Privacy Policy

This Privacy Policy ("Policy") applies to all users of the luki91 platform, accessible at luki91.cam. luki91 ("we", "us", "our") is the data controller responsible for the personal data you provide when you register an account, interact with our services or otherwise access the Platform.

We are committed to processing personal data transparently, securely and in accordance with applicable data protection principles. This Policy details exactly what information we collect, the lawful bases on which we rely to process it, how long we retain it, who we may share it with and what your rights are as a data subject.

By accessing luki91 or creating an account, you acknowledge that you have read and understood this Policy and agree to the collection and use of your information as described herein. If you do not accept this Policy, please discontinue use of the Platform immediately.

The following terms have the meanings set out below throughout this Policy:

luki91 collects personal data through several channels. The categories of data we collect and their sources are set out in the table below:

We do not intentionally collect special categories of sensitive personal data (such as health data, religious beliefs or biometric data) except where a user voluntarily provides such information in the context of a responsible gambling self-exclusion request or similar welfare interaction.

luki91 processes personal data on the basis of one or more of the following lawful grounds, as applicable to each specific processing activity:

• Contractual Necessity: Processing required to perform the contract between luki91 and the user — including account management, transaction processing, game play and withdrawal handling.
• Legal Obligation: Processing required to comply with applicable anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, age verification obligations and any other legal duties imposed by the operator's licence jurisdiction.
• Legitimate Interests: Processing undertaken in pursuit of luki91's legitimate interests, including fraud prevention, security monitoring, platform improvement and responsible gambling enforcement, provided such interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent — for example, in relation to non-essential cookies or optional marketing communications — you may withdraw consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

luki91 processes your personal data solely for the purposes described in this Policy. We use your information for the following purposes:

• Account Creation & Management: To create and maintain your account, verify your identity, process your login and manage account settings and preferences.
• Transaction Processing: To process deposits and withdrawals, including interaction with payment service providers supporting methods such as bank transfers (HBL, UBL, Meezan Bank, Bank Alfalah), mobile wallets and cryptocurrency — as available in the cashier at the time.
• Compliance & Verification: To conduct KYC checks, verify your age and address, screen against applicable sanctions lists and comply with our obligations under anti-money laundering regulations.
• Customer Support: To respond to your enquiries, resolve disputes and provide assistance through live chat, email and any other support channel.
• Responsible Gambling: To apply and monitor responsible gambling tools including deposit limits, loss limits, session limits, cooling-off periods and self-exclusion. To identify and, where appropriate, intervene in cases of problematic gambling behaviour.
• Security & Fraud Prevention: To detect, investigate and prevent fraudulent transactions, unauthorised account access, collusion, bonus abuse and any other prohibited conduct as defined in our Terms & Conditions.
• Platform Improvement: To analyse usage patterns, diagnose technical issues and improve the functionality, performance and content of the Platform.
• Communications: To send transactional communications (account confirmations, withdrawal notifications, security alerts) and, where you have opted in, promotional communications about offers and platform updates.

We do not use automated decision-making processes that produce legal or similarly significant effects without human review. Where profiling is used for fraud detection or responsible gambling purposes, it is subject to human oversight.

luki91 does not sell, rent, trade or otherwise commercially disclose your personal data to third parties. We may, however, share personal data with the following categories of recipients where necessary and under appropriate safeguards:

• Payment Service Providers: Financial data is shared with payment processors and gateway providers strictly to facilitate deposit and withdrawal transactions. These providers act as data processors under contractual data processing agreements.
• KYC & Identity Verification Providers: Identity and verification documents are processed by contracted third-party KYC service providers to fulfil our legal and regulatory verification obligations.
• Technology & Infrastructure Partners: Cloud hosting providers, content delivery networks and cybersecurity partners may process technical and usage data as part of delivering and securing the Platform.
• Regulatory & Law Enforcement Authorities: We may disclose personal data to competent authorities — including regulatory bodies in the operator's licence jurisdiction and law enforcement agencies — where we are legally required to do so or where we have a legitimate interest in preventing or reporting criminal activity.
• Responsible Gambling Organisations: Where a user has self-excluded or where we have reasonable grounds to refer a user for welfare support, limited data may be shared with responsible gambling support organisations as permitted by applicable law.

All third-party data processors engaged by luki91 are subject to contractual obligations requiring them to process personal data only as instructed, to maintain appropriate security measures and to comply with applicable data protection requirements.

luki91 operates internationally and your personal data may be transferred to, and processed in, countries outside Pakistan and outside your country of residence. These countries may not have data protection laws equivalent to those in Pakistan or your home jurisdiction.

Where personal data is transferred internationally, luki91 ensures that appropriate safeguards are in place including contractual data protection clauses that impose equivalent data protection standards on recipient organisations.

