luki91 Privacy Policy

This Privacy Policy is issued by luki91 ("luki91," "we," "us," "our"), the operator of the online gaming platform accessible at luki91.net. luki91 is the data controller responsible for the personal data collected through the luki91 website, mobile platform, and all associated services described in this Policy.

For the purposes of this Privacy Policy, "personal data" means any information that identifies or can reasonably be used to identify you as a natural person, either directly or in combination with other information held by luki91. This includes information such as your name, CNIC number, contact details, financial information, and account activity records.

This Policy applies to all registered luki91 account holders, visitors to the luki91 website who have not registered, and any individual whose personal data is processed by luki91 in connection with the services we provide. By accessing or using the luki91 platform, you acknowledge that you have read and understood this Privacy Policy in full.

luki91 collects personal data across several categories depending on the nature of your interaction with the platform. The table below summarises the categories of personal data we collect and specific examples within each category:

luki91 does not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, unless specifically required for the administration of a responsible gaming support case, in which case such data is collected only with your explicit prior consent.

luki91 collects your personal data through the following primary channels:

• Direct Collection: Information you provide voluntarily when registering an account, completing identity verification (KYC), making deposits or withdrawal requests, contacting customer support, or updating your account profile settings.
• Automated Technical Collection: When you access the luki91 website or mobile platform, our systems automatically record technical data including your IP address, device identifiers, browser configuration, and navigation behaviour. This data is collected via server logs, cookies, and similar tracking technologies described in Section 7 of this Policy.
• Third-Party Sources: luki91 may receive personal data about you from third-party identity verification providers, payment processors (such as JazzCash, EasyPaisa, and banking partners), fraud detection services, and age verification agencies. Data received from these sources is used solely to verify your identity, process transactions, and fulfil our compliance obligations.
• Customer Support Interactions: Any communications you initiate with the luki91 support team — whether via live chat, email, or any other channel — are recorded and retained as part of your interaction history for quality assurance and dispute resolution purposes.

luki91 processes your personal data on one or more of the following legal grounds, depending on the specific purpose of processing:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you as a registered luki91 account holder — including operating your account, processing deposits and withdrawals, settling bets, and administering bonuses. Without this processing, luki91 cannot provide its services to you.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including anti-money laundering (AML) obligations, Know Your Customer (KYC) verification mandates, age verification requirements, and financial record-keeping obligations.
• Legitimate Interests: Processing carried out for the legitimate business interests of luki91, including fraud detection and prevention, platform security monitoring, responsible gaming enforcement, customer support quality assurance, and platform performance analytics — provided that these interests are not overridden by your privacy rights.
• Consent: Processing for which you have provided explicit prior consent, including the receipt of marketing communications, promotional emails, and SMS notifications. You may withdraw consent for marketing processing at any time through your account settings or by contacting support, without affecting the lawfulness of any processing carried out prior to withdrawal.

Where luki91 relies on legitimate interests as the legal basis for processing, we conduct an assessment to confirm that the processing is necessary and proportionate, and that your fundamental privacy rights are not outweighed by those interests. You have the right to object to processing based on legitimate interests as described in Section 9 of this Policy.

luki91 uses the personal data we collect for the following documented purposes:

• Account Management: Creating, maintaining, and administering your luki91 account, including processing your registration, verifying your identity, managing your account settings, and communicating important account notifications to you.
• Transaction Processing: Processing all deposits, withdrawals, and internal account transfers in PKR through supported payment methods including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20.
• Gaming Services: Delivering all luki91 gaming products including cricket betting, live dealer casino, slot games, and loyalty program services, and maintaining accurate records of your gaming activity.
• Regulatory Compliance: Fulfilling our obligations under applicable AML regulations, including conducting enhanced due diligence on high-value transactions, reporting suspicious activity to relevant authorities, and maintaining required records for the legally prescribed retention period.
• Fraud Prevention & Security: Monitoring account activity and transactions to detect and prevent fraud, money laundering, account takeover, bonus abuse, and other prohibited conduct as defined in the luki91 Terms & Conditions.
• Responsible Gaming: Monitoring gaming behaviour to identify potential signs of problem gambling and, where appropriate, applying responsible gaming interventions including deposit limits, cooling-off periods, or self-exclusion in accordance with our Responsible Gaming Policy.
• Customer Support: Responding to your enquiries, resolving disputes, processing complaints, and maintaining records of support interactions for quality assurance and training purposes.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive marketing communications. You may opt out of marketing messages at any time.
• Platform Improvement: Analysing aggregated and anonymised usage data to improve the luki91 platform, optimise user experience, and develop new features and services.

luki91 will not use your personal data for any purpose that is incompatible with the purposes described in this Section without first obtaining your explicit consent or establishing an alternative lawful basis for the new processing purpose.

luki91 does not sell, rent, or trade your personal data to any third party. We share your personal data only with the following categories of recipients, and only to the extent strictly necessary for the purposes described in this Policy:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and cryptocurrency payment processors, solely for the purpose of processing your transactions. These providers are contractually bound to process your data only as instructed by luki91 and in accordance with applicable data protection standards.
• Identity Verification Providers: Third-party KYC and age verification service providers that assist luki91 in fulfilling its identity verification and AML compliance obligations. These providers receive only the minimum data necessary to perform the verification function.
• Game Technology Providers: Licensed game developers and live dealer studio operators whose games are made available on the luki91 platform. These providers may receive limited technical and gaming activity data necessary to deliver the game experience and maintain game integrity.
• Fraud Detection & Security Services: Third-party fraud detection and cybersecurity service providers that assist luki91 in monitoring for and preventing fraudulent account activity, bonus abuse, and platform security threats.
• Legal & Regulatory Authorities: Government agencies, law enforcement bodies, financial intelligence units, and regulatory authorities where luki91 is required by law or legitimate legal process to disclose personal data. luki91 will notify you of any such disclosure where it is legally permissible to do so.
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by luki91, subject to professional confidentiality obligations.

