Lucky 111 Privacy Policy – Your Data, Your Rights, Our Commitment to Pakistan

1Introduction – Who We Are and What This Policy Covers

Lucky 111 is Pakistan's dedicated online gaming and sports betting platform, accessible at lucky111.ws. This Privacy Policy explains how Lucky 111 ("we," "us," "the Platform") collects, uses, stores, and protects the personal information of our registered members and website visitors across Pakistan.

We understand that Pakistani users are increasingly aware of digital privacy — and rightly so. This policy is written to be genuinely readable rather than deliberately obscure. If something here isn't clear, you can contact us directly and we'll explain it in plain terms.

This policy applies to all personal data collected through the Lucky 111 website, mobile interface, customer support interactions, payment processing, and identity verification processes. It should be read alongside our Terms and Conditions and Responsible Gaming policy.

2What Personal Data Lucky 111 Collects

Lucky 111 collects the minimum personal data necessary to operate your account safely, comply with legal requirements, and provide you with the full range of platform services. The categories of data we collect are:

2.1 Registration Data

• Full legal name (as it appears on your CNIC or government-issued ID)
• Date of birth (for age verification — Lucky 111 is strictly 18+)
• Mobile number (used as your primary account identifier and for two-factor authentication)
• Email address (for account notifications and support correspondence)
• City and province of residence
• Preferred language (English or Urdu)

2.2 Identity Verification (KYC) Data

• CNIC number and a copy of your CNIC (front and back)
• Selfie photo for liveness verification
• Proof of address (utility bill, bank statement, or similar document dated within 90 days)
• Source of funds documentation where required for large withdrawals

2.3 Financial Transaction Data

• Easypaisa, JazzCash, NayaPay, or SadaPay account numbers used for deposit/withdrawal
• IBAN or bank account details for IBFT transfers
• Masked Visa/Mastercard card numbers (last four digits only — full card numbers are never stored by Lucky 111)
• Transaction history: deposit amounts, withdrawal amounts, dates, and methods

2.4 Platform Usage Data

• Bet history, game history, and session activity logs
• Account balance history and bonus utilisation records
• Login timestamps, IP addresses, and device identifiers
• Customer support interaction records (chat logs, email threads, call notes)

2.5 Technical and Device Data

• Browser type and version
• Device type, operating system, and screen resolution
• Network connection type
• Referring URLs and navigation paths within the Lucky 111 platform

3How We Collect Your Data

Lucky 111 collects data in three main ways:

3.1 Directly From You

The majority of data Lucky 111 holds about you is information you provide directly: when you register your account, complete KYC verification, make a deposit or withdrawal, contact customer support, or update your account settings. This is the most important category of data and is collected with your explicit knowledge.

3.2 Automatically During Platform Use

When you use the Lucky 111 platform, certain technical data is collected automatically. This includes your IP address (used for security and fraud prevention), the device and browser you're using, pages you visit within the platform, and the duration of your sessions. This data is not used to build advertising profiles — it is used for platform security, performance optimisation, and responsible gaming monitoring.

3.3 From Third Parties

In specific circumstances, Lucky 111 may receive information about you from third parties. This includes identity verification data returned by our KYC provider after document verification, fraud risk scores provided by payment processing partners, and information shared by partner sports data providers used in the betting interface. All third-party data sharing is governed by contracts that require those parties to handle data securely and in compliance with applicable law.

4How Lucky 111 Uses Your Personal Data

Every use Lucky 111 makes of your personal data has a specific, legitimate purpose. The table below sets out the primary purposes and the legal basis for each:

5Who Lucky 111 Shares Your Data With

Lucky 111 shares your personal data only in the following specific circumstances, with parties who are contractually obligated to protect it:

5.1 Identity Verification Providers

When you complete KYC verification, your identity documents are processed by a certified identity verification service. This provider receives your CNIC image, selfie, and personal details for the purpose of verifying your identity and confirming you meet the 18+ age requirement. The provider does not retain your data beyond the verification process except as required by their own legal obligations.

5.2 Payment Processors

To process your PKR deposits and withdrawals, Lucky 111 communicates with Easypaisa, JazzCash, NayaPay, SadaPay, your bank, or your card issuer. These parties receive only the minimum data necessary to complete your transaction. Lucky 111 does not transmit full card numbers to payment partners — all card processing is handled by PCI-DSS compliant payment gateways.

5.3 Legal and Regulatory Authorities

Lucky 111 may be required to disclose member data to law enforcement, regulatory bodies, or other government authorities in response to a valid legal request. In such cases, Lucky 111 discloses only the information specifically requested and, where legally permitted, notifies the affected member.

