Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how luky91 ("luky91", "we", "us", "our") collects, uses, stores, discloses and protects personal data provided by or collected from users ("you", "your") of the luky91 platform, accessible at https://luky91.cam and all associated sub-domains, mobile applications and digital services (collectively, the "Platform").

luky91 operates as an English-language online gaming information platform targeting Pakistani users. We take data privacy seriously. This Policy has been drafted to reflect the principles of transparency, data minimisation, purpose limitation and user rights that underpin responsible data handling practices.

By accessing, registering on or using any part of the Platform, you confirm that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must not use the Platform.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, each of which is incorporated by reference.

2. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, device identifiers and financial information.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, erasure or destruction.
• "Data Controller" means luky91, which determines the purposes and means of processing your personal data.
• "Data Processor" means any third party that processes personal data on behalf of luky91 under a data processing agreement.
• "KYC" (Know Your Customer) means the identity and age verification procedures applied during and after registration.
• "Cookie" means a small text file stored on your device by a web browser, used to maintain session information, preferences and analytics data.
• "Special Category Data" means sensitive personal data including health information, which may be relevant in responsible gambling contexts.

3. Data We Collect

luky91 collects personal data in the following categories, depending on how you interact with the Platform:

3.1 Registration & Account Data

• Full legal name and date of birth
• Email address and chosen username
• Residential address (including city — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar)
• Phone number (where provided)
• Account preferences and communication settings

3.2 Identity Verification (KYC) Data

• Government-issued photographic identification (e.g., CNIC, passport, driving licence)
• Proof of address documentation
• Proof of payment method ownership
• Selfie or biometric verification data (where required by the operator's KYC process)

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts in PKR
• Payment method details (partial card numbers, mobile wallet references)
• Transaction history and timestamps
• Bonus and promotion redemption records

Note: Payment method references (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) are used for transactional processing only. None of these providers are data controllers in relation to your luky91 account.

3.4 Technical & Device Data

• IP address and approximate geographic location
• Device type, operating system and browser version
• Session duration and login timestamps
• Cookie identifiers and tracking pixels

3.5 Behavioural & Gaming Data

• Betting history, game preferences and session patterns
• Responsible gambling tool usage (limit settings, self-exclusion requests)
• Customer support interaction records

3.6 Communications Data

• Email correspondence with our support team
• Live chat transcripts
• Survey responses and feedback submissions

4. Data Processing

We process your personal data for the following purposes:

5. Legal Basis for Processing

luky91 relies on the following legal bases for processing your personal data:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions, including account management, transaction processing and KYC verification.
• Legal Obligation: Processing required to comply with applicable anti-money laundering (AML), counter-terrorism financing (CTF), age verification and responsible gambling regulations.
• Legitimate Interests: Processing for fraud prevention, platform security, analytics and product improvement, where such interests are not overridden by your fundamental rights.
• Consent: Processing for marketing communications, non-essential cookies and optional features, where you have provided clear and affirmative consent. Consent may be withdrawn at any time by contacting support or adjusting your account preferences.

6. Data Sharing & Disclosure

luky91 does not sell, rent or trade your personal data. We may share data with the following categories of third parties only where strictly necessary and under appropriate contractual protections:

• KYC & Identity Verification Providers: To confirm your age and identity as required by our responsible gambling and compliance obligations.
• Payment Processing Partners: To facilitate deposits and withdrawals. Payment data is shared only to the extent required to complete the specific transaction.
• Fraud Prevention & Security Services: To detect, investigate and prevent fraudulent activity, money laundering and account abuse.
• Customer Support Tools: Third-party live chat and ticketing systems used to manage support interactions, operating under binding data processing agreements.
• Analytics Providers: Anonymised or pseudonymised session and behavioural data may be processed by analytics platforms to improve Platform performance.
• Regulatory Authorities: Where required by law, court order or regulatory direction, luky91 may disclose personal data to competent authorities.

All third-party data processors are required to handle your data securely, use it only for the specified purpose, and comply with applicable data protection obligations. luky91 remains accountable for ensuring appropriate safeguards are in place.

