laki91 Privacy Policy

laki91 (referred to throughout this Privacy Policy as "laki91", "we", "us", or "our") is an online gaming and sports betting platform accessible at https://laki91.net. laki91 operates under an internationally recognised gaming licence and serves players across Pakistan, with dedicated support for Pakistani payment methods and localised gaming content.

For the purposes of this Privacy Policy, laki91 is the data controller in respect of all personal information collected from registered players and website visitors. This means we determine the purposes and means by which your personal data is processed. Where we engage third-party processors — such as payment gateways or KYC verification providers — we remain responsible for ensuring those processors handle your data in accordance with this policy.

laki91 collects personal data across two broad categories: information you provide directly when registering or interacting with the platform, and information collected automatically as you use our services. The specific data points within each category are described below.

Information You Provide Directly:

• Identity Data: Full legal name, date of birth, gender, and nationality as provided during account registration and KYC verification.
• Contact Data: Email address, mobile number, and city of residence (e.g., Karachi, Lahore, Islamabad, or Faisalabad).
• Identity Document Data: CNIC number, passport number, or other government-issued identification number provided during the KYC verification process.
• Financial Data: Payment method details including JazzCash account number, EasyPaisa wallet ID, bank account identifiers (HBL, UBL, Meezan Bank), card details (Visa/Mastercard), or USDT wallet address. Full card numbers are never stored by laki91 — they are processed directly by our PCI-DSS compliant payment processor.
• Transaction Data: Records of all deposits, withdrawals, bonus credits, and wagering activity associated with your laki91 account, including amounts in PKR and timestamps.
• Communications Data: Content of messages sent to laki91 support via live chat, email, or any in-platform feedback mechanism.
• Responsible Gaming Data: Any deposit limits, cool-off periods, or self-exclusion preferences you configure within your account settings.

Information Collected Automatically:

• Technical Data: IP address, device type, operating system, browser type and version, and screen resolution.
• Usage Data: Pages visited on laki91.net, time spent on each page, games played, bet history, and session duration.
• Cookie and Tracking Data: Data collected via cookies and similar technologies as described in Section 7 of this policy.
• Geolocation Data: Approximate location derived from IP address, used to enforce jurisdictional access controls.

laki91 collects personal data through the following channels and mechanisms:

• Account Registration: When you create a laki91 account, you provide identity and contact data directly via the registration form.
• KYC Verification: When you submit identity documents to complete the Know Your Customer process, laki91 receives and stores the relevant document data via our regulated KYC provider.
• Deposits and Withdrawals: Financial data is captured when you initiate a transaction through any supported payment method, including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, Mastercard, or USDT.
• Platform Usage: Technical and usage data is collected automatically each time you access laki91.net, whether or not you are logged in to an account.
• Customer Support: When you contact laki91 via live chat or email, the content and metadata of that communication is recorded and associated with your account where applicable.
• Cookies and Tracking Technologies: Cookies, web beacons, and local storage mechanisms collect behavioural and technical data as described in Section 7.
• Third-Party Sources: In limited circumstances, laki91 may receive data from third-party fraud prevention or AML screening services where this is necessary to meet our regulatory obligations under our gaming licence.

laki91 processes personal data only where a valid legal basis exists under applicable data protection law. The primary legal bases on which laki91 relies are as follows:

• Contractual Necessity: Processing required to deliver the services you have registered for — including account management, game delivery, and payment processing — is carried out on the basis that it is necessary for the performance of our contract with you.
• Legal Obligation: Certain processing activities are mandatory under our gaming licence conditions and applicable AML regulations. This includes KYC identity verification, transaction record-keeping, and suspicious activity reporting. These processing activities cannot be opted out of; they are non-negotiable requirements of operating a regulated gaming platform.
• Legitimate Interests: laki91 processes certain data — such as security monitoring, fraud detection, and platform analytics — on the basis of legitimate interests. We conduct a balancing test to ensure these interests do not override your fundamental rights and freedoms before relying on this basis.
• Consent: Where laki91 relies on your consent as the legal basis for processing — for example, in relation to optional marketing communications — you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Consent withdrawal does not affect your ability to use the laki91 platform.

laki91 uses the personal data it collects for the following specific purposes. We do not use your data for any purpose that is incompatible with the purposes listed below without first obtaining your consent or establishing a fresh legal basis.

