Data Protection & Privacy

91 Lucky Privacy Policy — How We Handle Your Personal Data

We know that handing over personal information to any online platform takes trust. This policy explains exactly what 91 Lucky collects, why we collect it, how we protect it and what rights you have over your own data. Plain language, no runaround.

Last Updated: January 2025 256-bit SSL Encrypted
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The Short Version — Six Things That Matter Most

The full policy follows below. These six points summarise the most important commitments 91 Lucky makes to every player regarding their personal information.

We Never Sell Your Data

91 Lucky does not sell, rent or trade your personal information to third-party marketers — ever. Your details stay within the platform and its operating partners only.

Industry-Standard Encryption

All data in transit is protected by TLS 1.3. Stored data — including payment details and identity documents — is encrypted with AES-256. No card numbers are stored on our servers.

You Control Your Data

You can request a copy of all data we hold about you, correct inaccuracies and ask for deletion — subject to legal retention requirements — at any time via support.

Data Kept Only as Long as Needed

We retain account data for a minimum of 5 years after closure as required by anti-money laundering regulations, then delete it. Marketing preferences can be changed any time.

Limited Third-Party Sharing

We share data only with trusted partners necessary to operate the platform — payment processors, identity verification providers and game suppliers. Nothing more.

Transparent Cookie Use

We use cookies to keep you logged in, remember your preferences and understand how the platform is being used. You can manage cookie preferences at any time in your settings.

This Privacy Policy explains how 91 Lucky ("we," "us," "our") collects, uses, stores and protects personal data belonging to players and visitors on the 91lucky.app platform. It applies to all services offered by 91 Lucky, including sports betting, cricket betting, casino games, jackpot slots, poker, virtual sports, promotions and any mobile or browser-based access to the platform. By registering an account or continuing to use the platform, you confirm that you have read and understood this Privacy Policy. If you disagree with any part of it, please discontinue use and contact us to close your account.

1

Who We Are

91 Lucky is an online betting and gaming platform operated under a valid gaming licence. The platform is accessible at 91lucky.app and is designed primarily to serve players in Pakistan. For the purposes of this Privacy Policy, 91 Lucky is the data controller responsible for your personal information — meaning we determine how and why it is processed.

If you have any questions about how we handle your data or want to exercise any of your rights, the best first point of contact is our support team at support@91lucky.app. We aim to respond to all data-related enquiries within 5 business days.

2

What Personal Data We Collect

We collect only the data we genuinely need to operate the platform, comply with our legal obligations and provide a safe, personalised experience. Below is a summary of the categories of data we hold.

Category Examples When Collected
Identity DataFull name, date of birth, CNIC/Passport numberRegistration & KYC verification
Contact DataMobile number, email addressRegistration
Financial DataEasypaisa/JazzCash wallet number, IBFT account details, last 4 digits of cardFirst deposit or withdrawal
Transaction DataDeposit amounts, withdrawal history, bet records, game sessionsOngoing platform use
Technical DataIP address, device type, browser version, operating systemEach visit/session
Usage DataPages visited, games played, session duration, betting patternsOngoing platform use
Communications DataSupport chat transcripts, email correspondenceWhen you contact us
Verification DocumentsCNIC scan, proof of payment methodKYC process

91 Lucky does not store full card numbers. Payment card data is tokenised by our PCI-DSS compliant payment processor and only a reference token is held on our systems.

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3

How We Collect Your Data

We collect personal data through three main channels.

3.1 Data You Provide Directly

When you register an account on 91 Lucky, you provide your name, date of birth, mobile number and email address. When you make a deposit or request a withdrawal, you provide payment method details. When you contact our support team via live chat, WhatsApp or email, the content of those communications is recorded. When you complete KYC verification, you upload identity documents.

3.2 Data Collected Automatically

When you visit or use 91 Lucky, our platform automatically collects technical and usage data through server logs, cookies and similar technologies. This includes your IP address, the device and browser you are using, the pages you visit, how long you stay on each page, which games you open and your general geographic region (city-level, not exact location). This data is collected through standard web technologies and helps us keep the platform secure and improve performance for Pakistani users.

3.3 Data from Third Parties

In some cases we receive data about you from third parties. Our payment partners (such as Easypaisa and JazzCash) confirm transaction status to us. Our identity verification provider returns a pass/fail result along with the verified name and document number when you complete KYC. Our game content suppliers provide us with game session records. We do not receive broader personal data from data brokers or social media platforms.

4

Why We Use Your Data — Our Purposes

We use your data only for specific, legitimate purposes. We do not use it for anything we haven't told you about. Here's a breakdown of what we do with the data we collect.

