Privacy Policy for Laki 91 — How We Handle Your Data

01 Who We Are

Laki 91 is an online gaming platform serving Pakistani users, offering sports betting (cricket, football), live casino games, and card games including Teen Patti, Poker, and Baccarat — all conducted in Pakistani Rupees (PKR). The platform is accessible at laki91.app and operates as the data controller for all personal information collected from its users.

For any privacy-related enquiry, you can reach us at support@laki91.app. Our support team handles data-related requests alongside general account queries and will route your request to the appropriate person within the organisation without delay.

This policy applies to all individuals who visit or use the Laki 91 platform — registered members, visitors who browse without registering, and individuals who contact us through any channel. The policy does not cover third-party websites that may be linked to from our platform, though as per our Terms and Conditions, we do not add external links to our pages.

02 What Data We Collect

Laki 91 collects personal information through several channels. Here is a clear breakdown of what we collect and when:

Information You Provide Directly

• Registration data: Full name, date of birth, Pakistani phone number, and email address provided when you create your account;
• Identity verification documents: CNIC number and/or a photo of your CNIC, requested as part of our Know Your Customer (KYC) process before large withdrawals are processed;
• Payment information: Mobile wallet numbers (Easypaisa, JazzCash), NayaPay/SadaPay account details, or bank account information provided when depositing or withdrawing. Full payment credentials are processed by payment processors and not stored by Laki 91 in recoverable form;
• Support communications: Content of messages you send through live chat or email, which we retain for quality assurance and dispute resolution purposes.

Information Collected Automatically

• Device information: Device type, operating system, browser type, and screen resolution — used to optimise the mobile experience for Pakistani users;
• IP address: Used for fraud detection, duplicate account monitoring, and general security purposes;
• Session data: Login timestamps, pages visited, games played, bet amounts, and session duration — used for account management, responsible gaming monitoring, and service improvement;
• Cookies and similar technologies: Described in detail in Section 07 of this policy.

Data Category	Collected At	Retained For
Registration details	Sign-up	Duration of account + 5 years
CNIC / KYC documents	Verification request	5 years from verification
Transaction records	Each deposit / withdrawal	7 years (financial regulation)
Betting / game history	Each bet / game round	Duration of account + 3 years
Support chat logs	Each support session	2 years from last contact
Device & session data	Each login session	12 months rolling

03 How We Use Your Data

Laki 91 uses the personal data we collect for specific, legitimate purposes. We do not use data for purposes that would be surprising or inconsistent with the reason you provided it. Here is how your information is used:

• Account creation and management: Your registration data is used to set up and maintain your Laki 91 account, verify your identity, and process your transactions in PKR;
• Payment processing: Transaction data is used to credit deposits, process withdrawals to your Easypaisa or JazzCash wallet, and maintain an accurate account balance;
• Fraud prevention and security: IP address data, device information, and session activity are used to detect duplicate accounts, suspicious betting patterns, and unauthorised login attempts;
• Responsible gaming monitoring: Your gaming activity data — frequency, stake amounts, session durations — is monitored so Laki 91 can identify patterns that may indicate problematic gambling and reach out proactively where appropriate;
• Customer support: Contact details and support chat history are used to respond to your enquiries, investigate disputes, and process account changes;
• Legal compliance: Transaction records and identity data are retained to comply with anti-money laundering obligations and to cooperate with regulatory or law enforcement requests where legally required;
• Platform improvement: Aggregated, anonymised session and usage data helps us understand which features are popular, where users encounter difficulties, and how to improve the overall experience;
• Marketing communications: Where you have opted in, we may send you promotional emails or platform notifications about bonuses, new games, or special offers. You can opt out at any time.

04 Legal Basis for Processing

Laki 91 processes your personal data on the following legal grounds depending on the type of processing involved:

• Contract performance: Processing necessary to operate your account, process transactions, and deliver the services you signed up for — this covers registration data, payment information, and gaming activity;
• Legal obligation: Processing required to comply with anti-money laundering regulations, identity verification requirements, and any lawful regulatory or law enforcement request — this covers CNIC data and transaction records;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring — where our legitimate interest in maintaining a safe and fair platform is balanced against your privacy interest;
• Consent: Processing of data for direct marketing communications — this is opt-in and can be withdrawn at any time.

05 Sharing Your Data with Third Parties

Laki 91 shares your personal data with third parties only where strictly necessary and only for the purposes outlined in this policy. We do not sell personal data. Parties we may share data with include:

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, banks, and card networks receive transaction-level data necessary to process your deposits and withdrawals. Each processor operates under their own privacy policy and is independently responsible for data they handle;
• Identity verification providers: Where automated CNIC verification is used, document data may be processed by a third-party KYC provider. These providers are contractually bound to handle data securely and only for verification purposes;
• Platform infrastructure providers: Cloud hosting, server, and CDN providers may have access to data stored on their infrastructure. These are processors acting on Laki 91's instructions with contractual data protection obligations;
• Regulatory authorities and law enforcement: Laki 91 may be required by law to disclose personal data or transaction records to relevant Pakistani authorities. We will comply with lawful requests and will notify the affected member where legally permitted to do so;
• Fraud prevention networks: In cases of suspected fraud, data may be shared with industry fraud prevention services to prevent harm to other platforms and members.

06 Payments & Financial Data

Given that all Laki 91 transactions are conducted in Pakistani Rupees through local payment methods, financial data handling deserves specific explanation.

