lack91 Privacy Policy

lack91 ("we," "us," "our," or "the Company") is the operator of the lack91 online gaming platform accessible at lack91.com. lack91 is a licensed and regulated gaming operator offering sports betting, live casino, slot games, jackpots, and card games to players in Pakistan and other permitted jurisdictions.

For the purposes of this Privacy Policy, lack91 acts as the data controller in respect of the personal information you provide when registering for and using the lack91 platform. As data controller, lack91 determines the purposes and means by which your personal data is processed.

Questions or concerns regarding this Privacy Policy should be directed to our Data Protection team at [email protected]. We are committed to responding to all data-related enquiries within five (5) business days.

lack91 collects personal data in three primary ways: information you provide directly, information collected automatically during your use of the platform, and information obtained from third-party identity verification and payment service providers. The specific categories of data we collect are set out in the table below.

lack91 uses personal data collected from players strictly for the purposes listed below. We do not use your data for any purpose that is incompatible with those purposes without first obtaining your explicit consent.

• Account Management: To create, maintain, verify, and administer your lack91 player account, including processing your registration details and authenticating your identity at login.
• Payment Processing: To process deposits and withdrawals in Pakistani Rupees (PKR) via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card payment networks. Your payment data is shared only with the relevant payment processor for the purpose of completing each transaction.
• KYC & Age Verification: To verify that you are at least 21 years of age and to satisfy our Know Your Customer (KYC) obligations, as required by applicable gaming regulations and anti-money laundering frameworks.
• Game Delivery & Platform Operation: To provide access to cricket betting, live casino, slots, jackpots, Callbreak, and all other games and services available on the lack91 platform.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, multi-accounting, and other prohibited conduct on the platform.
• Responsible Gaming: To monitor gaming behaviour patterns that may indicate problem gambling and to administer self-exclusion, deposit limit, and cool-off requests submitted by players.
• Customer Support: To respond to your queries, complaints, and requests submitted via live chat or email to [email protected].
• Legal & Regulatory Compliance: To fulfil obligations imposed by applicable laws, gaming licences, tax authorities, and law enforcement agencies including the submission of required reports.
• Platform Improvement: To analyse aggregated, anonymised usage data in order to improve the performance, reliability, and user experience of the lack91 platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have opted in to receive marketing communications from lack91. You may opt out at any time.

lack91 processes your personal data on one or more of the following legal bases, depending on the specific purpose of the processing activity:

• Contractual Necessity: Processing that is necessary for the performance of your player agreement with lack91, including account registration, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC identity verification, anti-money laundering reporting, and age verification obligations.
• Legitimate Interests: Processing carried out in pursuit of lack91's legitimate business interests, including fraud detection, platform security, responsible gaming monitoring, and service improvement, provided those interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — principally in relation to marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

lack91 does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. We share data with third parties only to the limited extent necessary for the following purposes:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and international card networks (Visa, Mastercard) receive only the transactional data required to process your deposits and withdrawals. These providers operate under their own privacy and data security frameworks.
• Identity Verification Providers: Third-party KYC and age verification service providers receive identity documents and related data strictly for the purpose of conducting verification checks required by our regulatory obligations.
• Gaming Software Providers: Providers of casino games, sportsbook software, and random number generation services may receive session and gameplay data necessary for the delivery and audit of their games on the lack91 platform.
• Fraud Prevention Services: Anti-fraud and anti-money laundering service providers receive transactional and behavioural data for the purpose of detecting and preventing financial crime on the platform.
• Regulatory & Law Enforcement Authorities: lack91 will disclose personal data to competent regulatory bodies, tax authorities, or law enforcement agencies where required to do so by law, court order, or regulatory direction.
• Professional Advisors: Lawyers, auditors, and accountants engaged by lack91 may access personal data to the extent necessary for the provision of their professional services, subject to confidentiality obligations.

lack91 treats financial data with the highest level of care. We understand that for players in Karachi, Lahore, Faisalabad, Islamabad, and across Pakistan, the security of payment details connected to JazzCash, EasyPaisa, and bank accounts is a primary concern.

Card Data: lack91 does not store full credit or debit card numbers on its servers. Card payments are processed directly by our PCI-DSS-compliant payment processor. lack91 retains only the last four digits of a card number and the card type for account reference purposes.

Mobile Wallet Data: JazzCash and EasyPaisa account references are stored in encrypted form and are used solely for processing withdrawals to the account of the registered player. lack91 does not use mobile wallet references for any purpose other than the processing of transactions initiated by you.

Bank Account Data: Bank account details provided for HBL, UBL, or Meezan Bank withdrawals are encrypted at rest and in transit and are accessible only to authorised payment processing staff under strict access controls.

lack91 uses cookies and similar tracking technologies on its platform for the purposes described below. A cookie is a small text file placed on your device by the lack91 platform when you visit the site.