All third parties with whom luki91 shares personal data are subject to contractual data processing agreements that require them to implement appropriate technical and organisational security measures and to process personal data only for the purposes specified by luki91.

luki91 uses cookies and similar tracking technologies on its website and mobile platform. Cookies are small text files stored on your device that help luki91 recognise your browser, remember your preferences, and improve the functionality of the platform.

luki91 uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the luki91 platform to function. They enable core features such as maintaining your login session, securing your account, and processing transactions. These cookies cannot be disabled without preventing you from using the luki91 platform.
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred language, display settings, and responsible gaming limits — so you do not need to re-enter them on each visit.
• Performance & Analytics Cookies: These cookies collect aggregated information about how players use the luki91 platform, including pages visited, time spent on page, and navigation paths. This data is used to improve platform performance and user experience. All analytics data is anonymised before analysis.
• Security Cookies: Used by luki91's fraud detection and account security systems to identify potentially suspicious account activity, bot traffic, and unauthorised access attempts.

You may manage your cookie preferences through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or be notified when new cookies are set. Please note that disabling certain categories of cookies may affect the functionality of the luki91 platform.

luki91 does not use advertising cookies or allow third-party advertising networks to place tracking cookies on the luki91 platform.

luki91 retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, subject to any longer retention period required by applicable legal, regulatory, or compliance obligations. The following general retention principles apply:

• Active Account Data: Personal data associated with an active luki91 account is retained for the duration of the account relationship and for a minimum period of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction Records: All deposit, withdrawal, and gaming transaction records are retained for a minimum of five (5) years from the date of each transaction, as required by applicable financial record-keeping regulations.
• KYC Verification Documents: Identity verification documents (CNIC copies, proof of address) are retained for a minimum of five (5) years following account closure or the termination of the business relationship.
• Customer Support Records: Support interaction records, including live chat transcripts and email correspondence, are retained for a period of three (3) years from the date of each interaction.
• Marketing Data: Marketing consent records and communication preferences are retained for the duration of your account relationship and for one (1) year following account closure, or until you withdraw consent, whichever occurs first.
• Technical / Log Data: Server logs and technical access records are retained for a maximum of twelve (12) months, after which they are automatically purged or anonymised.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with luki91's internal data deletion procedures. Anonymised data (which can no longer identify you) may be retained indefinitely for platform analytics and improvement purposes.

As an individual whose personal data is processed by luki91, you have the following rights with respect to your personal data. To exercise any of these rights, please contact luki91 at [email protected] with the subject line "Data Rights Request":

luki91 takes the security of your personal data seriously and implements a comprehensive set of technical and organisational security measures to protect your data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes the following measures:

• Encryption in Transit: All data transmitted between your device and the luki91 platform is protected by 256-bit SSL/TLS encryption. We enforce HTTPS across the entire luki91 domain.
• Encryption at Rest: Sensitive personal data stored on luki91 servers — including financial data and identity documents — is encrypted at rest using industry-standard encryption protocols.
• Access Controls: Access to personal data is restricted to luki91 personnel who have a legitimate need to access it for their role. All staff with access to personal data are subject to confidentiality obligations and regular data protection training.
• Two-Factor Authentication: luki91 supports two-factor authentication (2FA) for player accounts and mandates 2FA for all internal administrative access to systems holding personal data.
• Penetration Testing: luki91 conducts regular independent security assessments and penetration tests of its platform infrastructure to identify and address vulnerabilities before they can be exploited.
• Incident Response: luki91 maintains a documented data breach incident response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, luki91 will notify affected players without undue delay.

While luki91 takes all reasonable steps to protect your personal data, no internet-based system is completely impenetrable. You are responsible for maintaining the security of your own luki91 account credentials. luki91 will never ask you to share your password via any communication channel.

The luki91 platform is strictly intended for adults aged 21 years and above. luki91 does not knowingly collect, process, or store personal data relating to individuals under the age of 21. Age verification is a mandatory step in the luki91 account registration process, and all accounts are subject to ongoing age verification checks.

If luki91 becomes aware that personal data has been collected from an individual under the age of 21 — whether through a false declaration of age at registration or any other means — we will immediately suspend the relevant account, delete all associated personal data to the extent permitted by our legal obligations, and return any deposited funds to the original source of payment.

If you are a parent or guardian and believe that your child has accessed the luki91 platform and provided personal data without your knowledge, please contact luki91 Support immediately at [email protected]. luki91 will investigate and take appropriate action as a matter of priority.

luki91 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements, or platform services. When material changes are made, luki91 will notify registered players by posting the updated Policy on the luki91 website and, where appropriate, by sending a notification to your registered email address. The "Last Updated" date at the top of this page will reflect the date of the most recent revision.

Your continued use of the luki91 platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the updated Policy. If you do not agree with any changes, you may close your account by contacting luki91 Support and requesting account closure.

We encourage you to review this Privacy Policy periodically to stay informed of how luki91 collects, uses, and protects your personal data. The current version of the Privacy Policy is always available at luki91.net/privacy-policy.

Contacting luki91 About Privacy: If you have any questions, concerns, or requests relating to this Privacy Policy or the way luki91 processes your personal data, please contact our data protection team using the details below. We are committed to responding to all privacy enquiries within 5 business days:

• Email: [email protected] (subject line: "Privacy Request")
• Live Chat: Available 24/7 on the luki91 website — average response under 2 minutes

This Privacy Policy was last reviewed and updated in January 2026. luki91 commits to reviewing this Policy at least annually and following any material change in our data processing activities or applicable legal requirements.