  • Account management: Creating and maintaining your 91 Lucky account, verifying your identity, processing deposits and withdrawals, and communicating important account notices.
  • Delivering the service: Processing bets, settling game results, crediting winnings to your wallet and providing access to all 91 Lucky products.
  • Security and fraud prevention: Detecting suspicious login activity, identifying duplicate accounts, preventing money laundering and investigating any potential Terms of Service breaches.
  • Legal compliance: Meeting our obligations under applicable anti-money laundering (AML) regulations, responding to lawful requests from regulatory authorities and maintaining required transaction records.
  • Responsible gaming: Monitoring for patterns of play that may indicate problem gambling and delivering responsible gaming tools and communications where relevant.
  • Platform improvement: Analysing aggregated usage data to identify bugs, improve load times, optimise the mobile experience for Pakistani devices and plan new features.
  • Marketing (with consent): Sending promotional emails, SMS notifications about bonuses and personalised offers — only if you have opted in. You can opt out at any time.
  • Customer support: Reviewing support interactions to resolve your queries, train our team and improve the quality of our service.
5

Legal Bases for Processing

We process your personal data on one of the following legal grounds, depending on the purpose.

  • Contract performance: Processing necessary to provide the 91 Lucky service you signed up for — account creation, bet processing, payouts.
  • Legal obligation: Processing we are required to carry out by law — KYC verification, AML transaction monitoring, regulatory reporting.
  • Legitimate interests: Processing in our legitimate interest that does not override your rights — fraud detection, platform security, aggregated analytics, responsible gaming monitoring.
  • Consent: Processing based on your explicit opt-in — marketing communications. You may withdraw consent at any time.
6

Sharing Your Data with Third Parties

91 Lucky does not sell your personal data. We share it only in the following carefully controlled circumstances.

6.1 Payment Service Providers

To process deposits and withdrawals, we share your name, contact details and transaction amount with Easypaisa, JazzCash, NayaPay, SadaPay, our IBFT banking partner and our card payment processor. These providers are contractually bound to process your data only for the purpose of completing your transaction and are not permitted to use it for any other purpose.

6.2 Identity Verification Providers

When you complete KYC verification, your identity document images and personal details are shared with our verification partner. This partner returns a confirmation result and verified name/document number. Document images are not stored by 91 Lucky beyond the verification review period, after which they are held encrypted in long-term secure storage as required by AML regulations.

6.3 Game Content Suppliers

Third-party casino and slot game providers receive a player session token and game activity data necessary to operate the game. They do not receive your name, contact details or financial information.

6.4 Legal and Regulatory Disclosure

We will disclose personal data to law enforcement agencies, regulatory bodies or courts when we are legally required to do so — for example, in response to a court order, AML investigation request or gambling regulation compliance audit. We do not make such disclosures voluntarily beyond our strict legal obligations.

We do not share data with social media companies, data brokers or advertising networks. We do not use your data for targeted advertising on external platforms.

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7

International Data Transfers

Some of our third-party service providers — particularly game content suppliers and certain payment processors — operate outside Pakistan. Where your data is transferred internationally, 91 Lucky ensures that appropriate safeguards are in place. These include contractual clauses requiring the recipient to apply the same standard of protection as we do, and where applicable, compliance with recognised international data transfer frameworks. We do not transfer data to jurisdictions that lack adequate legal protections for personal data without contractual safeguards in place.

8

How Long We Keep Your Data

We retain personal data only for as long as necessary for the purposes described in this policy, and in compliance with applicable legal obligations.

  • Active account data: Retained for the lifetime of your account plus 5 years after closure (AML regulatory requirement).
  • Transaction records: Minimum 5 years from the date of each transaction.
  • KYC and identity documents: Minimum 5 years from account closure; reviewed and deleted after that period unless a regulatory hold applies.
  • Support communications: 2 years from the date of interaction, then deleted unless related to an ongoing dispute.
  • Marketing preference data: Until you withdraw consent or close your account.
  • Technical/usage logs: 90 days for detailed logs; aggregated anonymised analytics are retained indefinitely.

When data reaches the end of its retention period, it is securely deleted or anonymised so that it can no longer be linked to you as an individual.

9

How We Secure Your Data

91 Lucky takes data security seriously. We have implemented technical and organisational measures proportionate to the sensitivity of the data we hold. These include:

TLS 1.3 Encryption in Transit

All data exchanged between your browser and 91 Lucky's servers is encrypted using TLS 1.3 — the current industry standard for secure web traffic.

AES-256 Encryption at Rest

Stored personal data — including identity documents and financial records — is encrypted at rest using AES-256 on secured, access-controlled servers.

Access Controls

Internal access to personal data is restricted to staff who need it to do their jobs. All access is logged and reviewed. No single employee has unrestricted access to the full data set.

Intrusion Detection

Automated monitoring scans for unusual login patterns, brute-force attempts and other suspicious activity. Triggered alerts are investigated by our security team within 30 minutes.

Despite our best efforts, no online platform can guarantee absolute security. If you believe your account has been compromised, contact support immediately. In the unlikely event of a data breach that affects your rights and interests, we will notify you and relevant authorities within the timeframe required by applicable law.

10

Cookies and Tracking Technologies

91 Lucky uses cookies and similar technologies to operate certain platform functions, remember your preferences and understand how the platform is being used. Here's what each category of cookie does.

You can manage cookie preferences at any time in your account settings or through your browser settings. Disabling essential cookies will affect platform functionality. Disabling analytics or preference cookies will not prevent you from placing bets or accessing your account.

