Privacy Policy – How Lucy91 Handles Your Personal Data

1Who We Are

Lucy91 is an online entertainment platform offering casino games, live dealer tables, slot games and related gaming content to adult players. When this Privacy Policy refers to "lucy91", "we", "us" or "our", it means the operator of the lucy91 platform accessible at lucy91.com.

We act as the data controller in respect of the personal information you provide when you register, deposit, play and interact with the platform. This means we are responsible for determining how and why your data is processed, and for ensuring it is handled in a way that is fair, transparent and secure.

If you have any questions about this Privacy Policy or about how your data is handled, you can reach us through the live chat on the platform or by emailing the support address shown in the footer of this page. We will respond to privacy-related queries within a reasonable timeframe.

2Information We Collect

The personal information we collect falls into several categories depending on how you interact with the platform:

We do not collect sensitive categories of personal data such as health information, religious beliefs or political opinions. We collect only what is necessary and proportionate to operating the platform and keeping it safe.

3How We Use Your Information

Lucy91 uses the personal data we collect for the following purposes:

• Account management: Creating and maintaining your account, verifying your identity, processing login requests and keeping your account information accurate and up to date.
• Transaction processing: Handling PKR deposits via JazzCash, Easypaisa, Raast, bank transfer and cards; processing withdrawal requests; and maintaining accurate financial records for your account.
• Platform security and fraud prevention: Monitoring accounts and transactions for irregular activity, detecting and investigating potential fraud, bonus abuse and prohibited conduct, and protecting other players on the platform.
• Customer support: Responding to your queries, resolving complaints, investigating disputed transactions and providing account assistance through live chat and email.
• Responsible gaming: Monitoring gaming patterns to identify signs of problematic behaviour, applying deposit limits or self-exclusion settings you have requested, and communicating responsible gaming information where appropriate.
• Platform improvement: Analysing aggregated usage data to understand how players interact with the platform, which games are most popular, and where the experience can be improved. This analysis uses aggregated, non-identifiable data wherever possible.
• Marketing communications: Sending promotional emails, bonus offers, PSL and cricket-related promotions and other marketing content — but only to players who have opted in to receive such communications.
• Legal compliance: Maintaining records required for audit, financial reporting and responding to lawful requests from relevant authorities.

We do not use your personal data for automated decision-making that produces significant legal effects without human review. If an account is flagged by our monitoring systems, the flag is reviewed by a member of the team before any action is taken.

4Legal Basis for Processing

Every time lucy91 processes your personal data, we do so on one of the following legal grounds:

• Contract performance: Processing your registration data, transaction data and gaming activity is necessary to deliver the services described in our Terms and Conditions. Without this processing, we cannot operate your account.
• Legitimate interests: Fraud detection, security monitoring, platform improvement and responsible gaming oversight are carried out on the basis of our legitimate interest in operating a safe and fair platform. We balance this against your interests and rights and only process what is proportionate.
• Legal obligation: Retaining transaction records and identity verification documents may be required to comply with applicable financial and anti-money-laundering obligations.
• Consent: Marketing communications are sent only where you have given clear, specific consent. You can withdraw consent at any time without affecting your ability to use the platform.

5Sharing Your Information

Lucy91 does not sell, rent or trade your personal information. We share your data only in the following limited circumstances:

• Payment processors: To process PKR deposits and withdrawals via JazzCash, Easypaisa, Raast, bank transfer and card networks. These providers receive only the data needed to complete the transaction and are bound by their own privacy and security obligations.
• Identity verification providers: When KYC verification is required, your identity documents and personal details are shared with a third-party verification service. This provider acts as a data processor under our instructions and does not use your data for any other purpose.
• Fraud prevention networks: In cases of confirmed fraud, chargeback abuse or prohibited conduct, relevant account and transaction information may be shared with payment industry fraud prevention databases to protect the wider ecosystem.
• Technology and hosting providers: The platform runs on third-party infrastructure. Hosting and technology providers may process your data as part of delivering services to lucy91. These providers are subject to data processing agreements that restrict how they can use your information.
• Legal and regulatory requests: If we receive a lawful and properly documented request from a relevant authority, we may be required to disclose specific account or transaction information. We will only disclose what is specifically requested and legally required.

All third parties who process personal data on behalf of lucy91 are required to handle it securely, use it only for the specified purpose and not retain it beyond what is necessary. We do not allow any third party to use your data for their own marketing purposes.

6Payment Data and Security

Financial transactions on lucy91 involve sensitive payment data. We take the security of this data seriously and have implemented the following measures:

• All data transmitted between your device and our servers is protected using TLS encryption. This applies to login, registration, deposits, withdrawals and any other data exchange.
• Full payment card numbers are not stored on lucy91 servers. Card transactions are handled directly by our payment processor, which is responsible for storing card data in compliance with applicable payment security standards.
• JazzCash and Easypaisa transactions are processed through the respective providers' secure APIs. Lucy91 receives confirmation of payment status but does not store mobile wallet PINs or passwords.
• Access to financial data within lucy91's systems is restricted to authorised personnel who require it to perform their job functions. Access is logged and reviewed regularly.

