Lucy91 Privacy Policy – How We Collect & Use Your Data

01 Overview

Lucy91 operates an online gaming and sports betting platform designed for adult users in Pakistan. In the course of providing the platform and its services, we collect and process certain personal information. This Privacy Policy describes what that information is, why we need it, and how it is managed.

We take your privacy seriously. Personal data collected by Lucy91 is used only for the purposes set out in this policy. It is not sold to third parties for marketing. It is stored with security measures appropriate to the nature of the information held.

If you are reading this before registering: by creating a Lucy91 account, you confirm you have read this policy and consent to the processing of your personal data as described here. If you are already a registered user: this policy applies to all data collected from the moment of your account creation to the present day.

02 Data We Collect

The categories of personal data Lucy91 collects are as follows:

Identity & Contact Data

Your full name, date of birth, CNIC number (where required for identity verification), mobile number, and email address. This information is collected during registration and identity verification processes.

Financial & Transaction Data

Records of your PKR deposits and withdrawals, including transaction amounts, timestamps, payment method identifiers (such as your JazzCash or Easypaisa account number), and transaction reference numbers. We do not store full card numbers or bank account credentials — payment processing is handled by our payment processor partners using their own secure systems.

Platform Usage Data

Records of your activity on the Lucy91 platform: game sessions played, bets placed, bonus usage, VIP tier progress, login history, device information, IP address, and browser or app version data.

Communication Data

Records of communications between you and Lucy91 support, including live chat transcripts, email correspondence, and any documentation you provide during identity verification or dispute resolution.

03 How We Collect Your Data

Lucy91 collects data through the following means:

• Direct registration: Information you provide when creating your account, completing identity verification, or updating your profile.
• Platform activity: Data generated automatically as you use the platform — game sessions, bets, deposits, withdrawals, and navigation within the app or website.
• Device and technical data: Your IP address, device model, operating system version, and browser or app information are captured automatically when you connect to the platform.
• Support interactions: Data you provide when contacting our support team, including details you share to resolve account issues or disputes.
• Cookies and tracking technologies: As described in Section 9 of this policy, we use cookies and similar technologies to maintain session state, improve performance, and understand platform usage patterns.

04 How We Use Your Data

Your data is used for the following purposes only:

• Account administration: Creating and maintaining your account, authenticating logins, and managing your preferences and settings.
• Transaction processing: Processing PKR deposits and withdrawals via JazzCash, Easypaisa, Raast, bank transfer, and card payments. Maintaining an accurate transaction history in your account.
• Identity verification: Confirming your identity in accordance with our anti-fraud and anti-money-laundering obligations before processing withdrawals above applicable thresholds.
• Platform performance: Monitoring and improving platform speed, game availability, and mobile app stability — particularly important given that most Pakistan players access Lucy91 via mid-range Android devices on 4G connections.
• Fraud detection and security: Monitoring for suspicious activity such as multi-account registration, payment fraud, and bonus abuse.
• Responsible gaming: Using your platform activity data to power tools such as deposit limits, session reminders, and self-exclusion — and to detect patterns that may indicate problematic play requiring support outreach.
• Customer support: Using your account and communication history to resolve support queries effectively.
• Legal compliance: Retaining records as required by applicable law and cooperating with lawful requests from authorities.

Lucy91 does not use your data for unsolicited marketing to third parties, and we do not build or sell advertising profiles based on your activity on our platform.

05 Sharing Your Data

Lucy91 does not sell your personal data. We share it only in the following limited circumstances:

• Payment processors: Your transaction data is shared with our payment processing partners — JazzCash, Easypaisa, Raast, and card payment processors — to the extent required to complete deposits and withdrawals. These partners operate under their own privacy policies and security standards.
• Game software providers: Your gameplay session data is shared with our game software suppliers to the extent required for game functionality, fairness auditing, and technical support.
• Identity verification services: Where third-party identity verification tools are used, your submitted identity documents are processed by those services under strict data protection terms.
• Legal and regulatory authorities: Where required by law or in connection with a lawful investigation, Lucy91 may share account and transaction data with regulatory bodies, law enforcement, or financial intelligence agencies.
• Anti-fraud networks: We may share fraud indicators — such as flagged IP addresses or device fingerprints — with industry fraud prevention networks to protect users across the platform.

