luke91 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how luke91 ("we", "us", "our", or "the Operator") collects, uses, stores, and shares personal data in connection with your use of the luke91 platform, accessible at luke91.net and all associated pages and subdomains. This Policy applies to all registered players, visitors to the platform, and any other individuals whose personal data is processed by luke91 in connection with the provision of its services.

By registering an account or otherwise using the luke91 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you should not register or continue to use the platform.

This Policy should be read in conjunction with the luke91 Terms & Conditions. Definitions used in the Terms & Conditions apply equally in this Policy unless otherwise stated.

2. Data Controller

For the purposes of applicable data protection law, luke91 is the data controller in respect of the personal data collected and processed through the platform. The Operator's contact details for data-related enquiries are set out in Section 14 of this Policy.

Where luke91 engages third-party service providers to process data on its behalf, those providers act as data processors under contractual arrangements that require them to handle personal data only in accordance with luke91's instructions and applicable data protection requirements.

3. Personal Data We Collect

luke91 collects the following categories of personal data in connection with the operation of the platform:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (such as your CNIC number). This information is required for account registration and KYC verification purposes.
• Contact Data: Email address, mobile phone number, and residential address. This information is used for account communications, verification correspondence, and support interactions.
• Financial Data: Payment method details including JazzCash account numbers, Easypaisa wallet references, or bank account information (HBL, UBL, Meezan Bank, Bank Alfalah) to the extent required for deposit and withdrawal processing. Full payment credentials are not stored on luke91's servers — transaction processing is handled by third-party payment processors.
• Transaction Data: Records of all deposits, withdrawals, bets placed, casino game sessions, and bonus transactions associated with your account. This data is retained for regulatory compliance and dispute resolution purposes.
• Technical Data: IP address, device type, browser type, operating system, session timestamps, and geolocation data at the time of login. This data is collected automatically and used for security, fraud prevention, and platform optimisation purposes.
• Profile Data: Username, account preferences, communication preferences, and responsible gaming settings configured within your account dashboard.
• Compliance Data: Documentation submitted for KYC verification, including copies of identification documents, proof of address, and source of funds documentation where requested.

4. How We Collect Your Data

luke91 collects personal data through the following means:

• Direct submission: Data you provide during account registration, KYC verification, deposit and withdrawal requests, support communications, and responsible gaming tool configuration.
• Automated collection: Technical data collected automatically through your use of the platform, including cookies, session logs, and device fingerprinting technologies.
• Third-party sources: Data received from payment processors, fraud prevention services, identity verification providers, and regulatory databases in connection with compliance obligations.

5. Purposes and Legal Basis for Processing

luke91 processes your personal data for the following purposes and on the corresponding legal bases:

• Account management and service delivery: Processing is necessary for the performance of the contract between you and luke91 (i.e., the Terms & Conditions).
• Identity verification and KYC compliance: Processing is necessary for compliance with legal obligations applicable under luke91's licensing arrangements, including anti-money laundering and know-your-customer requirements.
• Payment processing: Processing is necessary for the performance of the contract and to fulfil transaction requests made by you.
• Fraud prevention and security: Processing is necessary for the legitimate interests of luke91 in maintaining the security and integrity of the platform.
• Responsible gaming monitoring: Processing is carried out in the legitimate interests of luke91 and in fulfilment of operator obligations to identify and assist players who may be at risk of problem gambling behaviour.
• Communications and support: Processing is necessary for the performance of the contract and for luke91's legitimate interest in providing customer support services.
• Marketing communications: Where you have provided explicit consent, luke91 may send you promotional communications regarding platform offers. You may withdraw consent at any time via your account notification settings.

6. Sharing of Personal Data

luke91 does not sell or rent your personal data to third parties. We may share your personal data with the following categories of recipients, strictly to the extent necessary for the stated purpose:

• Payment service providers: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and any other payment processors integrated into the platform, for the purposes of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and document verification services engaged to validate identity documents and screen against regulatory watchlists.
• Fraud prevention and security services: Providers of fraud detection, device fingerprinting, and risk assessment services used to protect the integrity of the platform.
• Regulatory and licensing authorities: Data may be disclosed to our licensing authority or other competent regulatory bodies where required by applicable law or licensing conditions.
• Law enforcement: Where required by applicable law, court order, or at the request of competent government or law enforcement authorities.

All third-party service providers who process personal data on our behalf are contractually required to handle such data solely in accordance with our instructions and applicable data protection requirements, and to implement appropriate security measures.

7. International Data Transfers

As luke91 operates under international licensing arrangements, personal data may be transferred to and processed in jurisdictions outside of Pakistan. Where such transfers occur, luke91 takes appropriate steps to ensure that the receiving party provides an adequate level of data protection, including through contractual arrangements incorporating standard data protection clauses or equivalent safeguards.

8. Data Retention

luke91 retains personal data for as long as is necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory, and licensing obligations. In particular:

• Account and transaction data is retained for a minimum period required by our licensing jurisdiction's anti-money laundering regulations, typically five years from account closure or the date of the last transaction, whichever is later.
• KYC and identity verification documentation is retained for the legally mandated period applicable under our licensing arrangements.
• Technical and session log data is retained for a shorter period consistent with fraud prevention and security purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data destruction procedures.

9. Cookies and Tracking Technologies

The luke91 platform uses cookies and similar tracking technologies to enable core platform functionality, maintain your logged-in session, and collect analytical data about platform usage. The categories of cookies used include:

• Essential cookies: Required for the platform to function. These cannot be disabled without affecting platform functionality.
• Analytical cookies: Used to collect aggregated, anonymised data about how users navigate the platform, enabling us to identify and address usability issues.
• Security cookies: Used to detect and prevent fraudulent activity and to protect the security of your account session.

You may control cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of parts of the luke91 platform.

10. Your Rights as a Data Subject

Subject to applicable data protection law, you have the following rights in respect of the personal data held about you by luke91:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data in certain circumstances, subject to our legal retention obligations.
• Right to restriction of processing: You may request that we restrict the processing of your data in certain circumstances.
• 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.

To exercise any of these rights, please contact the luke91 support team at the details provided in Section 14. We will respond to verified requests within a reasonable timeframe consistent with our obligations.

11. Security Measures

luke91 implements appropriate technical and organisational security measures designed to protect your personal data against accidental loss, unauthorised access, disclosure, alteration, or destruction. These measures include SSL/TLS encryption for all data in transit, access controls and authentication requirements for staff accessing personal data, regular security assessments, and secure data storage practices.

Whilst we take reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

12. Children and Minors

The luke91 platform is strictly restricted to individuals who are 18 years of age or older. luke91 does not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been submitted by or collected in respect of an individual under 18, that data will be deleted and the associated account closed without delay. If you believe that a minor has registered on or is using the luke91 platform, please contact our support team immediately.

13. Amendments to This Policy

luke91 reserves the right to update or amend this Privacy Policy at any time. Material changes to the Policy will be communicated to registered players via their registered email address or through a prominent notice on the platform prior to the effective date of the change. Your continued use of the platform following such notification constitutes acceptance of the revised Policy. We recommend that you review this Policy periodically to remain informed of how your data is handled.

14. Contact and Complaints

For any questions, requests, or concerns regarding this Privacy Policy or the handling of your personal data by luke91, please contact our data protection team at: [email protected]

When submitting a data subject rights request, please include sufficient information to allow us to verify your identity and locate your account. We may request additional verification before processing a data access or deletion request.

If you are dissatisfied with our response to a privacy concern, you may have the right to lodge a complaint with the relevant data protection supervisory authority applicable in your jurisdiction.