luck91 Privacy Policy — Your Data, Your Rights

1 Introduction

This Privacy Policy ("Policy") describes how luck91 ("we", "us", "our") collects, processes, stores and protects the personal data of users ("you", "User") who access or use the website located at https://luck91.cam ("the Site").

luck91 is an English-language online gaming information platform serving the Pakistan market. We publish educational guides on casino games, sports betting, responsible gambling, payment methods and account management. We are not a gambling operator, and we do not process financial transactions on behalf of any gambling platform.

This Policy forms part of our broader legal framework alongside our Terms & Conditions. By using the Site, you acknowledge that you have read and understood this Policy. If you do not agree with how we handle personal data, please discontinue use of the Site.

2 Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

3 Data We Collect

3.1   luck91 may collect the following categories of Personal Data from Users of this Site:

3.2   luck91 does not collect, process or store the following categories of data in connection with the Site:

• Financial data such as bank account numbers, card details or wallet credentials;
• Government identification numbers such as CNIC or passport numbers;
• Biometric data or health-related information;
• Data relating to gambling transactions, wagers, deposits or withdrawals (as luck91 is not a gambling operator).

4 How We Collect Data

4.1   Directly from you: When you voluntarily contact luck91 by email or through any enquiry mechanism on the Site, we collect the communication data you provide (such as your email address and the content of your message).

4.2   Automatically: When you access or browse the Site, we automatically receive and record technical data including your IP address, browser details and page-access logs through our web server infrastructure. This is standard practice across virtually all websites and does not require explicit action from you.

4.3   Via cookies and similar technologies: Cookies and equivalent tracking technologies may collect session and usage data as described in Section 8 of this Policy. Where required by applicable law, we obtain your consent prior to setting non-essential cookies.

4.4   From third-party analytics services: We may use third-party web analytics tools to process aggregated or pseudonymised usage data. These services process data under their own privacy terms, and we do not receive personally identifiable information from them beyond what we would already hold through our own infrastructure.

5 Legal Basis for Processing

5.1   luck91 processes Personal Data only where a valid legal basis exists. The principal legal bases we rely upon are:

• Legitimate interests: Processing technical and usage data to operate, secure and improve this Site, where those interests are not overridden by User rights and freedoms;
• Consent: Where you have given explicit consent for the processing of particular data for a specific purpose (such as optional analytics cookies), which you may withdraw at any time;
• Contractual necessity: Where processing is required to respond to your voluntary communications or to fulfil obligations arising from your use of the Site under our Terms & Conditions;
• Legal obligation: Where processing is required to comply with a legal obligation imposed on luck91 by applicable law.

5.2   Where we rely on consent as the legal basis, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 How We Use Your Data

6.1   luck91 uses the Personal Data we collect for the following purposes only:

• To operate, maintain and improve the technical performance of the Site;
• To analyse how Users navigate and interact with the Site so we can improve content structure, educational guides and page usability;
• To respond to queries, complaints or requests you submit by email or via any enquiry mechanism;
• To ensure the security of the Site, detect fraudulent or abusive access patterns, and protect against technical threats;
• To comply with any applicable legal or regulatory obligation;
• To administer cookies and user preference settings in line with your expressed choices.

6.2   We do not use your data for:

• Unsolicited direct marketing or promotional email campaigns (we do not maintain a marketing mailing list);
• Automated profiling that produces legal or similarly significant effects on you;
• Resale, transfer or licensing of your data to third parties for their commercial use.

7 Data Sharing and Disclosure

7.1   We do not sell your personal data. luck91 will never sell, rent or otherwise transfer your Personal Data to third parties for their own independent marketing, commercial or data-brokerage purposes.

7.2   We may share Personal Data with carefully selected third parties only in the following circumstances:

• Service providers and data processors: Trusted suppliers who assist in operating the Site, such as web hosting providers, content delivery networks, server infrastructure providers and analytics platforms. These parties act only on our instruction and are bound by appropriate data processing agreements;
• Legal compliance: Where disclosure is required by applicable law, court order, or the lawful request of a competent regulatory or law enforcement authority;
• Protection of rights: Where disclosure is reasonably necessary to protect the rights, property or safety of luck91, its users or the public, including fraud prevention and cybersecurity purposes;
• Business transfers: In the event of a merger, acquisition or sale of all or substantially all of luck91's assets, Personal Data may be transferred to the successor entity, subject to equivalent privacy protections.

