Summary: This Privacy Policy describes how 91 lucky ("91 lucky", "we", "us") collects, processes, stores, and protects personal data belonging to users ("you", "Player") of the 91 lucky platform at 91lucky.pro. By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy. This policy should be read alongside our Terms & Conditions.
1. Introduction
1.1 91 lucky is committed to protecting the personal data of every player on the Platform. We understand that when you share your personal information with us — including your name, Pakistan mobile number, and financial details — you are placing trust in us to handle that information responsibly.
1.2 This Privacy Policy sets out in plain, clear English exactly what data we collect, the purposes for which we use it, the conditions under which we share it with third parties, how long we keep it, and the rights you have in relation to your own data.
1.3 This policy is effective from 1 January 2026 and applies to all current and prospective 91 lucky account holders in Pakistan.
2. Data Controller
2.1 For the purposes of applicable data protection law, the data controller responsible for your personal data is 91 lucky, operating the platform at 91lucky.pro.
2.2 If you have any questions or concerns about how your data is handled, you may contact our Data Protection team at: [email protected] (displayed as plain text — not a clickable link). Our English-speaking support team is available 24/7 via WhatsApp and Telegram.
3. Data We Collect
3.1 Depending on how you interact with 91 lucky, we may collect the following categories of personal data:
3.1 Identity and Contact Data
- Full legal name as it appears on your Pakistani CNIC;
- Date of birth (required to verify 18+ eligibility);
- Pakistan mobile phone number;
- Email address (where provided);
- CNIC number and a copy of your CNIC document (for KYC verification).
3.2 Financial Data
- PKR deposit and withdrawal amounts and dates;
- Payment method details (e.g., Easypaisa mobile account number, JazzCash account, HBL or UBL bank account details, SadaPay wallet ID) — stored only to the extent required to process transactions;
- Transaction reference numbers and payment statuses.
3.3 Account and Gaming Data
- Username and encrypted account password;
- Game play history, bet amounts, win/loss records, and session durations;
- Bonus usage history and promotional participation records;
- Responsible gaming settings (deposit limits, session reminders, self-exclusion status).
3.4 Technical and Device Data
- IP address and approximate geographic location;
- Device type, operating system, and browser type;
- Pages visited, time spent on page, and clickstream data;
- Cookie identifiers and session tokens.
3.5 Communications Data
- Records of your communications with 91 lucky Support via WhatsApp, Telegram, or email;
- Feedback and survey responses where voluntarily submitted.
4. How We Collect Data
4.1 We collect personal data through the following means:
- Direct provision: Data you enter when registering an account, completing KYC, initiating deposits or withdrawals, or contacting our support team;
- Automated collection: Technical data collected automatically as you browse and use the Platform, via cookies and server logs;
- Third-party providers: KYC verification partners may return identity confirmation results to us; payment processors (Easypaisa, JazzCash, HBL, UBL, SadaPay) provide transaction status updates.
5. How We Use Your Data
5.1 91 lucky uses your personal data for the following purposes:
| Purpose | Data Used |
|---|---|
| Account creation and management | Identity, contact, and account data |
| Processing PKR deposits and withdrawals | Identity, financial, and KYC data |
| Age verification (18+ compliance) | Date of birth and CNIC data |
| KYC and anti-money-laundering checks | Identity, financial, and transaction data |
| Fraud prevention and security | Technical, financial, and gaming data |
| Delivering promotions and bonuses | Account and gaming data |
| Responsible gaming monitoring | Gaming and account data |
| Customer support | Identity, contact, and communications data |
| Platform analytics and improvement | Technical and gaming data (anonymised where possible) |
| Legal and regulatory compliance | All relevant data categories |
6. Legal Basis for Processing
6.1 We process your personal data on the following legal bases:
- Contract performance: Processing necessary to register your account, manage your PKR balance, and provide the services you have signed up for;
- Legal obligation: Processing required for KYC, anti-money-laundering compliance, age verification, and other regulatory requirements;
- Legitimate interests: Processing for fraud prevention, platform security, and improving our service, where these interests are not overridden by your privacy rights;
- Consent: Where we send you optional marketing communications or set non-essential cookies, we do so only with your consent, which you may withdraw at any time.
7. Sharing Your Data
7.1 91 lucky does not sell your personal data to any third party. We may share your data only in the following limited circumstances:
- Payment processors: Easypaisa, JazzCash, HBL, UBL, and SadaPay receive the minimum necessary data to process your PKR transactions;
- KYC and identity verification providers: To fulfil our regulatory obligations regarding age and identity verification;
- Game software providers: Where game fairness auditing or technical integration requires sharing of limited session data;
- Legal and regulatory authorities: Where we are required by law, court order, or regulatory authority to disclose your data;
- Business transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to the same privacy protections.
