lucky101
Privacy Policy

This Privacy Policy is published by lucky101, an online gaming platform operating at lucky101.bio and serving registered players primarily based in Pakistan. lucky101 is licensed under an international gaming licence, details of which are available on our About Us page. For the purposes of this Privacy Policy, lucky101 acts as the data controller in respect of all personal data collected from registered players and website visitors.

As data controller, lucky101 is responsible for determining the purposes for which your personal data is processed and the means by which that processing takes place. We are committed to handling your personal data lawfully, transparently, and in accordance with the principles set out in this Privacy Policy.

lucky101 collects several categories of personal data from players and website visitors. The specific data collected depends on your level of engagement with the platform — browsing without an account results in minimal data collection, while full account registration and active gameplay involves a broader range of personal data being processed.

lucky101 does not intentionally collect special category data (such as health information, religious beliefs, or political opinions) from players. If you voluntarily disclose such information during a support interaction, it will be used solely to address your specific query and will not be stored beyond the resolution of that query.

lucky101 collects personal data through a combination of direct inputs from you, automated technical collection, and in some cases through third-party service providers. The primary collection methods are as follows:

• Direct submission: Data you provide when you complete the lucky101 account registration form, submit KYC documents, initiate a deposit or withdrawal, contact our support team, or respond to a promotional survey.
• Automated technical collection: Data collected automatically when you access the lucky101 platform, including your IP address, device identifiers, browser cookies, session data, and page interaction logs. This collection is necessary for platform security, fraud prevention, and performance optimisation.
• KYC verification partners: Data returned to lucky101 by our licensed identity verification partners following CNIC-based age and identity checks. This data is used solely to confirm your eligibility to hold a lucky101 account.
• Payment processors: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank when you make a deposit or request a withdrawal. lucky101 does not store full bank account credentials — only the reference data necessary to process and reconcile your transactions.
• Analytics providers: Aggregated, anonymised usage data provided by platform analytics tools used to improve the lucky101 user experience. This data does not identify individual players.

lucky101 uses the personal data we collect for the following specific purposes. We will never use your personal data for a purpose that is incompatible with the original purpose for which it was collected without first seeking your explicit consent or establishing a new lawful basis for processing.

• Account management: To create, maintain, and administer your lucky101 account, including processing your lucky101 Login, managing your PKR wallet balance, and applying responsible gaming limits you have configured.
• Identity and age verification: To confirm that you are who you say you are and that you meet the minimum age requirement of 21 years, in compliance with our international gaming licence obligations.
• Transaction processing: To process your deposits via JazzCash, EasyPaisa, HBL, UBL, or Meezan Bank and to execute your PKR withdrawal requests within the processing timeframes set out in our Terms & Conditions.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, collusion, and other prohibited conduct using automated risk monitoring tools and manual review processes.
• Regulatory compliance: To fulfil our anti-money-laundering (AML), counter-terrorism financing (CTF), and KYC reporting obligations under our international gaming licence.
• Customer support: To respond to your queries, resolve disputes, and improve the quality of our support services based on communication history.
• Platform improvement: To analyse anonymised usage patterns and gameplay data in order to improve lucky101's product offering, game selection, and user experience for players across Pakistan.
• Marketing communications: Where you have provided explicit consent, to send you promotional emails or SMS messages about lucky101 bonuses, new game launches, PSL cricket betting markets, and other relevant offers. You may withdraw consent at any time via Account Settings.
• Responsible gaming monitoring: To monitor gameplay patterns for indicators of problem gambling behaviour and, where appropriate, to trigger responsible gaming interventions including account reviews or cooling-off period suggestions.

lucky101 processes your personal data on the basis of one or more of the following lawful grounds, depending on the specific processing activity in question:

• Contractual necessity: Processing your identity data, contact data, and financial data is necessary for lucky101 to perform its obligations under the account agreement with you — including enabling you to deposit, play, and withdraw in PKR.
• Legal obligation: Processing for KYC, AML, CTF, and regulatory reporting purposes is required by the terms of lucky101's international gaming licence and applicable law. This processing cannot be opted out of — it is a condition of holding a lucky101 account.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and product improvement is carried out on the basis of lucky101's legitimate interest in operating a safe, fair, and commercially viable gaming platform, balanced against your interests and rights.
• Consent: Processing your data for direct marketing communications is based on your explicit opt-in consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

lucky101 does not sell, rent, or otherwise commercialise your personal data. We share personal data with third parties only in the limited circumstances described below, and only to the extent strictly necessary for the stated purpose:

• KYC and identity verification providers: Licensed third-party verification services that perform CNIC-based age and identity checks on behalf of lucky101. These providers are contractually bound to process your data solely for verification purposes and to maintain equivalent data protection standards.
• Payment processors: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank receive the minimum transaction data required to process your PKR deposits and withdrawals. Each payment partner operates under its own privacy policy and applicable Pakistani financial regulation.
• Game and platform technology providers: Licensed game studios and platform infrastructure providers may receive anonymised or pseudonymised technical data necessary to deliver their services within the lucky101 platform. These providers do not receive directly identifying personal data such as your CNIC number or financial account details.
• Regulatory and licensing authorities: lucky101 may be required to disclose personal data to its licensing authority, law enforcement agencies, or financial intelligence units in response to lawful requests. lucky101 will notify you of such disclosures where legally permitted to do so.
• Legal and professional advisors: Lucky101 may share data with its legal counsel, auditors, or compliance consultants where strictly necessary for the conduct of legal proceedings, regulatory investigations, or professional compliance reviews. All such parties are bound by confidentiality obligations.

