939betapp Privacy Policy — Data Protection

1. Who We Are and the Scope of This Policy

The 939betapp is a Sports Betting and online casino platform operating in Brazil, offering betting services on football (Brasileirão Série A, Copa do Brasil, Libertadores), volleyball, basketball (NBB), MMA/UFC, e-sports, as well as Live Casino games, slots, and crash games. To operate these services, we collect and process personal data from registered users.

This Privacy Policy applies to all users who access, register with, or use any 939betapp service — whether via the website or a mobile browser. By creating an account, you confirm that you have read and agreed to the terms described here.

939betapp acts as data controller under the LGPD, as the party responsible for decisions regarding the processing of personal information collected during use of the platform.

2. What Personal Data We Collect

939betapp collects only the data necessary to operate the platform safely and in legal compliance. The data collected is organized into the following categories:

939betapp does not collect sensitive data such as health information, sexual orientation, political opinion, religion, or biometric data, except when required by a specific legal obligation and with your express consent.

3. How We Collect Your Data

Personal data is collected through the following channels and circumstances:

• Registration form: when you create your 939betapp account, you voluntarily provide your name, tax ID, email address, date of birth, and mobile number.
• Financial transactions: when making deposits via Pix, bank slip, credit/debit card, PicPay, or Mercado Pago, we collect the data needed to process and record the transaction — including your Pix key and card data tokenized by the payment processor.
• Platform usage: while you browse, we automatically collect technical data such as IP address, device type, browser, operating system, and pages visited through cookies and similar technologies.
• Support communication: every interaction with our support team — whether by email, live chat, or another channel — is recorded for quality and security purposes.
• Identity verification: when required by legal obligation or upon suspicion of fraud, we may request additional documents that you send to us directly.
• Public sources: for fraud prevention purposes, we may consult available public databases to verify information provided during registration.

4. How We Use Your Data

939betapp uses your personal data exclusively for the following purposes:

• Platform operation: creating and managing your account, processing bets, settling results, and paying out winnings via Pix or other available methods.
• Identity verification and fraud prevention: verify your identity, detect suspicious behavior, and fulfill Know Your Customer (KYC) obligations required by Brazilian regulations.
• Payment processing: securely process deposits and withdrawals, reconcile transactions, and maintain the financial records required by law.
• Customer support: respond to your requests, resolve account issues, handle transaction disputes, and provide technical support.
• Platform security: identify and prevent unlawful activities such as money laundering, bot usage, multiple account creation, and betting manipulation.
• Compliance with legal obligations: respond to requests from competent authorities under Brazilian law, including financial regulators and public security authorities when legally required.
• Service improvement: analyze usage patterns in aggregated, anonymized form to improve the platform experience.
• Transactional communications: send notifications about confirmed deposits, processed withdrawals, settled bets, and important account security updates.
• Promotional communications: send offers, bonuses, and updates — only with your consent and with an opt-out option in every message.

5. Legal Basis for Processing (LGPD)

Every data processing activity carried out by 939betapp has a specific legal basis under the LGPD (Law No. 13.709/2018). Here is how that works in practice:

• Contract performance (Art. 7, V): the processing of identification, financial, and platform usage data is necessary to fulfill the contract you entered into when registering — without this data, it is not possible to operate your account or process bets.
• Legal obligation (Art. 7, II): the collection of CPF, financial data, and transaction records is required by Brazilian anti-money laundering legislation and the financial regulations applicable to betting platforms.
• Legitimate interest (Art. 7º, IX): the processing of technical and usage data for platform security, fraud detection, and service improvement is based on 939betapp's legitimate interest in maintaining a safe environment for all users.
• Consent (Art. 7, I): promotional communications (email marketing, bonus offers) are only sent with your explicit consent, which can be withdrawn at any time.

6. Data Sharing with Third Parties

939betapp does not sell, rent, or trade users' personal data. Data is only shared in the situations described below, with partners who are contractually bound to equivalent data protection standards as set out in this policy:

• Payment processors: companies such as card networks, Pix providers, and digital wallets (PicPay, Mercado Pago) receive only the minimum data needed to process the requested transaction. Card data is always tokenized — 939betapp never stores the full card number.
• Game providers: live casino, slots, and crash game providers receive an anonymized session identifier to enable gameplay. Your name, tax ID, and financial data are never shared with game providers.
• Identity verification services: KYC bureaus and document verification services used to confirm your identity as required by law, operating under confidentiality and data protection agreements.
• IT Infrastructure: cloud and hosting service providers that store data on secure servers with encryption at rest and in transit, with no access to the content of users' data.
• Competent authorities: when legally required, 939betapp may disclose data to Brazilian judicial, law enforcement, or regulatory authorities upon formal request grounded in applicable law.

In all cases of third-party data sharing, 939betapp contractually requires partners to implement equivalent security measures and use the data solely for the authorized purpose.

7. Storage & Retention Periods

Personal data is stored on servers with encryption at rest, with access restricted to authorized staff on a need-to-know basis. Retention periods follow applicable legal and operational requirements:

• Registration and identification data: retained for as long as the account is active and for at least 5 years after closure, in compliance with anti-money-laundering requirements.
• Financial data and transaction history: retained for 10 years after each transaction, in accordance with Brazilian accounting and tax obligations.
• Betting history and gaming sessions: retained for 5 years for audit and dispute resolution purposes.
• Support communication records: stored for 3 years for quality assurance and dispute resolution purposes.
• Technical data (access logs, IP addresses): retained for 6 months to 1 year for platform security and fraud investigation purposes, pursuant to the Brazilian Internet Civil Rights Framework (Law No. 12.965/2014).