• To create and manage your laki91 account, including processing your registration, maintaining your PKR wallet balance, and administering your account preferences.
• To verify your identity and age as part of the KYC process, ensuring compliance with our gaming licence obligation that all active players are aged 21 years or above.
• To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, Mastercard, and USDT, and to maintain accurate transaction records.
• To deliver the gaming services you access on laki91, including cricket betting markets, PSL fixtures, casino games, live dealer tables, and slot titles.
• To administer bonus offers, free bet credits, and promotional campaigns in accordance with the terms of each active promotion.
• To detect and prevent fraud, money laundering, account abuse, and any other prohibited conduct as defined in our Terms & Conditions.
• To provide customer support and to respond to enquiries, complaints, and dispute resolution requests submitted via live chat or email.
• To send transactional communications, including deposit confirmations, withdrawal notifications, and account security alerts.
• To enforce responsible gaming measures including deposit limit monitoring, session time tracking, cool-off period management, and self-exclusion enforcement.
• To improve laki91 platform performance through aggregated analytics, A/B testing, and user experience research.
• To send marketing communications about laki91 bonuses, promotions, and new game launches — only where you have provided explicit consent.

laki91 does not sell, rent, or trade your personal data. We share personal data only in the limited circumstances described below, and only to the minimum extent necessary to fulfil the stated purpose.

• Payment Processors: Financial data is shared with our regulated payment processing partners — including those facilitating JazzCash, EasyPaisa, and bank transfer transactions — solely to process your deposits and withdrawals. These partners are PCI-DSS compliant and operate under strict data processing agreements.
• KYC and Identity Verification Providers: Identity document data is shared with our licensed KYC verification partner to fulfil our regulatory age and identity verification obligations. This provider processes data only on laki91's instructions and does not retain data beyond the verification workflow.
• Fraud Prevention and AML Screening Services: laki91 may share limited account and transaction data with regulated fraud prevention and AML compliance services where required under our gaming licence obligations.
• Game Content Providers: When you play a third-party game on laki91 — such as a slot or live dealer title — a session token and anonymised player identifier may be shared with the game provider's platform to facilitate gameplay. No personally identifiable information is shared beyond what is strictly necessary for game session management.
• Regulatory and Law Enforcement Authorities: laki91 will disclose personal data to competent regulatory bodies, law enforcement agencies, or courts of law where we are legally compelled to do so, or where such disclosure is necessary to prevent serious harm.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of the laki91 platform, player data may be transferred to the acquiring entity. Affected players will be notified in advance of any such transfer and will retain all data rights described in this policy.

laki91 uses cookies and similar technologies — including web beacons, local storage objects, and session identifiers — to operate the platform effectively and to understand how players interact with our services. This section explains the categories of cookies we use and how you can manage your preferences.

You can manage cookie preferences through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies will prevent laki91 from functioning correctly and may result in your session being terminated. Disabling analytics or marketing cookies will not affect your ability to use the platform.

laki91 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and our gaming licence conditions. The specific retention periods applicable to each data category are set out below.

• Account and Identity Data: Retained for the duration of your active laki91 account plus a minimum of 5 years following account closure. This retention period is mandated by our gaming licence AML compliance obligations.
• KYC Document Data: Identity document images and verification records are retained for a minimum of 5 years from the date of verification, in accordance with anti-money laundering regulatory requirements.
• Financial and Transaction Data: Complete deposit and withdrawal records, including PKR amounts, timestamps, and payment method identifiers, are retained for a minimum of 7 years to satisfy financial record-keeping obligations.
• Customer Support Communications: Live chat transcripts and email correspondence are retained for 3 years from the date of the most recent interaction, or for the duration of any unresolved dispute.
• Marketing Consent Records: Records of your marketing opt-in or opt-out decisions are retained for the life of your account plus 2 years, to evidence compliance with consent obligations.
• Technical and Usage Data: Anonymised analytics data may be retained indefinitely as it no longer constitutes personal data once de-identified. Individually attributable usage logs are retained for 12 months.

Upon expiry of the applicable retention period, laki91 will securely delete or anonymise your personal data. Where deletion is not immediately possible due to backup cycle constraints, data will be isolated from active processing until it can be securely destroyed.

