luky91 Privacy Policy 🛡️

1. Who We Are

luky91 ("luky91", "we", "us", "our") operates the online casino and sports betting platform accessible at luky91.app. For the purposes of data protection and privacy law, luky91 acts as the data controller in respect of personal data collected from users of its platform. When this Policy refers to "you" or "the Player", it means any individual who accesses, browses, registers on, or interacts with the luky91 platform, including Pakistani players accessing the platform from any location.

This Privacy Policy governs luky91's data practices in connection with the luky91.app website and all associated services, mobile-optimised interfaces, and communication channels including live chat and email support. It should be read together with luky91's Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between luky91 and its players.

2. Personal Data We Collect

luky91 collects the following categories of personal data from players in the ordinary course of account management, gaming activity, and regulatory compliance:

• Identity Data: Full legal name, date of birth, gender, and CNIC number (required for KYC age and identity verification).
• Contact Data: Pakistani mobile phone number, email address, and residential address (city and province; full address may be required for high-value withdrawal KYC).
• Financial Data: JazzCash account number, Easypaisa mobile wallet number, bank account details (IBAN, bank name), debit card details (card type, last four digits), and USDT wallet address where applicable. luky91 does not store full card numbers — payment tokenisation is used.
• Transaction Data: Records of all deposits, withdrawals, wagers placed, bonuses applied, and account balance history.
• Technical Data: IP address, browser type and version, operating system, device type (mobile/desktop/tablet), session timestamps, and approximate geolocation derived from IP.
• Behavioural Data: Gaming history (games played, bet amounts, win/loss records), betting patterns, session durations, and responsible gaming tool usage.
• Communications Data: Records of live chat conversations, support ticket exchanges, and any other correspondence between you and the luky91 team.
• Verification Documents: Copies of CNIC, utility bills, or bank statements submitted to satisfy KYC verification requirements.

3. How We Collect Your Data

luky91 collects personal data through the following channels:

• Direct Submission: Information you provide when creating your luky91 account, completing KYC verification, submitting deposit or withdrawal requests, or contacting our support team.
• Automated Collection: Technical and behavioural data collected automatically as you interact with the luky91 platform, including via cookies, session logs, and analytics tools.
• Payment Processors: Transaction confirmation data received from JazzCash, Easypaisa, and other payment service providers when processing deposits and withdrawals.
• Identity Verification Services: Data received from third-party KYC and age verification providers where luky91 uses such services to validate CNIC authenticity or confirm player identity.
• Fraud Prevention Partners: Risk signals and device fingerprinting data from fraud detection services used to protect both players and the platform from financial crime.

4. How We Use Your Personal Data

luky91 processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your luky91 account, processing your luky91 login sessions, and managing account settings including responsible gaming tools.
• Service Delivery: Enabling access to all games, sports betting markets, live casino tables, and other platform features available on luky91.
• Payment Processing: Processing deposits via JazzCash, Easypaisa, and other payment methods, and executing withdrawal requests to verified payment instruments.
• Regulatory Compliance: Complying with KYC (Know Your Customer) and AML (Anti-Money Laundering) obligations including age verification (18+), identity verification, and transaction monitoring.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, multi-accounting, bonus abuse, money laundering, and other prohibited conduct.
• Responsible Gaming: Monitoring player behaviour to identify signs of problem gambling, administering self-exclusion and cooling-off requests, and applying deposit limit settings.
• Customer Support: Responding to player queries, resolving disputes, processing complaints, and maintaining communication records.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve luky91's performance, user experience, and game selection for Pakistani players.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have not opted out of marketing communications. You may unsubscribe at any time.

5. Legal Basis for Processing

luky91 processes personal data on the following legal grounds:

• Contractual Necessity: Processing required to fulfil luky91's obligations under the player account agreement — including account creation, payment processing, and game access.
• Legal Obligation: Processing required to comply with applicable regulatory requirements, including KYC, AML, and age verification obligations under luky91's operating licence conditions.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics — where luky91's legitimate interests do not override the player's fundamental rights.
• Consent: Processing for non-essential marketing communications and optional data uses, where consent is obtained and may be withdrawn at any time.

6. Data Sharing & Third Parties

luky91 may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Service Providers: JazzCash, Easypaisa, Skrill, and other payment processors receive the minimum data necessary to execute transactions.
• KYC & Identity Verification Providers: Third-party services used to validate CNIC documents and confirm player age and identity where luky91 is required to do so under its licence conditions.
• Game Content Providers: Companies such as Pragmatic Play, PG Soft, Evolution Gaming, and JILI receive anonymised session identifiers to deliver game content. They do not receive your full personal profile.
• Fraud Prevention & Security Services: Specialist providers assisting in the detection of financial fraud, multi-accounting, and suspicious betting activity.
• Regulatory Authorities: luky91's licensing authority and any competent law enforcement or regulatory body where disclosure is legally required.
• Professional Advisers: Legal, accounting, and auditing firms who process data in the course of providing services to luky91, subject to confidentiality obligations.