11

Your Rights Over Your Personal Data

You have meaningful rights over the personal data 91 Lucky holds about you. Here is what you can request and how to do it.

Right of Access

Request a copy of all personal data we hold about you. We'll provide it in a readable format within 15 business days.

Right to Rectification

If any of your data is incorrect or out of date, you can ask us to correct it. Minor updates (address, phone) can be made in account settings directly.

Right to Erasure

Request deletion of your data after account closure. Note that AML regulations require us to retain certain transaction records for 5 years regardless.

Right to Object

Object to processing based on legitimate interests, including direct marketing. We will stop unless we can demonstrate compelling grounds to continue.

Right to Portability

Request your data in a structured, machine-readable format (JSON/CSV) for transfer to another service where technically feasible.

Right to Restriction

Ask us to restrict processing of your data while a dispute or accuracy challenge is being resolved, rather than deleting it outright.

To exercise any of these rights, email support@91lucky.app with the subject line "Data Rights Request." We will acknowledge your request within 2 business days and fulfil it within 15 business days. We may ask for identity verification before actioning a request, to protect your data from unauthorised access.

12

Children's Privacy

The 91 Lucky platform is intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you are a parent or guardian and believe your child has registered on 91 Lucky, please contact us immediately at support@91lucky.app. We will investigate and, if confirmed, delete the account and all associated data without delay. Age verification checks are performed on all accounts as part of our KYC process, and accounts that fail to demonstrate eligibility are suspended pending review.

13

Marketing Communications

With your consent, 91 Lucky may send you promotional emails and SMS messages about bonuses, new games, odds boosts on Pakistan cricket and other offers. You can opt in during registration or through your account notification settings. You can opt out of marketing communications at any time by:

  • Clicking the "unsubscribe" link in any marketing email
  • Replying STOP to any SMS from 91 Lucky
  • Updating your notification preferences in your account settings
  • Emailing support@91lucky.app with "Unsubscribe" in the subject line

Opting out of marketing does not affect transactional communications — we will still send you account security alerts, withdrawal confirmations and important notices about changes to the platform or these policies.

We do not share your contact details with third-party marketing companies. All 91 Lucky communications come directly from our own infrastructure at 91lucky.app.

14

Updates to This Privacy Policy

We review this Privacy Policy regularly and update it when our practices change, when we add new services or when legal requirements evolve. The "Last Updated" date at the top of this page reflects the most recent revision. For material changes that affect your rights or how we use your data, we will notify registered players via email at least 14 days before the changes take effect. Minor clarifications or formatting updates take effect immediately.

We encourage you to check this page periodically. Continued use of the 91 Lucky platform after any update constitutes acceptance of the revised Privacy Policy. If you disagree with any material change, you may close your account before the effective date without penalty.

15

Contact Us and How to Complain

If you have questions about this Privacy Policy, want to exercise a data right or have a concern about how your information is being handled, please contact us:

support@91lucky.app — mark subject as "Privacy Enquiry"
Live chat at 91lucky.app — available 24/7
WhatsApp — number available in your account settings after login

We take privacy complaints seriously and aim to resolve them promptly. If after contacting us you feel your concern has not been adequately addressed, you have the right to escalate the matter to the relevant data protection or gaming regulatory authority in your jurisdiction. We will provide you with the appropriate contact details on request.

Privacy FAQs — Questions Pakistani Players Ask Us Most

These answers are summaries — the full detail is in the policy sections above.

Only when we are legally required to do so — for example, in response to a valid court order or a formal request from a financial intelligence unit as part of an anti-money laundering investigation. We do not proactively share player data with any government body. We will notify you if we receive such a request unless we are legally prohibited from doing so (which can happen in the context of active criminal investigations).

Yes. When you make a deposit or withdrawal via Easypaisa, JazzCash or any other PKR wallet, your wallet number is shared only with the relevant payment provider to complete the transaction. 91 Lucky does not store your full wallet credentials — we retain only a transaction reference. All communication between 91 Lucky and payment providers is encrypted. Your payment data cannot be accessed by other players or by unauthorised staff.

You can close your account at any time by contacting support. After closure and withdrawal of any remaining balance, we will begin the deletion process for your personal data. However, anti-money laundering regulations require us to retain transaction records and identity verification data for a minimum of 5 years after account closure, regardless of your deletion request. This is not optional — it is a legal obligation. After the retention period expires, all remaining data is securely deleted. We will confirm the timeline specific to your account when you submit a deletion request.

Identity verification (KYC) is required by anti-money laundering regulations that apply to online gaming platforms. We use your CNIC to confirm that you are who you say you are, that you are 18 or older and that you are not on any applicable sanctions lists. Your CNIC is shared with our certified identity verification partner to carry out these checks. The result — a pass or fail — is returned to 91 Lucky. Your document image is stored encrypted and is never visible to our customer-facing team after the initial verification review. NICOP is also accepted for overseas Pakistanis. Passports are accepted as an alternative where CNIC is not available.

Register at 91 Lucky — Pakistan's Trusted Platform for Cricket Betting and Casino

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