Privacy Policy

luck93 ("we", "us", "our") operates the online gaming and sports betting information platform accessible at luck93.cam. We are committed to protecting the personal data of every individual who accesses or uses our platform, and to being transparent about how that data is handled.

This Privacy Policy ("Policy") describes the categories of personal data we collect, the purposes for which we process that data, the parties with whom we may share it, the safeguards we apply to protect it, and the rights available to you in relation to your personal data.

This Policy applies to all users of the luck93 platform, including registered account holders and visitors who browse without registering. It should be read alongside our Terms & Conditions and Responsible Gambling Policy.

For the purposes of this Privacy Policy, the following definitions apply:

• "Controller" means luck93, the entity that determines the purposes and means of processing your personal data.
• "Data Subject" means any identified or identifiable natural person whose personal data is processed by luck93 — in most cases, this is you, the user.
• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, IP address, device identifiers and financial information.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, transfer or deletion.
• "Processor" means any third party that processes personal data on behalf of luck93 under a written data processing agreement.
• "Sensitive Data" means personal data revealing racial or ethnic origin, political opinions, religious beliefs, health information, biometric data or financial data requiring heightened protection.
• "Platform" means the luck93 website, mobile site and all associated services accessible at luck93.cam.

We collect personal data through several channels — directly from you when you register or interact with the Platform, automatically through your use of the Platform, and from third-party sources where legally permitted. The categories of data we collect are set out in the table below.

We do not intentionally collect Sensitive Data as defined in Section 2 unless strictly required by our legal or regulatory obligations. Where such collection is unavoidable — for example, health-related data provided voluntarily in connection with responsible gambling self-exclusion — it will be treated with the highest level of protection.

luck93 processes your personal data only where a valid legal basis exists. The applicable legal bases are:

• Contractual Necessity: Processing required to fulfil the contract between you and luck93 — for example, operating your account, processing deposits and withdrawals, and delivering the gaming services you have requested.
• Legal Obligation: Processing required to comply with applicable laws, including anti-money-laundering (AML) regulations, know-your-customer (KYC) requirements, responsible gambling obligations and tax reporting duties.
• Legitimate Interests: Processing that serves luck93's legitimate business interests — such as fraud prevention, platform security, analytics and service improvement — provided those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific and informed consent — for example, sending you marketing communications or placing non-essential cookies on your device. You may withdraw consent at any time without affecting the lawfulness of prior processing.

luck93 uses the personal data we collect for the following purposes:

• Account Management: To create, verify, maintain and close your account, and to authenticate your identity each time you log in.
• Service Delivery: To provide access to the full range of gaming and sports betting content on the Platform, including cricket markets, PSL T20 and ICC tournament events, casino games and live dealer experiences.
• Transaction Processing: To process deposits, withdrawals and refunds through available payment methods, and to maintain accurate financial records of all transactions in PKR and other supported currencies.
• KYC & Fraud Prevention: To verify your age and identity, detect and prevent fraudulent activity, money laundering, collusion and other prohibited conduct, and to comply with applicable AML obligations.
• Responsible Gambling: To monitor gaming patterns that may indicate problem gambling, to enforce self-exclusion and account limits you have set, and to contact you if we have genuine welfare concerns about your account activity.
• Customer Support: To respond to your enquiries, process complaints and provide technical assistance through our support channels.
• Marketing Communications: Where you have given your consent, to send you promotional offers, bonus notifications and platform updates. You may opt out at any time.
• Platform Improvement: To analyse usage patterns, conduct internal research, test new features and improve the overall user experience for players across Pakistan.
• Legal Compliance: To meet our obligations under the applicable licensing framework and any other laws or regulations that govern our operations.

luck93 does not sell, rent or trade your personal data to any third party for their own marketing or commercial purposes. We share personal data only in the following circumstances:

• Payment Processors: We share necessary financial data with payment processing partners to facilitate deposits and withdrawals. Payment method names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced as familiar local contexts only. These institutions do not endorse luck93 and receive no user data from luck93 except through their own payment infrastructure.
• KYC & Identity Verification Providers: We share identity documents and verification data with contracted KYC service providers solely for the purpose of age and identity verification.
• Fraud & AML Prevention Partners: We may share relevant data with fraud detection and anti-money-laundering compliance services to protect the integrity of the Platform.
• Technology & Hosting Partners: Infrastructure providers and cloud hosting services that process data on our behalf under strict contractual data processing agreements.
• Regulatory & Law Enforcement Authorities: We will disclose personal data to regulatory bodies, courts or law enforcement agencies when legally required to do so, or when disclosure is necessary to protect the rights, property or safety of luck93, its users or the general public.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets involving luck93, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

luck93 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage and support security. The types of cookies we use are as follows:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable core features such as session management, login authentication and security checks. These cannot be disabled without significantly impairing the Platform's functionality.
• Analytical / Performance Cookies: These cookies help us understand how users interact with the Platform — which pages are most visited, how long sessions last and where errors occur. This information is used in aggregate and anonymised form to improve the user experience.
• Functional Cookies: These cookies remember your preferences, such as language settings, display options and responsible gambling limit configurations, so you do not need to re-enter them on each visit.
• Marketing Cookies: Where you have consented, these cookies help us deliver relevant promotional content and track the effectiveness of marketing campaigns. You may withdraw consent for marketing cookies at any time.