7.3   References to payment providers familiar to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — appear in our educational content for contextual illustration only. luck91 has no data-sharing relationship with any of these institutions, and no Personal Data collected by luck91 is shared with these providers.

8 Cookies & Tracking Technologies

8.1   luck91 uses cookies and similar browser-based tracking technologies to support the operation of the Site. Cookies are small text files stored on your device that allow the Site to recognise your browser session and retain certain preference information.

Types of Cookies We May Use

8.2   You may manage or disable cookies through your browser settings at any time. Most modern browsers — including those commonly used in Pakistan on Android and iOS devices — allow you to view, block or delete cookies from within the browser's privacy or settings menu.

8.3   Disabling strictly necessary cookies may impair the functionality of certain Site features. Disabling analytical or functional cookies will not prevent you from accessing educational content on the Site.

9 Data Retention

9.1   luck91 retains Personal Data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law.

9.2   The following indicative retention periods apply:

• Server and access logs (technical data): Typically retained for up to 12 months for security and infrastructure diagnostic purposes, then deleted or anonymised;
• Email and communication data: Retained for a reasonable period (generally up to 24 months) to manage ongoing correspondence and to handle any related disputes or legal obligations, after which it is securely deleted;
• Analytics data: Retained in aggregated or pseudonymised form for up to 26 months, in line with common analytics platform standards, then purged;
• Cookie preference records: Retained for up to 12 months or until you withdraw consent, whichever is sooner.

9.3   When Personal Data is no longer required for the relevant purpose and there is no legal obligation to retain it, we take reasonable steps to securely delete, anonymise or aggregate it so that it can no longer be associated with an identifiable individual.

10 Data Security

10.1   luck91 implements appropriate technical and organisational security measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures in place include, but are not limited to:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your browser and our servers;
• Access controls limiting Personal Data access to authorised personnel only, on a need-to-know basis;
• Regular review of our security posture and infrastructure vulnerabilities;
• Secure data storage practices and encrypted database configurations where applicable.

10.2   While we take these measures seriously, no data transmission over the internet or electronic storage system is 100% secure. We cannot guarantee the absolute security of Personal Data and disclaim liability for breaches that fall outside our reasonable control.

10.3   In the event of a Personal Data breach that is likely to result in a risk to your rights and freedoms, we will take prompt action in accordance with applicable legal obligations, which may include notifying affected individuals where required by law.

11 Your Rights as a Data Subject

11.1   Depending on applicable data protection law in your jurisdiction, you may have the following rights in relation to Personal Data that luck91 holds about you:

11.2   To exercise any of the rights listed above, please contact us using the details provided in Section 13 of this Policy. We will respond to your request within a reasonable timeframe and, where required by law, within any statutory deadline applicable in your jurisdiction.

11.3   We may need to verify your identity before fulfilling a data subject request, to ensure we do not inadvertently disclose or delete another person's data in error.

11.4   If you believe your data rights have not been adequately addressed, you may have the right to lodge a complaint with a relevant supervisory or data protection authority in your jurisdiction.

12 Minors & Age Restriction

12.1   The luck91 Site is intended exclusively for adults. We do not knowingly collect Personal Data from individuals under the age of 18, or below the higher minimum age required by the operator or licence jurisdiction applicable to users in their location.

12.2   If you are under the applicable minimum age, you must not use this Site or provide any Personal Data to us. If you are a parent or guardian and believe your child has provided Personal Data to luck91, please contact us immediately using the details in Section 13, and we will take prompt steps to delete that data.

13 Contact Us

13.1   If you have any questions, concerns, complaints or requests regarding this Privacy Policy or the way luck91 processes your Personal Data, please contact us using the details below.

13.2   Data Controller: luck91 (operated under the domain https://luck91.cam)

13.3   Email: [email protected] (plain text only — not a clickable link)

13.4   Please include "Privacy Policy Enquiry" or "Data Subject Request" in the subject line of your correspondence. We aim to acknowledge receipt of your query promptly and to provide a substantive response within a reasonable timeframe, consistent with applicable legal requirements.

13.5   For queries related to responsible gambling rather than data privacy, please visit our dedicated Responsible Gambling page, which contains specific guidance and support resource information for players in Pakistan and internationally.