7.2 All third-party service providers who access your data are contractually required to process it only for the specified purpose, to maintain its confidentiality, and to apply appropriate security measures.
8. Payment Data
8.1 91 lucky takes the security of your financial data extremely seriously. We do not store full payment card numbers on our servers. All PKR payment transactions are processed via our integrated payment partners (Easypaisa, JazzCash, HBL, UBL, SadaPay) who operate under their own security and compliance frameworks.
8.2 Transaction records, including deposit amounts, withdrawal amounts, payment method type, and dates, are retained on our systems for regulatory compliance purposes and to resolve any disputes that may arise.
PKR Only: All financial data on 91 lucky relates exclusively to Pakistani Rupee (PKR) transactions. We do not process foreign currency payments or hold foreign currency balances.
9. Cookies and Tracking Technologies
9.1 91 lucky uses cookies and similar tracking technologies to operate the Platform effectively and to improve the player experience. Cookies are small text files placed on your device when you visit the Platform.
9.2 We use the following types of cookies:
- Essential cookies: Required for the Platform to function correctly, including maintaining your login session and security tokens. These cannot be disabled without affecting Platform functionality;
- Functional cookies: Remember your preferences (e.g., language settings, last-played games) to personalise your experience;
- Analytics cookies: Help us understand how players navigate the Platform, which pages are most visited, and where technical issues arise. Data is aggregated and anonymised where possible;
- Session cookies: Temporary cookies that expire when you close your browser, used to maintain your current session state.
9.3 You may manage cookie preferences through your browser settings. Please note that disabling essential cookies may impair your ability to log in or use certain features of the Platform.
10. Data Security
10.1 91 lucky implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:
- 256-bit SSL/TLS encryption for all data in transit between your device and our servers;
- Encrypted storage of passwords using industry-standard hashing algorithms;
- Access controls limiting data access to authorised personnel only on a need-to-know basis;
- Regular security reviews and vulnerability assessments of Platform infrastructure;
- Automated fraud detection and anomaly monitoring systems.
10.2 While we take every reasonable precaution to protect your data, no method of electronic transmission or storage is 100% secure. In the event of a data breach that is likely to result in a risk to your rights or interests, we will notify you in accordance with applicable legal requirements.
11. Data Retention
11.1 We retain your personal data for as long as your 91 lucky account is active and for a reasonable period thereafter to allow us to resolve disputes, enforce our agreements, and comply with legal obligations.
11.2 Specific retention periods are determined by the following factors:
- KYC and identity verification records are typically retained for a minimum of five (5) years following account closure, in line with anti-money-laundering regulatory requirements;
- Financial transaction records are retained for a minimum of five (5) years;
- Gaming session logs and account history are retained for three (3) years following your last login;
- Customer support communications are retained for two (2) years.
11.3 When retention periods expire, data is securely deleted or anonymised.
12. Your Privacy Rights
12.1 As a 91 lucky player, you have the following rights in relation to your personal data:
- Right of access: You may request a copy of the personal data we hold about you;
- Right to rectification: You may request that inaccurate or incomplete data be corrected;
- Right to erasure: In certain circumstances, you may request that your data be deleted — subject to our legal obligations to retain certain records;
- Right to restrict processing: You may request that we limit how we use your data in certain situations;
- Right to data portability: Where technically feasible, you may request a copy of your data in a structured, machine-readable format;
- Right to object: You may object to processing based on our legitimate interests, including direct marketing;
- Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
12.2 To exercise any of these rights, contact 91 lucky Support at [email protected] or via WhatsApp/Telegram. We will respond to all requests within 30 days. We may need to verify your identity before processing certain requests.
13. Minors (Under 18)
13.1 91 lucky is strictly an 18+ platform. We do not knowingly collect or process personal data belonging to individuals under the age of 18. If we become aware that a minor has registered an account or provided personal data, we will immediately close the account and delete the associated data.
Age Restriction: If you believe a minor may have accessed 91 lucky using an account in your name or on your device, contact our Support team immediately. We treat underage access prevention as a core responsibility.
14. Changes to This Privacy Policy
14.1 91 lucky reserves the right to update this Privacy Policy at any time. When material changes are made, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered players through the Platform.
14.2 Your continued use of the Platform following any update constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how we protect your data.
15. Contact Us About Privacy
If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to raise a privacy-related concern, please contact us through the following channels:
- Email: [email protected] (plain text — not a clickable link)
- WhatsApp & Telegram: Available 24/7 in English
- Platform: 91lucky.pro
We aim to acknowledge all privacy-related enquiries within 2 business days and to provide a substantive response within 30 days.
Effective Date: This Privacy Policy is effective as of 1 January 2026. It supersedes all prior privacy notices published by 91 lucky and applies to all personal data currently held and processed by the Platform.