7. Cookies & Tracking Technologies

luky91 uses cookies and similar technologies to operate the Platform effectively. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. They enable session management, authentication and security features. These cannot be disabled without impairing core functionality.
• Functional Cookies: Store your preferences such as language settings, display options and responsible gambling tool configurations.
• Analytics Cookies: Collect anonymised data about how users interact with the Platform — pages visited, session duration, error events. Used solely to improve performance.
• Security & Fraud Prevention Cookies: Used to detect and prevent bot activity, account takeovers and fraudulent access attempts.

Upon your first visit, you will be presented with a cookie notice. You may accept all, reject non-essential cookies, or manage individual preferences. Withdrawing cookie consent may affect certain Platform features. We do not use advertising or cross-site tracking cookies.

8. Data Retention

luky91 retains personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable legal, regulatory or compliance obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of your account and for a minimum period after account closure as required by anti-money laundering and responsible gambling regulations.
• KYC & Identity Documents: Retained for the period required by the operator's license jurisdiction — typically five years from the date of account closure or last transaction, whichever is later.
• Transaction Records: Retained for the period required for financial audit, tax and compliance purposes under applicable law.
• Responsible Gambling Records: Self-exclusion, limit settings and problem gambling intervention records may be retained for extended periods to protect users and fulfil regulatory obligations.
• Marketing Data: Retained until consent is withdrawn or you unsubscribe, after which it is deleted within a reasonable processing cycle.
• Support & Communications Data: Retained for the period reasonably required to resolve disputes and for operational quality review purposes.

Upon expiry of the relevant retention period, personal data is securely deleted or anonymised in accordance with our internal data disposal procedures.

9. User Rights

Subject to applicable law, you hold the following rights in relation to your personal data held by luky91:

• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data held in your account.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
• Right to Restrict Processing: You may request that we limit processing of your data in certain circumstances, such as while a data accuracy dispute is being resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request a structured, machine-readable copy of the data you have provided to us.
• Right to Object: You may object to processing based on legitimate interests, including profiling, where your individual circumstances justify an override.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our support team via live chat or at the email address listed in Section 13. We will respond within a reasonable timeframe. We may need to verify your identity before fulfilling a rights request to protect against fraudulent submissions.

10. Data Security

luky91 implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols.
• Encryption of sensitive data at rest using industry-standard algorithms.
• Role-based access controls limiting data access to authorised personnel only.
• Regular security assessments, vulnerability scanning and penetration testing.
• Incident response procedures for detecting, containing and reporting data breaches.
• Staff training on data protection obligations and secure data handling practices.

Despite these measures, no data transmission over the internet or electronic storage system is entirely secure. luky91 cannot guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users and relevant authorities as required by applicable law.

11. Minors & Age Verification

The Platform is strictly for adults aged 18 and over — or the higher minimum age required by the operator's license jurisdiction. luky91 does not knowingly collect personal data from individuals under the applicable minimum age. Age verification is a mandatory component of the KYC process.

If luky91 becomes aware that personal data has been collected from a person below the minimum age, that data will be deleted promptly and the associated account will be closed. If you believe a minor has registered on the Platform, please contact our support team immediately.

Being 18 years of age does not, by itself, make online gambling lawful in Pakistan. Users are solely responsible for assessing their legal position under applicable local legislation, including the Prevention of Gambling Act, 1977.

12. Changes to This Privacy Policy

luky91 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, the revised Policy will be published on this page with an updated "Last Updated" date. Where technically practicable, registered users will be notified of significant changes via email or an in-Platform notification.

Your continued use of the Platform after a revised Policy has been published constitutes your acceptance of the updated terms. We encourage you to review this page periodically to stay informed of how your data is handled.

13. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the handling of your personal data, please contact our Data Protection team:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly on the Platform.
• Response Time: Privacy-related requests and enquiries are typically acknowledged within 5 business days. Complex rights requests may require additional time to process.

For responsible gambling-related data requests — including self-exclusion records or limit history — please visit the Responsible Gambling page or contact support directly.