Pakistani users should be aware that Pakistan's data protection framework continues to develop. luki91 makes no representation that its data processing activities fully comply with Pakistani domestic data protection law (to the extent any such obligations apply) and users access the Platform at their own risk in this regard.

luki91 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention principles apply:

• Active Account Data: Retained for the duration of your registered account on the Platform.
• Transaction & Financial Data: Retained for a minimum of five (5) years following the date of the transaction, in compliance with anti-money laundering record-keeping obligations. This period may be extended where required by law or ongoing legal proceedings.
• KYC & Identity Documents: Retained for a minimum of five (5) years following account closure or the completion of the business relationship, as required by applicable regulations.
• Communications Data: Support interactions and correspondence retained for up to three (3) years, or longer where relevant to an ongoing dispute or legal matter.
• Technical & Usage Data: Typically retained for up to twelve (12) months for analytics and security purposes, after which it is aggregated or deleted.
• Self-Exclusion Records: Retained for the duration of the self-exclusion period and for a defined period thereafter to prevent accidental re-registration.

When personal data is no longer required, it is securely deleted or anonymised in a manner that prevents re-identification.

luki91 implements a range of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These include:

• Encryption of data in transit using TLS (Transport Layer Security) and encryption of sensitive data at rest.
• Role-based access controls restricting access to personal data to authorised personnel with a documented business need.
• Regular security assessments and vulnerability testing of the Platform's technical infrastructure.
• Two-factor authentication (2FA) available to users for account login, and enforced for administrative access to internal systems.
• Incident response procedures for detecting, containing and reporting data security incidents in accordance with applicable obligations.

Notwithstanding these measures, no internet transmission or electronic storage method is completely secure. luki91 cannot guarantee absolute security of data transmitted to or from the Platform. You use the Platform at your own risk in this respect, and we strongly recommend that you protect your account with a strong, unique password and enable two-factor authentication where available.

luki91 uses cookies and similar tracking technologies (such as web beacons and local storage) to operate the Platform, remember your preferences and understand how users interact with our content. The categories of cookies we use are described below:

You can control cookie behaviour through your browser settings. Most browsers allow you to refuse all cookies, accept only certain cookies or be notified when a cookie is set. Note that disabling essential cookies will impair your ability to use the Platform.

We do not use third-party advertising cookies or behavioural tracking cookies for the purpose of serving targeted advertising to users based on their off-platform browsing history.

Subject to applicable law and legitimate exceptions, you have the following rights in relation to your personal data held by luki91. To exercise any of these rights, please contact us using the details in Section 15.

luki91 will acknowledge privacy rights requests within a reasonable period and respond substantively as soon as practicable. We may need to verify your identity before processing a request to protect against unauthorised access to another user's data.

The luki91 Platform is strictly for adults aged 18 years or older, or the higher minimum age required by the applicable operator licence jurisdiction. luki91 does not knowingly collect or process personal data from individuals under this age.

If you believe that a minor has registered an account or provided personal data through the Platform, please notify us immediately at [email protected]. We will investigate and, if confirmed, take immediate steps to close the account and delete all associated personal data.

luki91 applies age verification checks during the registration and KYC process. Users who cannot satisfy age verification requirements will have their accounts closed and any available balance returned subject to the applicable verification of identity.

The luki91 Platform may contain references to third-party services — including technology partners, payment providers and sports data services. luki91 does not control the privacy practices of these third parties and is not responsible for the content or privacy policies of any external service.

References to payment services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are provided as contextual information only. When you use any of these services to complete a transaction, your data is processed under the terms and privacy policy of that provider. luki91 does not receive or store your full payment credentials — only confirmation tokens and transaction references necessary for account reconciliation.

We strongly recommend reviewing the privacy policy of any third-party service you interact with in connection with your use of luki91.

luki91 reserves the right to update or modify this Privacy Policy at any time. Where changes are material — meaning they significantly affect how we use your personal data or your rights — we will notify registered users via email and/or a prominent notice on the Platform before the changes take effect.

The "Last Reviewed" date at the top of this Policy reflects the most recent revision. We encourage you to review this Policy periodically to stay informed about how we protect your information.

Continued use of the Platform following notification of changes constitutes your acceptance of the revised Policy. If you do not agree with any changes, please discontinue use of the Platform and contact us to initiate account closure.

If you have any questions about this Privacy Policy, wish to exercise a data protection right, or have a concern about how luki91 handles your personal information, please use the contact details below. All privacy-related correspondence should be in English for fastest handling.

Live chat is available 24/7 through the Platform interface as provided by the operator. For privacy rights requests involving sensitive personal data, we recommend using the email channel to maintain a secure written record.