Privacy Policy — luck94

This Privacy Policy ("Policy") is issued by luck94 ("luck94", "we", "us", "our"), the operator of the online gaming and sports-betting information platform accessible at https://luck94.cam ("the Platform"). This Policy applies to all individuals who access, browse or register an account on the Platform, including players located in Pakistan ("you", "your", "User").

luck94 is committed to protecting your personal data and to being transparent about the data we hold, why we hold it, and what we do with it. This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform as a whole. By accessing or using the Platform, you acknowledge that you have read and understood this Policy.

Because luck94 operates as an English-language platform accessible to players in Pakistan, we note that Pakistani data-protection legislation may apply to your use. We also note that the Platform's data-processing activities are principally governed by the laws of the jurisdiction in which luck94 is licensed and registered. Where those laws provide stronger protections than applicable local law, those stronger standards apply. This Policy does not constitute legal advice.

The following definitions apply throughout this Policy:

luck94 collects Personal Data from you directly (when you register, interact with support, or transact) and automatically (when you browse or use the Platform). The categories of data we may collect are described in the table below:

We do not intentionally collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric identifiers) unless specifically required by law or the KYC process. Where such data is collected incidentally (e.g., from a document submitted for identity verification), it is processed solely for the purpose for which it was provided and is not retained beyond the required retention period.

luck94 processes your Personal Data only where a valid legal basis exists. The legal bases on which we rely are:

• Contractual necessity: Processing that is necessary to perform the contract with you — including account creation, bet processing, payment handling and withdrawal management.
• Legal obligation: Processing required to comply with applicable law — including KYC/AML obligations, record-keeping requirements and responses to lawful requests from competent authorities.
• Legitimate interests: Processing for purposes that are in our legitimate business interests and do not unduly override your rights — including fraud prevention, platform security, analytics and product improvement.
• Consent: Processing based on your freely given, specific and informed consent — principally for direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

luck94 uses the Personal Data we collect for the following purposes:

• Account registration and management: Creating and maintaining your Account, authenticating your login, and managing account settings and preferences.
• Identity verification (KYC): Verifying that you are who you claim to be, that you meet the minimum age requirement (18+, or the higher minimum required by the operator or license jurisdiction), and that your account is not being used for fraudulent purposes.
• Transaction processing: Processing deposits, withdrawals and the settlement of bets and game results. Currency figures on this platform are commonly referenced in PKR for the convenience of Pakistani players.
• Responsible gambling: Monitoring account activity to identify indicators of problem gambling behaviour, applying limits requested by players, and fulfilling self-exclusion requests.
• Customer support: Responding to queries, complaints and responsible-gambling assistance requests submitted via email or live chat.
• Fraud prevention and security: Detecting and investigating suspicious activity, preventing multi-accounting, and protecting the platform from abuse.
• Marketing communications: Sending promotional offers, bonus notifications and platform updates to players who have opted in. You may unsubscribe at any time through account settings or by contacting support.
• Platform analytics and improvement: Analysing anonymised usage data to improve platform performance, navigation and content relevance.
• Legal compliance: Retaining records as required by applicable law and responding to lawful requests from regulatory authorities or courts.

luck94 does not sell, rent or trade your Personal Data to third parties for their independent use. We may share your Personal Data only in the following circumstances:

• Service providers and Data Processors: We engage trusted third-party service providers to support platform operations — including payment processors, identity verification services, fraud-detection providers, cloud hosting providers and customer-support tools. These parties process data only on our documented instructions and are bound by confidentiality obligations.
• Game and technology partners: Game studios and sports-data providers integrated into the platform may receive anonymised session data necessary for game delivery, RNG certification and live-odds feeds. No personally identifiable information is shared beyond what is operationally required.
• Legal and regulatory obligations: We may disclose Personal Data to law-enforcement agencies, regulatory bodies or courts where required by law, court order or to protect the rights, property or safety of luck94, its users or the public.
• Business transfers: In the event of a merger, acquisition or sale of substantially all of our assets, your Personal Data may be transferred as part of that transaction. We will notify you via email prior to such a transfer and provide the opportunity to close your account.