06 Payment Data & PKR Transactions

All financial transactions on Lucy91 are processed in PKR. When you make a deposit or withdrawal, your payment details are transmitted directly to the relevant payment processor — JazzCash, Easypaisa, Raast, your bank, or a card processing network.

Lucy91 does not store your full card number, bank account number, or mobile wallet PIN. What Lucy91 retains is a transaction record: the amount, timestamp, payment method type, a masked identifier (for example, the last four digits of a card or the first and last two digits of a mobile number), and the transaction reference number.

This transaction history is stored in your account and is used for your records, for resolving disputes, and for compliance with our financial record-keeping obligations. It is accessible to you through your account transaction history at any time.

07 Data Retention

Lucy91 retains your personal data for as long as your account is active and for a period afterwards as required by our legal obligations and operational needs.

• Account identity data is retained for the lifetime of the account and for a minimum of five years following account closure, in line with standard financial record-keeping requirements.
• Transaction records are retained for a minimum of five years following each transaction.
• Support communication records are retained for a minimum of two years.
• Platform usage logs (game sessions, betting records) are retained for a minimum of two years.

After the applicable retention period, data is deleted or anonymised. Anonymised data — from which no individual can be identified — may be retained for longer periods for analytical purposes.

08 Security

Lucy91 implements technical and operational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encrypted transmission of data between your device and our servers using TLS.
• Encrypted storage of sensitive personal data fields.
• Access controls that limit which personnel can view personal data, and only to the extent required for their function.
• Regular security reviews of platform infrastructure.
• Fraud monitoring systems that flag unusual account activity for review.

No security system is completely impenetrable. In the unlikely event of a data breach that affects your personal data, Lucy91 will notify affected users as required and take appropriate remediation steps.

You also have a role in account security: use a strong, unique password, do not share your login credentials with anyone, and contact support immediately if you suspect unauthorised access to your account.

09 Cookies & Tracking Technologies

Lucy91 uses cookies and similar local storage technologies to operate the platform. These are small data files stored in your browser or app. They are used for the following purposes:

• Session cookies: Keep you logged in during your session on the platform. These expire when you close your browser or app.
• Preference cookies: Remember your platform settings, such as your language preference or game lobby filter selections.
• Security cookies: Help detect and prevent fraudulent activity, including flagging unusual login locations or device changes.
• Performance cookies: Collect anonymised data on how the platform is used — which pages load slowly, which games are accessed most — so we can improve performance. No personally identifiable information is contained in these cookies.

Lucy91 does not use third-party advertising cookies or allow advertising networks to place tracking cookies on our platform. You can control cookie behaviour through your browser settings. Disabling session cookies will prevent you from remaining logged in to the platform.

10 Your Rights Over Your Data

As a registered user of Lucy91, you have the following rights regarding your personal data:

To exercise any of these rights, contact Lucy91 support through the live chat in your account or by email at [email protected]. Requests will be processed within 30 days wherever possible.

11 Minors

Lucy91 is strictly an adult platform. Users must be 18 years of age or older to register or use any part of the platform. We do not knowingly collect personal data from anyone under the age of 18.

If Lucy91 becomes aware that a registered account belongs to a person under 18, the account will be closed immediately and all data associated with it will be deleted as quickly as our legal obligations allow. If you believe a minor has registered on the platform, please contact support immediately.

12 Changes to This Policy

Lucy91 may update this Privacy Policy from time to time. When we make material changes, we will notify registered users through an in-platform notification or by email to the address registered on your account. The updated policy will take effect from the date stated at the top of the page.

Continued use of the Lucy91 platform after the effective date of any updated policy constitutes acceptance of those changes. If you disagree with any changes, you should stop using the platform and may request account closure by contacting support.

13 Contact

If you have questions about this Privacy Policy, want to exercise your data rights, or need to raise a data-related concern, please contact Lucy91 through the following channels:

Live Support Chat: Available 24/7 inside your account dashboard.

Email: [email protected]

Privacy and data-related requests are handled by our support team with priority. If you are making a formal data access or deletion request, please state this clearly in your message so it can be routed appropriately.