You can manage, restrict or delete cookies through your browser settings at any time. Please note that disabling certain cookies may affect the availability and performance of some Platform features. For detailed guidance on managing cookies in your specific browser, refer to your browser's help documentation.

luck93 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory or contractual obligations. Our general retention periods are as follows:

• Active Account Data: Retained for the duration of your account relationship with luck93, plus any legally mandated post-closure retention period.
• Financial Transaction Records: Retained for a minimum of five (5) years following the transaction date, in line with standard AML and financial record-keeping requirements.
• KYC & Verification Documents: Retained for a minimum of five (5) years following account closure, or longer if required by the applicable licensing jurisdiction.
• Customer Support Communications: Retained for up to three (3) years from the date of the interaction, or longer if relevant to an ongoing dispute or legal matter.
• Marketing Consent Records: Retained for as long as your consent remains active, plus a reasonable period following withdrawal of consent to demonstrate compliance.
• Technical & Log Data: Typically retained for up to twelve (12) months for security monitoring and platform diagnostic purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with you as an individual.

luck93 operates in an international environment and may transfer your personal data to processors or infrastructure providers located outside your country of residence, including outside Pakistan. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place to protect your data, including:

• Transfers to countries recognised as providing an adequate level of data protection by the applicable regulatory framework;
• Standard contractual clauses or equivalent contractual safeguards approved by competent data protection authorities; and
• Binding corporate rules or other legally approved transfer mechanisms where applicable.

By using the Platform and providing your personal data, you acknowledge that your data may be transferred to, stored in and processed in jurisdictions outside Pakistan. luck93 does not represent that all such jurisdictions provide the same level of data protection as Pakistan, but we commit to applying the safeguards described in this Policy regardless of where processing occurs.

Subject to applicable law and our legal retention obligations, you have the following rights in relation to the personal data luck93 holds about you. To exercise any of these rights, please contact us at [email protected] (plain text — not a clickable link). We will respond within 30 days of receiving a valid request.

The luck93 platform is strictly intended for adults. We do not knowingly collect, process or store personal data from any individual under the age of 18 — or the higher minimum age required by the applicable operator or license jurisdiction.

If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close any associated account without delay. If you believe a minor has registered an account or provided personal data to luck93, please contact us immediately at [email protected] (plain text).

Parents and guardians are encouraged to use available parental control software to prevent underage access to online gambling platforms. luck93 supports the use of such tools and cooperates with recognised child protection initiatives where applicable.

luck93 applies industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss or destruction. Our security programme includes:

• Encryption in Transit: All data transmitted between your device and the luck93 platform is encrypted using TLS (Transport Layer Security) protocols.
• Encryption at Rest: Sensitive stored data, including financial records and identity documents, is encrypted at rest using robust encryption standards.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and receive regular data protection training.
• Secure Authentication: Account login is protected by secure password hashing and, where available, two-factor authentication (2FA) options.
• Regular Security Reviews: The Platform undergoes periodic security assessments and vulnerability testing to identify and remediate potential risks.
• Incident Response: In the event of a personal data breach that poses a risk to your rights and freedoms, luck93 will notify affected users and relevant authorities as required by the applicable legal framework.

Whilst we implement robust safeguards, no digital platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect any unauthorised access to your Account.

luck93 reserves the right to update or amend this Privacy Policy at any time. Changes may be required to reflect updates to our services, changes in applicable law, or improvements to our data protection practices.

When we make material changes to this Policy, we will update the "Last Updated" date displayed at the top of this page and, where appropriate, notify registered users by email or via a notice within the Platform. We encourage you to review this Policy periodically to remain informed about how we handle your personal data.

Your continued use of the Platform following any update to this Policy constitutes your acknowledgement of the revised terms. If you do not agree with any changes, you should cease using the Platform and contact us to request closure of your Account.

If you have any questions, concerns or complaints about this Privacy Policy, or if you wish to exercise any of your data subject rights, please contact the luck93 privacy team using the details below. We aim to acknowledge all privacy enquiries within 5 business days and provide a substantive response within 30 days.

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Privacy Enquiries: "Privacy Policy Enquiry" or "Data Subject Request"
• Platform Support: Submit a support ticket through the help centre within your Account dashboard for non-urgent privacy questions.

For responsible gambling enquiries — including data held in connection with self-exclusion orders, limit settings or welfare interventions — please visit our Responsible Gambling page for dedicated guidance and contact options.