When you initiate a deposit via Easypaisa or JazzCash, the actual fund transfer is initiated through the respective mobile money network. Laki 91 receives a transaction confirmation and reference number — it does not receive or store your mobile money PIN or full account password. Your Easypaisa or JazzCash account is linked to your Laki 91 account by the registered phone number, which Laki 91 retains for account matching and withdrawal processing purposes.

When you request a withdrawal, Laki 91 initiates a payment instruction to the relevant processor using the account details you registered. Laki 91 retains the record of this instruction and the outcome (success or failure) for your transaction history. If a withdrawal fails due to an incorrect account number or wallet limit, the funds are returned to your Laki 91 wallet balance automatically.

Transaction records — deposit amounts, withdrawal amounts, bet stakes, and game winnings — are retained for a minimum of seven years from the transaction date. This retention period is required for financial compliance purposes and applies even after account closure.

07 Cookies & Tracking Technologies

Laki 91 uses cookies and similar browser storage technologies to operate the platform and improve your experience. Here is what each type does:

Essential Cookies

These are required for the platform to function. They maintain your login session, remember your account preferences, and keep your game state intact if you temporarily lose connection. These cookies cannot be disabled without breaking core platform functionality.

Analytics Cookies

Laki 91 uses first-party analytics to understand how users navigate the platform — which pages are visited most, where sessions start and end, and how long users spend in different sections. This data is aggregated and anonymised and does not identify individual users. Analytics cookies can be declined via your browser settings without affecting your ability to use the platform.

Security Cookies

Short-lived cookies are used during login and payment flows to verify that actions are being taken by a legitimate session holder and to protect against cross-site request forgery. These are a security requirement and cannot be disabled.

08 Data Retention

Laki 91 retains personal data for as long as it is needed to provide the service and meet legal obligations. When an account is closed voluntarily, we delete or anonymise personal data according to the schedule in Section 02, subject to the following minimum retention periods required by law or legitimate business interest:

• Transaction records and financial data — minimum seven years;
• Identity verification documents — minimum five years from verification date;
• Account registration data — minimum five years after account closure;
• Responsible gaming intervention records — minimum five years, to ensure re-registration after a self-exclusion period respects the original exclusion.

Where Laki 91 is legally required to retain data beyond these periods, we will do so and will notify you if possible. Data retained beyond the minimum periods is stored with restricted access and is not used for marketing or service improvement purposes.

09 Security Measures

Laki 91 implements a range of technical and organisational measures to protect your personal data from unauthorised access, loss, or misuse:

• Transport encryption: All data between your device and Laki 91 servers is encrypted using TLS 1.2 or higher;
• At-rest encryption: Sensitive data stored in Laki 91 databases is encrypted at rest using industry-standard algorithms;
• Access controls: Internal access to personal data is restricted on a need-to-know basis. Support staff can see account and transaction data necessary to assist you; they cannot access full payment credentials or CNIC document images once verification is complete;
• Login security: Accounts support two-factor authentication. Login activity from unrecognised devices triggers email notifications. Multiple failed login attempts trigger a temporary account lock;
• Regular security reviews: Platform infrastructure undergoes periodic security assessments to identify and address vulnerabilities.

No security measure is foolproof. In the unlikely event of a data breach that poses a risk to your personal data, Laki 91 will notify affected members promptly with details of what was affected and what steps to take.

10 Exercising Your Data Rights

As a Laki 91 member, you have the rights described in the introductory section of this page. Here is how to use them:

1. Submit your request by emailing support@laki91.app with the subject line "Data Rights Request — [your registered name]". Include a brief description of what you are requesting;
2. Identity verification — we will verify your identity before fulfilling any data rights request. This typically involves confirming your registered phone number and may require CNIC verification for deletion or full access requests;
3. Response timeline — Laki 91 will acknowledge your request within 48 hours and provide a substantive response within 30 days. Complex requests may require up to 60 days, in which case we will notify you of the extended timeline;
4. No fees — Data rights requests are free of charge. If a request is clearly unfounded or excessive, we may decline it and explain why.

11 Children's Privacy

Laki 91 is strictly an 18+ platform and does not knowingly collect personal data from individuals under the age of 18. Age verification is performed during registration and may be enhanced with CNIC verification before withdrawals are processed.

If Laki 91 becomes aware that a registered account belongs to a person under 18, the account will be immediately closed and any real-money deposits will be returned to the original payment method. Any gaming activity conducted through the underage account will be voided. If you have reason to believe a minor has registered on Laki 91, please contact us at support@laki91.app immediately.

12 Changes to This Privacy Policy

Laki 91 may update this Privacy Policy from time to time as the platform evolves, as laws change, or as we add new features that affect how data is processed. When material changes are made, we will:

• Update the "Last Updated" date at the top of this page;
• Notify registered members via email or a prominent platform notification;
• Where required by law, request renewed consent for any new data processing activities.

Continued use of the Laki 91 platform following notification of changes constitutes acceptance of the updated policy. If you disagree with any changes, you have the right to close your account and request deletion of your data — subject to mandatory retention periods outlined in Section 08.

13 Contact & Complaints

For any privacy-related question, concern, or to exercise your data rights, contact Laki 91 through the following channels:

If you are not satisfied with how Laki 91 has handled a privacy concern after raising it with us directly, you have the right to raise the matter with the relevant data protection authority in Pakistan. Laki 91 will cooperate fully with any regulatory enquiry conducted in accordance with applicable law.

For questions about the Terms and Conditions or the Responsible Gaming policy, the same support channels apply. These documents form part of the overall framework governing your use of the Laki 91 platform.