luck94 retains your Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general principles apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money-laundering and record-keeping requirements.
• KYC and identity documents: Retained for the period required by the operator's regulatory obligations, typically five (5) years from account closure or the date of the last transaction, whichever is later.
• Transaction records: Retained for a minimum of five (5) years in accordance with financial record-keeping obligations.
• Support communications: Retained for three (3) years from the date of the interaction, unless the subject matter relates to an ongoing complaint or legal proceeding.
• Marketing consent records: Retained from the date of opt-in until withdrawal of consent plus one (1) year for audit purposes.
• Technical and usage data: Anonymised analytics data is retained indefinitely for platform improvement. Raw log data containing IP addresses is typically retained for up to twelve (12) months.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised. You may request earlier deletion where no legal obligation requires continued retention — see Section 10 (Your Rights) below.

luck94 uses cookies and similar tracking technologies (such as local storage and session tokens) to operate the platform, maintain authenticated sessions and gather anonymised performance analytics. We do not use cookies to track your activity across unrelated third-party websites.

The following cookie categories are in use on luck94:

• Strictly necessary cookies: Essential for the platform to function. They maintain your login session, remember cart or bet selections, and enable security features. These cannot be disabled without impairing platform functionality.
• Functional cookies: Remember your preferences such as language settings, preferred display options and responsible-gambling limit confirmations. Disabling them may affect your personalised experience.
• Analytics cookies: Collect anonymised data about how pages are used — which sections are visited most, how long sessions last, and where navigation drop-offs occur. This data is used solely to improve the platform.
• Security cookies: Used to detect and prevent fraudulent sessions, bot activity and unauthorised access attempts.

You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from using core platform features including account login.

As luck94 operates internationally, your Personal Data may be transferred to and processed in countries other than Pakistan. Some of these countries may have different data-protection standards to those applicable in your jurisdiction.

Where Personal Data is transferred outside the jurisdiction in which it was collected, luck94 ensures that appropriate safeguards are in place, such as:

• Contractual provisions requiring recipient parties to maintain data-protection standards equivalent to those in this Policy.
• Transfers to jurisdictions that are recognised as providing an adequate level of data protection under the laws of the jurisdiction in which luck94 is licensed.
• Standard contractual clauses or data processing agreements with all Data Processors handling transferred data.

By using luck94, you acknowledge that your Personal Data may be processed in jurisdictions outside Pakistan. If you have concerns about international transfers of your data, please contact us using the details in Section 14.

Subject to applicable law and our legal obligations, you hold the following rights over your Personal Data held by luck94. To exercise any of these rights, contact us at [email protected] with your registered email address and the specific right you wish to exercise.

luck94 is strictly an adults-only platform. We do not knowingly collect Personal Data from individuals under the age of 18 — or the higher minimum age required by the operator or applicable license jurisdiction. Age verification is a mandatory part of the KYC process and is enforced before any account is fully activated.

If we become aware that Personal Data has been collected from a minor, we will immediately close the associated account, delete all collected data, and — where applicable — report the incident to the relevant authority.

If you are a parent or guardian and believe that a minor in your care has registered on luck94 without authorisation, please contact us immediately at [email protected] so that we can take prompt action.

luck94 implements appropriate technical and organisational security measures to protect your Personal Data against accidental loss, unauthorised access, disclosure, alteration or destruction. These measures include:

• HTTPS/TLS encryption for all data transmitted between your device and our servers.
• Encryption at rest for sensitive stored data including payment information and identity documents.
• Access controls restricting data access to authorised personnel on a strict need-to-know basis.
• Multi-factor authentication for administrative access to production systems.
• Regular security assessments and penetration testing of platform infrastructure.
• Incident response procedures ensuring that any data breach is identified, contained and reported to affected users and relevant authorities promptly.

Despite these measures, no system is completely immune to security risks. You play an important role in protecting your own account by using a strong, unique password and never sharing your login credentials with any other person. If you suspect unauthorised access to your account, notify us immediately at [email protected].

luck94 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data practices, the services we offer or the structure of our organisation.

When material changes are made to this Policy, we will notify registered players by email to the address on file and by displaying a prominent notice on the Platform for a reasonable period following the change. The "Last Updated" date at the top of this page indicates when the most recent version was published.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the changes, you must cease using the Platform and may request account closure.

If you have any questions, concerns or requests relating to this Privacy Policy or the handling of your Personal Data, please contact us using the details below. We take all privacy enquiries seriously and aim to respond promptly.

For responsible-gambling concerns, self-exclusion requests or any welfare-related matter, please also visit our dedicated Responsible Gambling page.