As a laki91 player, you hold a number of rights in relation to the personal data we hold about you. These rights may be subject to certain limitations where overriding legal obligations — such as AML record-keeping requirements — prevent immediate fulfilment. laki91 will always inform you of any applicable limitation and the reason for it.

• Right of Access: You may request a copy of all personal data laki91 holds about you. Requests are fulfilled within 30 days at no charge. Where a request is manifestly excessive or repetitive, laki91 reserves the right to charge a reasonable administrative fee.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data. Note that verified KYC data — such as your registered name and date of birth — cannot be altered without resubmitting valid identity documentation.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected and no overriding legal retention obligation applies. Erasure requests submitted alongside an account closure request will be actioned within 30 days.
• Right to Restriction: You may request that laki91 restrict the processing of your personal data in certain circumstances — for example, while a rectification request is being assessed.
• Right to Data Portability: You may request a copy of the personal data you have provided to laki91 in a structured, commonly used, and machine-readable format (CSV or JSON), where technically feasible.
• Right to Object: You may object to the processing of your personal data where laki91 relies on legitimate interests as the legal basis. laki91 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent — such as marketing communications — you may withdraw consent at any time via your account notification settings or by contacting support.

To exercise any of the above rights, please contact laki91 at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 5 business days and provide a substantive response within 30 days.

laki91 implements a multi-layered technical and organisational security framework to protect your personal data against unauthorised access, loss, alteration, or disclosure. Our key security measures include:

• Transport Encryption: All data transmitted between your browser or device and laki91's servers is protected by TLS 1.2 or higher. Our SSL certificate is maintained and renewed continuously to ensure uninterrupted encryption coverage.
• Data Encryption at Rest: Sensitive personal data stored on laki91 servers — including CNIC references and payment identifiers — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within laki91's internal systems is restricted on a strict need-to-know basis. Staff access is role-based, logged, and subject to regular review. Multi-factor authentication is required for all internal system access.
• Penetration Testing: laki91 conducts regular third-party security audits and penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: laki91 maintains a documented data breach response procedure. In the event of a breach that poses a risk to your rights and freedoms, laki91 will notify affected players without undue delay and, where required, report the breach to the relevant supervisory authority within 72 hours of discovery.

laki91 operates a strict 21+ age policy and does not knowingly collect, process, or store personal data belonging to individuals under the age of 21. The laki91 platform is not intended for, marketed to, or accessible by minors.

As part of our registration process and KYC verification, laki91 requires all players to confirm they are aged 21 or above and to submit valid government-issued identity documentation confirming date of birth. Any account found to belong to a person under the age of 21 will be immediately suspended and all associated balances will be withheld pending investigation in accordance with our responsible gaming procedures.

laki91 is operated from a jurisdiction outside Pakistan and may process and store personal data on servers located in jurisdictions other than Pakistan. Where personal data is transferred internationally, laki91 ensures that appropriate safeguards are in place to maintain the same standard of data protection as described in this policy.

• Transfers to third-party processors — such as KYC providers, payment processors, and game content providers — are governed by binding data processing agreements that require those parties to protect data to an equivalent standard.
• Where transfers are made to jurisdictions that do not have a domestic legal framework providing an adequate level of data protection comparable to international best practices, laki91 implements additional contractual safeguards to protect the data in transit and at rest.
• laki91 does not transfer personal data to jurisdictions subject to sanctions or where such transfers would be prohibited by applicable law.

laki91 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. The version number and last-updated date displayed at the top of this page indicate the current operative revision.

Where changes are material — meaning they significantly affect your rights or the way laki91 processes your personal data — laki91 will notify registered players via email or an in-platform notification at least 7 days before the updated policy takes effect. Continued use of the laki91 platform following the effective date of a policy update constitutes acceptance of the revised Privacy Policy.

We encourage all players to review this page periodically to stay informed about how laki91 protects your personal data. Previous versions of this policy are available upon request from the laki91 support team.

If you have any questions, concerns, or complaints regarding laki91's data processing practices or this Privacy Policy, please contact our Data Protection team using the details below. We take all privacy-related correspondence seriously and commit to responding substantively within 10 business days.

If you are not satisfied with laki91's response to a privacy complaint, you have the right to escalate your concern to the relevant supervisory authority or to the regulatory body overseeing our gaming licence. laki91 will cooperate fully with any such regulatory enquiry.