5.4 Anti-Fraud and Security Partners

Lucky 111 uses third-party risk assessment tools to detect fraudulent account activity, collusion in poker, and money laundering patterns. These tools may receive limited transactional and behavioural data in anonymised or pseudonymised form for risk scoring purposes.

6PKR Payments, KYC and Financial Privacy

Because Lucky 111 operates entirely in Pakistani Rupees and uses local payment infrastructure, we understand the financial privacy concerns specific to Pakistani users. Here's what you need to know about how your payment and KYC data is handled.

6.1 Mobile Wallet Transactions

When you deposit via Easypaisa or JazzCash, Lucky 111 receives a transaction confirmation from the wallet provider that includes your registered mobile number and the transaction amount. Lucky 111 does not have access to your full wallet transaction history — we only see transactions that are directed to Lucky 111's registered merchant account.

6.2 KYC Document Security

Your CNIC copy and selfie images are stored in an encrypted, access-restricted document vault separate from your general account data. These documents are accessible only to the Lucky 111 compliance team members with a specific business need to review them. KYC documents are never stored alongside betting or gaming activity records in the same accessible database.

6.3 Withdrawal Privacy

When you request a withdrawal, Lucky 111 processes the payment to the same account or method used for deposit wherever possible. This is both a security measure (to prevent account takeover fraud) and a standard practice for your protection. Withdrawal records are maintained as required by applicable financial regulations.

7Cookies and Tracking Technologies

Lucky 111 uses cookies and similar technologies on the platform website. Cookies are small text files stored on your device that help the platform function, remember your preferences, and operate securely. Here's a breakdown of the cookies used and which ones are optional:

You can manage cookie preferences at any time through your browser settings or through the Lucky 111 account privacy settings panel. Note that disabling essential cookies will prevent the platform from functioning.

8How We Protect Your Data – Security Measures

Lucky 111 takes data security seriously. The following technical and organisational measures are in place to protect member data:

• 256-bit SSL encryption on all pages and all data in transit between your device and Lucky 111 servers.
• Encrypted data at rest — all stored member data, including KYC documents and financial records, is encrypted using industry-standard encryption algorithms.
• Role-based access controls — Lucky 111 staff can only access the member data their specific role requires. No individual has unrestricted access to the complete member database.
• Two-factor authentication (2FA) — available and strongly recommended for all Lucky 111 accounts. Gold and Platinum VIP members are prompted to enable 2FA.
• Regular security audits — Lucky 111 conducts internal security reviews quarterly and engages independent penetration testers annually.
• Intrusion detection systems — automated monitoring systems flag unusual access patterns and trigger manual review of potentially compromised accounts.
• Staff training — all Lucky 111 staff who handle personal data receive mandatory data privacy training on joining and annually thereafter.

9Data Retention – How Long We Keep Your Information

Lucky 111 retains personal data only for as long as necessary for the purposes described in this policy, or as required by applicable law. The following retention periods apply:

After the applicable retention period expires, your personal data is securely deleted or anonymised so it can no longer be linked to you as an individual.

10Your Data Rights as a Lucky 111 Member

As a Lucky 111 member, you have the following rights regarding your personal data. To exercise any of these rights, contact [email protected] with your account mobile number and a description of your request. We respond to all data rights requests within 30 days.

11Protection of Minors

Lucky 111 is strictly an 18+ platform. We do not knowingly collect personal data from persons under the age of 18. All registration processes include date of birth collection and age verification steps. KYC verification further confirms age through CNIC document verification, as Pakistani CNICs are issued only to persons over 18.

If Lucky 111 becomes aware that an account has been registered by or on behalf of a minor, the account will be immediately suspended, all funds frozen pending review, and the personal data of the minor will be deleted as promptly as legally permissible. Parents or guardians who believe a minor has registered an account should contact us immediately at [email protected].

12Changes to This Privacy Policy

Lucky 111 may update this Privacy Policy from time to time to reflect changes in our data practices, new services offered on the platform, or changes in applicable law. The date of the most recent update is shown at the top of this page.

When material changes are made to this policy, we will notify all registered Lucky 111 members via in-platform notification and, where available, by email to the registered address. We encourage you to review this policy periodically — not because we hide important changes in updates, but because staying informed about how your data is used is genuinely worthwhile.

Continued use of the Lucky 111 platform after the effective date of an updated Privacy Policy constitutes your acceptance of the changes. If you disagree with any material change, you have the right to close your account before the effective date.

13Contact – Privacy Queries and Data Rights Requests

For any question about this Privacy Policy, to exercise your data rights, or to raise a privacy concern, please contact the Lucky 111 privacy team:

If you are not satisfied with Lucky 111's response to a privacy concern, you have the right to raise the matter with the relevant data protection authority or pursue other legal remedies available under applicable Pakistani law.