your data in certain circumstances, for example while the accuracy of data you have contested is being verified.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, submit your request to [email protected]. 663bat will respond within thirty (30) days. Identity verification may be required before your request is processed.

10. International Data Transfers

663bat operates internationally. Your personal data may be transferred to and processed in countries outside of Pakistan. Where such transfers occur, 663bat ensures that appropriate safeguards are in place to protect your data, including contractual arrangements with data processors that require equivalent data protection standards to those applied within 663bat's primary operating jurisdiction.

By registering an account with 663bat, you acknowledge and consent to the international transfer of your personal data where necessary for the delivery of 663bat's services.

11. Children & Minors – Strict 18+ Policy

663bat is strictly an 18+ platform. We do not knowingly collect personal data from individuals under the age of 18. If 663bat becomes aware that personal data has been collected from a minor, the account will be immediately closed, all balances will be confiscated, and the personal data will be deleted in accordance with applicable law.

If you have reason to believe that a minor has registered an account with 663bat, please contact us immediately at [email protected].

12. Contact, DPO & Policy Updates

For any privacy-related queries, data subject rights requests, or complaints regarding 663bat's handling of your personal data, please contact our privacy team:

663bat reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered account holders via email and/or prominent notice on the Platform. The effective date at the top of this document will be updated to reflect the date of the latest revision. Continued use of the Platform following notification of any change constitutes acceptance of the updated Policy.

The most current version of this Privacy Policy is always available at 663bat.app/privacy-policy.