Once the applicable retention periods have expired, data is securely and irreversibly deleted or anonymized so that it can no longer be used to identify the data subject.

8. Data Security at 939betapp

939betapp implements technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. The main safeguards in place are:

• SSL/TLS 256-bit encryption across all communications between your device and the platform's servers.
• Encryption at rest for data stored in databases, ensuring it remains protected even in the event of unauthorized physical access to the server.
• Financial data tokenization: credit/debit card numbers are replaced with tokens — 939betapp never stores your full card number.
• Role-based access control: each 939betapp team member can only access the data required to perform their specific role, with full access traceability.
• Continuous monitoring: automated systems monitor access and transactions in real time to detect anomalous behavior and intrusion attempts.
• Two-factor authentication: available for users who want to add an extra layer of security to their account access.
• Periodic security testing: 939betapp's infrastructure undergoes penetration testing and security audits carried out by independent specialists.

9. Cookies & Tracking Technologies

939betapp uses cookies and similar technologies to enhance your experience on the platform. Cookies are small text files stored on your device that allow the site to remember your preferences and recognize your visits. We use the following types of cookies:

• Strictly necessary cookies: essential for the platform to function — they keep your session active, protect against CSRF attacks, and ensure bets are linked to your account. They cannot be disabled without compromising core functionality.
• Performance cookies: collect data on how users interact with the platform in aggregated, anonymized form, without identifying individual users. Used to detect pages with loading issues or confusing navigation flows.
• Functional cookies: remember your language preferences, odds display settings, and other customizations so you don't have to reconfigure them every time you log in.
• Security cookies: used to detect unauthorized access attempts, bot activity, and anomalous behavior that may pose a fraud risk to the account.

You can manage cookie settings through the platform's privacy panel or your browser settings. Disabling non-essential cookies won't prevent basic use of 939betapp, though it may affect some personalization features.

10. Your Rights as a Data Subject (LGPD)

The LGPD grants you, as a data subject, a set of rights that can be exercised at any time by submitting a request to 939betapp. Here is what those rights are and how to exercise them:

To exercise any of these rights, submit your request by email to contato@939betapp.best with the subject line "LGPD Rights — [your right]". 939betapp responds within 15 calendar days, as required by the LGPD. For straightforward requests such as updating registration data, the response is usually much faster.

11. Protection of Minors

939betapp is a platform exclusively for individuals with 18 years of age or older. We do not intentionally collect personal data from anyone under 18. Registration requires a valid CPF and includes an age verification step during the sign-up process.

If 939betapp determines that an account was created by a minor — through document verification, a report from a legal guardian, or any other means — the account will be immediately suspended, the data will be deleted as permitted by law, and any balance will be held pending investigation.

If you are the legal guardian of a minor and believe they have created an account on 939betapp, please contact us immediately at contato@939betapp.best. Our team will take the necessary steps as a matter of priority.

12. International Data Transfers

To operate the platform, 939betapp may use technological infrastructure from cloud service providers whose servers are located outside Brazil. In such cases, international data transfers occur only when:

• The destination country provides an adequate level of personal data protection, as assessed by the ANPD.
• The provider must have signed standard data protection contractual clauses approved by the ANPD or an equivalent international body.
• Equivalent contractual safeguards to those required by the LGPD are in place, including technical and organizational security measures.

In all cases of international data transfer, 939betapp ensures your data receives a level of protection equivalent to that required by Brazilian law. The infrastructure providers used by the platform are not permitted to access or process user data for their own purposes.

13. Changes to This Privacy Policy

939betapp may update this Privacy Policy periodically to reflect changes in legislation, platform practices, or the services offered. The date of the last update is always displayed at the top of this page.

When changes are significant — such as updates to how your data is shared or the purposes for which it is used — you will be notified by email with reasonable advance notice. For minor editorial or clarity updates, updating the date at the top of the document is sufficient.

Continued use of the platform after the changes take effect constitutes acceptance of the updated policy. If you do not agree with the changes, you may request account closure as set out in the Terms and Conditions.

14. How to Get in Touch — DPO & Privacy Support

For any questions, requests related to your rights as a data subject, or to report a privacy incident, please contact the 939betapp data protection team:

• General e-mail: contato@939betapp.best — available 24 hours a day, with responses to urgent matters within 2 hours.
• LGPD Requests: send an email with the subject line "LGPD Rights — [request type]" to the same address. The response deadline for formal rights requests is up to 15 calendar days.
• Security incidents: if you suspect unauthorized access to your account or misuse of your data, please notify us immediately at the e-mail above so we can take preventive action as a priority.
• ANPD: if, after contacting 939betapp, you feel your rights have not been properly addressed, you may file a complaint with the National Data Protection Authority (ANPD), the regulatory body for the LGPD in Brazil.

939betapp is committed to responding to all privacy requests seriously and within the legally required timeframes. No LGPD rights request will be ignored or handled with unjustified delay.