7. Cookies & Tracking Technologies

luky91 uses cookies and similar tracking technologies on its platform. The following categories of cookies may be placed on your device:

• Essential Cookies: Required for core platform functionality including luky91 login session management, security tokens, and load balancing. These cannot be disabled without affecting platform access.
• Analytics Cookies: Collect anonymised data on how players use the luky91 platform to help us improve navigation, performance, and game discovery.
• Preference Cookies: Store your language, display, and notification preferences to personalise your luky91 experience across sessions.
• Marketing Cookies: Used only where you have provided consent, to track the effectiveness of luky91 promotional campaigns and deliver relevant bonus offers.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent access to core luky91 services but may affect certain personalisation features.

8. Data Retention

luky91 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following specific retention considerations:

• Active account data is retained for the lifetime of the player's luky91 account plus a minimum of five (5) years following account closure, to satisfy regulatory and anti-money laundering record-keeping obligations.
• KYC verification documents (CNIC copies, utility bills) are retained for the regulatory minimum period stipulated by luky91's licence authority — typically five (5) years from the date of submission.
• Financial transaction records are retained for a minimum of seven (7) years to comply with applicable financial regulations.
• Support communication records are retained for three (3) years from the date of the last relevant interaction.
• Data processed solely on the basis of consent is deleted promptly upon withdrawal of that consent, unless another legal basis for retention applies.

9. Data Security

luky91 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and luky91 servers.
• Encrypted storage of sensitive data including password hashes, CNIC numbers, and financial account references.
• Two-factor authentication (2FA) support for player accounts, strongly recommended for all luky91 users.
• Role-based internal access controls limiting staff access to personal data on a strict need-to-know basis.
• Regular security audits and penetration testing of luky91 platform infrastructure.
• Incident response procedures to contain and notify affected players of any data breach in accordance with applicable regulatory obligations.

While luky91 applies rigorous security measures, no internet-based platform can guarantee absolute security. You are responsible for keeping your luky91 login credentials confidential and for logging out of shared devices after each session.

10. Your Rights Over Your Data

Subject to applicable data protection law, you have the following rights in relation to personal data that luky91 holds about you:

• Right of Access: Request a copy of the personal data luky91 holds about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data where luky91 no longer has a legitimate basis to retain it. Note that regulatory retention obligations may prevent full erasure in some cases.
• Right to Restrict Processing: Request that luky91 limits the way it processes your data in certain circumstances.
• Right to Data Portability: Request a structured, machine-readable export of your personal data where processing is based on your consent or a contract.
• Right to Object: Object to processing based on legitimate interests, including direct marketing communications.
• Right to Withdraw Consent: Where luky91 processes data based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact the luky91 privacy team via email at [email protected]. luky91 aims to respond to all data rights requests within thirty (30) calendar days.

11. Children's Privacy

The luky91 platform is strictly intended for adults aged 18 and above. luky91 does not knowingly collect, process, or retain personal data from individuals under the age of 18. If luky91 discovers that an account has been created by or on behalf of a person under 18, the account will be closed immediately, all data associated with that account deleted (subject to any mandatory regulatory retention requirements), and all funds returned to the originating payment method without payment of any winnings.

If you believe that a minor may have registered a luky91 account, please contact our support team immediately via live chat or email.

12. International Data Transfers

luky91 may transfer personal data to servers, processors, and service providers located outside of Pakistan. Where such transfers occur, luky91 ensures that appropriate safeguards are in place to protect the data to a standard equivalent to that provided under applicable data protection law. These safeguards may include standard contractual clauses, data processing agreements with certified providers, or transfers to jurisdictions with recognised adequate data protection frameworks.

13. Changes to This Policy

luky91 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform functionality. When material changes are made, luky91 will notify registered players by email to their registered address and/or by a prominent notice on the platform prior to the changes taking effect. The date of the most recent revision is always displayed at the top of this page. Continued use of the luky91 platform after the effective date of any revised Privacy Policy constitutes acceptance of those revisions.

14. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or to the personal data luky91 holds about you, please contact the luky91 privacy and data team through one of the following channels:

• 📧 Email: [email protected]
• 💬 Live Chat: Available 24/7 on the luky91 platform — the fastest channel for urgent data enquiries.

luky91 is committed to handling all privacy-related enquiries promptly, professionally, and in full confidence.