The lucky101 platform uses cookies and similar tracking technologies to operate core platform functions, maintain your session security, and analyse how players interact with the site. The following categories of cookies are in use:

You can manage your cookie preferences at any time through your browser settings. Note that disabling strictly necessary cookies will prevent the lucky101 platform from functioning correctly and may log you out of your account. Disabling analytics or marketing cookies will not affect your ability to play games or make transactions on the platform.

lucky101 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes:

• AES-256 encryption for all personal data stored in lucky101's databases
• TLS 1.3 encryption for all data transmitted between your device and the lucky101 platform
• Multi-factor authentication requirements for all internal staff accessing player data systems
• Role-based access controls ensuring that only authorised lucky101 personnel can access personal data relevant to their specific job function
• Regular third-party penetration testing and vulnerability assessments of the lucky101 platform infrastructure
• 24/7 security monitoring and automated threat detection on all platform systems
• Documented incident response procedures with defined notification timelines in the event of a data breach

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, lucky101 will notify you without undue delay through the contact details registered on your account, and will simultaneously report the breach to the relevant supervisory authority as required under our licensing obligations.

lucky101 retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, subject to mandatory retention periods imposed by our international gaming licence and applicable anti-money-laundering legislation. The following retention periods apply as a general guide:

• Account and identity data: Retained for a minimum of five years following account closure to satisfy AML record-keeping obligations. CNIC documentation is retained for the same minimum period.
• Financial transaction records: Retained for a minimum of five years following each transaction date in accordance with international financial record-keeping standards applicable to licensed gaming operators.
• Gameplay and betting history: Retained for a period of two years from the date of each gaming session for responsible gaming monitoring, dispute resolution, and regulatory audit purposes. Anonymised aggregate gameplay data may be retained indefinitely for platform analytics.
• Support communications: Retained for two years from the date of the last interaction, or longer if the communication relates to an ongoing dispute or regulatory matter.
• Marketing data: Retained for as long as you maintain an active marketing consent status. Upon withdrawal of consent, your personal data will be removed from active marketing lists within 30 days, although it may be retained in suppression lists to ensure you are not re-contacted inadvertently.
• Technical and log data: Typically retained for 12 months from collection for security monitoring and fraud prevention purposes, after which it is automatically deleted or anonymised.

At the end of any applicable retention period, personal data is securely deleted or anonymised in accordance with lucky101's data disposal procedures.

As a data subject, you hold a number of rights in respect of your personal data held by lucky101. lucky101 is committed to responding to all valid data rights requests within 30 days of receipt. The following rights are available to you:

• Right of access: You have the right to request a copy of all personal data lucky101 holds about you, along with information about how that data is being processed. Submit a Subject Access Request (SAR) by contacting support via live chat or by emailing [email protected].
• Right to rectification: If any personal data lucky101 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. For account data such as your registered address or contact number, corrections can be made directly via Account Settings.
• Right to erasure: You may request that lucky101 delete your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent. Note that this right is subject to our legal retention obligations; certain data cannot be deleted before the end of the mandatory retention period.
• Right to restrict processing: You may request that lucky101 suspend the processing of your personal data in specific circumstances while a request for rectification or erasure is being assessed.
• Right to data portability: Where processing is based on your consent or on contractual necessity, you have the right to receive your personal data in a structured, commonly used, machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to object: You have the right to object to the processing of your personal data where that processing is based on lucky101's legitimate interests. lucky101 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing communications), you may withdraw consent at any time via Account Settings or by contacting support. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

The lucky101 platform is strictly for adults aged 21 and above. lucky101 does not knowingly collect personal data from any person under the age of 21 and does not permit minors to register or use any part of the lucky101 platform.

CNIC-based age verification is applied to every new account registration. If lucky101 discovers at any point that personal data has been collected from an individual under the age of 21 — whether through registration, a support interaction, or any other channel — that data will be permanently deleted and the associated account will be immediately and permanently closed. No winnings generated by an underage user will be paid out under any circumstances.

lucky101 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our licensing obligations, or the way we operate the platform. When material changes are made to this Privacy Policy, lucky101 will notify registered players by email to their registered address and by displaying a prominent notice on the platform for a minimum period of 14 days following the update.

The effective date at the top of this Privacy Policy will be updated to reflect the date on which the latest version came into effect. Your continued use of the lucky101 platform following notification of a Privacy Policy update constitutes your acceptance of the revised terms. If you do not agree with the updated Privacy Policy, you should cease using the platform and contact support to request account closure.

We recommend that you review this Privacy Policy periodically to stay informed about how lucky101 is protecting your personal data.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way lucky101 processes your personal data, our support team is available 24 hours a day, 7 days a week in both Urdu and English — including all Pakistan public holidays.

To exercise a data right, submit a privacy complaint, or simply ask a question about how your data is used, please use one of the contact channels below. Note that the email address is provided as plain text and is not a clickable link — please copy it into your email client.