Privacy Policy – Lucy 97 Online Gaming Platform Pakistan

1. Introduction

This Privacy Policy ("Policy") explains how lucy 97, operated at https://lucy97.app ("the Platform", "we", "us", "our"), collects, processes, uses, stores, and protects the personal data of individuals ("you", "the Player") who register an account, make deposits, place bets, or otherwise interact with the lucy 97 platform.

Lucy 97 takes the privacy of its players seriously. This is not a document written simply to satisfy a legal requirement and then forgotten about. The principles described here reflect the way lucy 97 actually operates with respect to player data on a day-to-day basis. We have written this Policy in plain language so that Pakistani players can read it and genuinely understand what happens to their information – without needing a legal background to follow along.

This Policy should be read alongside the lucy 97 Terms and Conditions and Responsible Gaming Policy. By registering an account on lucy 97 or using the platform in any way, you confirm that you have read and understood this Privacy Policy and that you consent to the processing of your personal data as described within it.

2. Data We Collect

Lucy 97 collects personal data in two ways: information you provide to us directly, and information collected automatically when you use the platform.

2.1 Information You Provide

When you register an account on lucy 97 or interact with the platform, you may provide the following:

2.2 Information Collected Automatically

When you visit and use lucy 97, certain technical data is collected automatically:

• Device information: device type, operating system, browser version
• IP address: used for geolocation, fraud prevention, and regulatory compliance
• Session data: pages visited, time spent, games played, bets placed
• Cookie data: see the Cookies section below for full details
• Referral data: how you arrived at lucy 97 (e.g. direct URL, link)

3. How We Use Your Data

Lucy 97 uses the personal data we collect strictly for the following purposes:

• Account management: creating, maintaining, and securing your lucy 97 account
• Identity and age verification: confirming that you are who you say you are and that you are at least 18 years old
• Payment processing: facilitating deposits and withdrawals in PKR via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, and Visa/Mastercard
• Platform operation: delivering games, live cricket scores, PSL betting markets, and all other platform features
• Customer support: responding to queries, resolving disputes, and providing assistance in Urdu and English
• Fraud prevention and security: detecting and preventing unauthorised access, money laundering, and other illegal activities
• Responsible gaming: monitoring for signs of problem gambling behaviour and enforcing self-exclusion and deposit limits
• Legal compliance: meeting obligations under applicable law, including retaining records required by financial regulations
• Platform improvement: using anonymised, aggregated usage data to improve the lucy 97 user experience
• Marketing communications: sending you relevant promotional information about lucy 97 offers, where you have consented to receive such communications. You may withdraw consent at any time by contacting support.

4. Legal Basis for Processing

Lucy 97 processes your personal data on the following legal bases:

• Contractual necessity: processing your registration data, payment information, and account activity is necessary to fulfil our obligations under the Terms and Conditions you have agreed to as a registered player on lucy 97.
• Legal obligation: certain processing – particularly identity verification, transaction records, and anti-money-laundering checks – is required by law and cannot be avoided regardless of consent.
• Legitimate interest: fraud detection, platform security, and the prevention of problem gambling are legitimate interests that justify certain data processing activities.
• Consent: where processing is not required by contract or law, lucy 97 relies on your explicit consent. You may withdraw consent for any consent-based processing at any time by contacting support@lucy97.app.

5. Data Sharing

Lucy 97 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We may share your data with third parties only in the following limited circumstances:

5.1 Payment Processors

To process your deposits and withdrawals in PKR, lucy 97 shares the minimum necessary transaction data with local payment service providers including Easypaisa, JazzCash, NayaPay, SadaPay, and banking partners. These providers are contractually bound to protect your data and may only use it for the purpose of processing your specific transaction.

5.2 Game Providers

Certain games on the lucy 97 platform are provided by third-party game studios. These providers receive session data necessary to operate the game (such as player session identifiers and bet amounts) but do not receive your full personal details such as your name or contact information.

5.3 Legal and Regulatory Authorities

Lucy 97 will disclose personal data to relevant authorities when required to do so by applicable law, a valid court order, or a legitimate regulatory request. We will always attempt to notify you of such disclosure unless we are prohibited from doing so by law.

5.4 Fraud Prevention Services

Lucy 97 may share certain account and transaction data with fraud prevention and identity verification services to protect the platform and its players. These services are bound by strict data protection obligations.

6. Data Security

Lucy 97 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption on all pages and API communications – all data transmitted between your device and lucy 97 is encrypted
• Encrypted storage for sensitive data fields including passwords (stored as salted hashes, never in plain text) and payment reference information
• Access controls restricting employee access to personal data on a strict need-to-know basis with full audit logging
• Regular security assessments of platform infrastructure and third-party integrations
• Two-factor authentication available for player accounts and required for all staff access to administrative systems

While lucy 97 takes all reasonable precautions, no online platform can guarantee absolute security against all possible threats. You are responsible for maintaining the security of your own account credentials. Never share your lucy 97 password with anyone – our support team will never ask for it.

7. Cookies & Tracking Technologies

Lucy 97 uses cookies and similar tracking technologies to operate the platform, remember your preferences, and improve your experience. The following types of cookies are used:

You can manage cookie preferences through your browser settings. Disabling non-essential cookies may affect some platform features. Lucy 97 does not use third-party advertising cookies or tracking pixels for cross-site advertising.

8. Payment Data

Lucy 97 takes particular care with financial data because we understand how sensitive it is for Pakistani players to share their payment information online. The following principles govern how we handle payment data:

• Lucy 97 does not store full bank card numbers, CVV codes, or complete mobile wallet credentials on our servers at any point.
• Payment transactions are processed through PCI-compliant payment gateways. Lucy 97 receives only a tokenised reference to identify the transaction – not the underlying financial credentials.
• Deposit and withdrawal records are retained for the period required by financial regulations to support audits and dispute resolution.
• If you request a withdrawal to a different payment method than the one used for your most recent deposit, lucy 97 will require additional identity verification before processing – this is a standard security measure, not an obstruction.

9. Data of Minors

Lucy 97 does not knowingly collect personal data from individuals under the age of 18. The platform is strictly for adults and all registration processes include an age verification step. If we become aware that a registered account belongs to a person under 18, that account will be immediately closed, deposits returned, and all personal data associated with the account deleted in accordance with this Policy.

Parents or guardians who believe their child may have registered an account on lucy 97 should contact support@lucy97.app immediately. We will investigate and act without delay.

10. Data Retention

Lucy 97 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or to comply with legal and regulatory obligations. The following retention periods apply:

• Active account data: retained for the full duration of your account's active status on lucy 97.
• Transaction records: retained for a minimum of five years after the transaction date, as required by financial regulations.
• Identity verification documents: retained for five years after account closure or the date of the last transaction, whichever is later.
• Customer support communications: retained for two years from the date of the interaction.
• Closed account data: personal data associated with closed accounts is deleted or anonymised at the end of the applicable retention period. Where deletion is not technically possible, data will be securely isolated and not actively processed.

11. Your Rights

As a lucy 97 player, you have the following rights with respect to your personal data. To exercise any of these rights, contact us at support@lucy97.app with the subject line "Data Rights Request":