7Cookies and Tracking

Lucy91 uses cookies — small text files stored on your device — to make the platform work properly and to understand how it is being used. The cookies we use fall into the following categories:

• Essential cookies: These are required for the platform to function. They maintain your login session, remember your language preference and keep your account secure during an active session. The platform cannot function correctly without these cookies.
• Analytics cookies: These help us understand how players navigate the platform — which pages are visited most, how long sessions last and where players encounter issues. This data is aggregated and does not identify you personally. It is used solely to improve the platform experience.
• Preference cookies: These remember choices you have made on the platform, such as game filters or display preferences, so you do not need to set them again each time you visit.

Lucy91 does not use advertising or retargeting cookies. We do not share cookie data with advertising networks.

You can control cookie settings through your browser. Most browsers allow you to block or delete cookies. Blocking essential cookies will affect platform functionality, including the ability to stay logged in. Blocking analytics or preference cookies will not affect your ability to play games or manage your account.

8Data Retention

Lucy91 retains personal data for as long as is necessary for the purposes for which it was collected, subject to the following general principles:

• Active accounts: Personal data associated with an active account is retained for the duration that the account remains open and for a reasonable period thereafter to handle any outstanding queries or disputes.
• Closed accounts: Following account closure, core account and transaction records are retained for a period necessary to meet financial record-keeping obligations and to defend against any potential legal claims arising from the account's activity.
• Identity verification documents: Documents submitted for KYC verification are retained for the period required to meet the applicable obligations and are then securely deleted.
• Support communications: Chat transcripts and email records are retained for a period sufficient to resolve related queries and complaints, and then deleted in line with our internal data management schedule.
• Marketing data: If you have opted in to marketing and subsequently opt out, your contact details are removed from active marketing lists promptly and retained only on a suppression list to ensure you are not inadvertently contacted again.

When data is no longer required, it is securely deleted or anonymised so that it can no longer be linked to you as an individual. Anonymised, aggregated data may be retained indefinitely for statistical and platform improvement purposes.

9Your Rights Over Your Data

As a user of lucy91, you have the following rights in relation to your personal information:

• Right of access: You can request a copy of the personal data lucy91 holds about you at any time. We will provide this in a clear format within a reasonable timeframe.
• Right to correction: If any of the information we hold about you is inaccurate or incomplete, you have the right to ask us to correct it. For most account details, you can update these directly through your account settings.
• Right to erasure: You can request that we delete your personal data. We will action this request where there is no overriding legal reason to retain it. Note that some data — particularly transaction records — may need to be retained for a minimum period regardless of an erasure request.
• Right to restrict processing: In certain circumstances, you can ask us to temporarily stop processing your data while a query or complaint is being resolved.
• Right to data portability: You can request your personal data in a structured, commonly used format so that it can be transferred to another service if you wish.
• Right to withdraw consent: Where processing is based on your consent — such as for marketing communications — you can withdraw that consent at any time without affecting any prior processing that took place.

To exercise any of these rights, contact our support team through live chat or via the support email address shown in the footer. We may need to verify your identity before processing the request to protect your account from unauthorised access.

10Children's Privacy

Lucy91 is strictly an adult platform. We do not knowingly collect or process personal data from anyone under the age of 18. Our registration process includes a date-of-birth check, and accounts that cannot be verified as belonging to an adult are not permitted to access the platform.

If we become aware that personal data has been collected from someone under the age of 18, we will close the associated account and delete the data as quickly as possible. Parents or guardians who believe a minor has registered on lucy91 should contact our support team immediately so that the account can be closed and the data removed without delay.

We also encourage players with children in their household to make use of device-level parental controls to prevent access to online gaming platforms. More information on keeping children safe online is available from reputable internet safety organisations.

11Changes to This Policy

Lucy91 may update this Privacy Policy from time to time to reflect changes in how we operate, the services we offer, or relevant obligations. When we make material changes, we will update the "Last Updated" date at the top of this page and, where the changes are significant, notify registered players via email or an in-platform notification.

We encourage you to review this Privacy Policy periodically so you stay informed about how your data is being handled. The most current version of the policy is always available on this page at lucy91.com/privacy-policy.

Continued use of the platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you disagree with any changes, you should stop using the platform and contact support to request account closure.

12Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or to the way lucy91 handles your personal data, please get in touch with our support team. We are available 24 hours a day, seven days a week throughout the year.

You can reach us through the live chat feature on the platform for the fastest response, or by emailing the address shown in the footer of this page. When submitting a data-related request, please include your registered username and a brief description of the request so we can assist you as efficiently as possible.