• Strictly Necessary Cookies: These cookies are essential for the lack91 platform to function. They manage your login session, maintain your account state between pages, and ensure secure navigation. These cookies cannot be disabled without preventing core platform functionality.
• Functional Cookies: These cookies remember your preferences — such as your preferred language and display settings — to personalise your experience on lack91.
• Analytics Cookies: lack91 uses anonymised analytics cookies to understand how players navigate the platform — which pages are visited most, where players encounter difficulties, and how long sessions last. This data is used in aggregate form only to improve platform performance.
• Responsible Gaming Cookies: Session tracking cookies are used to power the session time reminder and reality check features available in your responsible gaming settings.

lack91 does not deploy advertising cookies, cross-site tracking cookies, or cookies that build profiles for third-party behavioural advertising. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the lack91 platform.

lack91 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Active Account Data: Retained for the full duration of your player account relationship with lack91 and for a period of five (5) years following permanent account closure.
• Transaction and Financial Records: Retained for a minimum of seven (7) years from the date of the transaction, in compliance with applicable financial record-keeping requirements.
• KYC & Identity Verification Documents: Retained for five (5) years from the date of verification or from account closure, whichever is later, as required by anti-money laundering regulations.
• Support Communications: Retained for three (3) years from the date of the interaction, unless the communication relates to an ongoing dispute or legal matter in which case it is retained until resolution.
• Self-Exclusion Records: Retained indefinitely to prevent re-registration by self-excluded players and to demonstrate regulatory compliance.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following opt-out as evidence of the consent lifecycle.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised so that it can no longer be linked to an individual.

lack91 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and lack91 servers.
• AES-256 encryption for sensitive data stored at rest, including financial records, identity documents, and password hashes.
• Role-based access controls limiting access to personal data to authorised lack91 personnel whose roles genuinely require such access.
• Regular independent security penetration testing and vulnerability assessments of the lack91 platform infrastructure.
• Multi-factor authentication requirements for all internal lack91 administrative systems that handle player data.
• Comprehensive incident response procedures to contain, assess, and notify affected parties in the event of a data security incident.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, lack91 will notify you without undue delay via the email address registered to your account, and will take all reasonable steps to contain the breach and mitigate its impact.

lack91 may transfer personal data to third-party service providers — including gaming software providers, KYC verification services, and fraud prevention platforms — that operate servers located outside of Pakistan. Where such transfers occur, lack91 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that applied within Pakistan.

Safeguards used for international transfers include contractual data processing agreements incorporating internationally recognised standard data protection clauses, and transfer only to jurisdictions or organisations that maintain demonstrably adequate data protection frameworks.

You may request details of the specific safeguards applicable to any international transfer of your personal data by contacting [email protected].

The lack91 platform is strictly intended for adults aged 21 years and over. lack91 does not knowingly collect, process, or store personal data relating to individuals under the age of 21. Age verification checks are conducted during the registration process, and additional KYC verification may be requested at any time.

If lack91 becomes aware that personal data has been collected from an individual under the age of 21, that data will be immediately deleted, the associated account will be permanently closed, and any deposited funds will be returned to the originating payment method. No winnings will be paid out in respect of gameplay conducted by an underage individual.

As a lack91 player, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request." lack91 will respond within 30 days and may request proof of identity before processing your request.

• Right of Access: You have the right to obtain confirmation of whether lack91 holds personal data about you, and to receive a copy of that data along with information about how it is being processed.
• Right to Rectification: You have the right to have inaccurate or incomplete personal data corrected without undue delay. You may update many account details directly through your lack91 account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to lack91's legal retention obligations.
• Right to Restriction of Processing: You have the right to request that lack91 restricts the processing of your personal data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: You have the right to receive personal data you have provided to lack91 in a structured, commonly used, and machine-readable format for transfer to another service provider where technically feasible.
• Right to Object: You have the right to object to processing of your personal data where lack91 relies on legitimate interests as its legal basis, and to object at any time to the processing of your data for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

With your consent, lack91 may send you promotional emails, SMS messages, and in-platform notifications about bonuses, new games, cricket betting offers (including PSL promotions), jackpot events, and other platform news. Marketing communications are sent only to players who have opted in during registration or via their account settings.

You may withdraw your consent to receive marketing communications at any time by:

• Clicking the "Unsubscribe" link in any marketing email sent by lack91.
• Updating your communication preferences in your lack91 account settings under the Notifications section.
• Contacting support at [email protected] with an opt-out request.

Opting out of marketing communications does not affect the sending of transactional messages — such as deposit confirmations, withdrawal notifications, account security alerts, and important account notices — which lack91 may send regardless of your marketing preferences.

lack91 reserves the right to update or amend this Privacy Policy at any time. Material changes — those that significantly affect how we collect, use, or share your personal data — will be communicated to registered players via email to the address on file no less than fourteen (14) days before the change takes effect.

Minor updates, such as clarifications of existing practices or corrections of typographical errors, may be made without advance notice. The "Last Updated" date at the top of this document will always reflect the date of the most recent revision.

Your continued use of the lack91 platform following the effective date of any revision to this Privacy Policy constitutes your acknowledgement of the updated version. If you do not accept the revised terms, you should cease using the platform and request account closure via [email protected].

If you have any questions, concerns, or requests relating to this Privacy Policy or the way lack91 handles your personal data, please do not hesitate to get in touch with our Data Protection team:

• Email: [email protected] — available 24 hours a day, seven days a week.
• Subject Line: Please use "Privacy Enquiry" or "Data Rights Request" as the subject line to ensure your message is routed to the correct team promptly.
• Response Time: lack91 commits to acknowledging all privacy-related enquiries within 48 hours and to providing a full response within 30 calendar days.