◆ Data Protection & Privacy ◆
Your privacy matters to us. This Privacy Policy explains how lack91 collects, uses, stores and protects your personal data when you access or use our platform. We are committed to handling your information transparently and in accordance with applicable data protection standards.
Effective Date: 1 January 2026 | Version 1.0All data transmitted through the lack91 Platform is protected by SSL/TLS encryption. Access to personal information is restricted to authorised personnel operating under strict confidentiality obligations.
lack91 does not sell, rent or trade your personal information to third parties for their own marketing purposes. Data is shared only where necessary for platform operation or legal compliance.
You have the right to access, correct, restrict and request deletion of your personal data. You may also withdraw consent for optional data processing at any time by contacting our support team.
We collect only the personal information that is necessary for account operation, KYC compliance, fraud prevention and the delivery of our gaming services. We do not collect data beyond what is required.
We use cookies and similar tracking technologies for session management, performance analytics and user experience improvement. You can manage cookie preferences through your browser settings.
Marketing communications are optional. You may opt out of promotional emails and notifications at any time without affecting your account status or access to the Platform's core gaming features.
This Privacy Policy ("Policy") applies to the lack91 Platform, accessible at https://lack91.cam ("Platform", "Site", "lack91"). It describes how lack91 — operated in the English language and targeting users in Pakistan — collects, processes, stores, shares and protects personal data obtained from individuals who access or use the Platform ("User", "you", "your").
lack91 is committed to protecting the privacy and security of the personal information entrusted to us. This Policy has been prepared in accordance with generally accepted data protection principles and reflects our obligations to handle personal data responsibly, transparently and lawfully.
By registering an account, accessing the Platform or otherwise interacting with lack91, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the Platform immediately.
For the purposes of this Privacy Policy, the following terms carry the meanings set out below:
lack91 collects personal data in the categories described below. We collect only what is necessary for the stated purposes and do not process data beyond those needs.
| Data Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, CNIC or passport number | Account registration & KYC verification |
| Contact Data | Email address, phone number, residential address (city, e.g. Karachi, Lahore, Islamabad) | Account registration, support enquiries |
| Financial Data | Deposit/withdrawal amounts, transaction history, payment method references (PKR) | Deposits, withdrawals, bonus activity |
| Technical Data | IP address, browser type, device identifiers, operating system, session logs | Automatically on Platform access |
| Usage Data | Pages visited, games played, bets placed, session duration, click data | Automatically during Platform use |
| Communications Data | Support ticket content, live chat transcripts, email correspondence | When contacting support |
| Verification Documents | Scanned CNIC, utility bill, bank statement (KYC) | KYC & withdrawal verification |
| Marketing Preferences | Opt-in/opt-out status, preferred communication channels | Account settings, consent forms |
lack91 collects personal data through the following channels:
Information you voluntarily provide when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, respond to a survey or interact with any feature of the Platform that involves data entry.
Technical and usage data collected automatically when you visit or interact with the Platform, including through cookies, web beacons, pixel tags, log files and similar tracking technologies. This data is collected regardless of whether you are logged in to an account.
lack91 may receive personal data about you from third-party sources, including:
Where data is received from third parties, lack91 ensures that appropriate contractual safeguards are in place and that the third party has the lawful authority to share that data.
lack91 may infer preferences, risk profiles and behavioural patterns from the data you provide or from your Platform activity. These inferences are used to personalise your experience, improve responsible gambling controls and detect potentially problematic gambling behaviour.
lack91 processes your personal data only for the purposes listed below. We do not use personal data for purposes that are incompatible with those originally stated.
lack91 relies on the following legal bases for processing your personal data, consistent with internationally recognised data protection principles:
Processing that is necessary for the performance of the contract between you and lack91 — including account registration, service delivery, payment processing and KYC verification — is carried out on the basis that such processing is required to fulfil our contractual obligations to you.
Where processing is necessary for the legitimate interests of lack91 or a third party — including fraud prevention, Platform security, responsible gambling monitoring and analytics — and those interests are not overridden by your rights and freedoms, we rely on legitimate interests as the lawful basis.
Processing required to comply with applicable legal obligations — including AML obligations, regulatory reporting, response to court orders and law enforcement requests — is carried out on the basis of legal compliance.
Where processing is based on your consent — including optional marketing communications and certain cookie uses — we will seek your explicit consent prior to that processing. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent does not affect processing carried out on other legal bases.
lack91 does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual protections:
lack91 may disclose your personal data to competent authorities, regulatory bodies or law enforcement agencies where required by applicable law, court order or regulatory obligation. In such cases, we will disclose only what is strictly required and, where legally permissible, we will endeavour to notify you of the disclosure.
In the event of a merger, acquisition, corporate restructuring or sale of assets involving lack91, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material change to this Privacy Policy that results from it.
The personal data we collect may be transferred to, stored in and processed in countries other than Pakistan or the jurisdiction from which you access the Platform. These countries may have data protection laws that differ from, and in some cases offer less protection than, those in your home jurisdiction.
Where personal data is transferred internationally, lack91 takes reasonable steps to ensure that appropriate safeguards are in place to protect your information, including contractual protections with data processors and service providers. These safeguards are designed to ensure that your data receives a level of protection consistent with the principles set out in this Policy.
By using the lack91 Platform, you acknowledge and accept that your personal data may be transferred, stored and processed outside of Pakistan. If you have concerns about international data transfers, please contact us at the details provided in Section 16.
lack91 retains personal data for no longer than is necessary for the purposes for which it was collected, subject to applicable legal and regulatory requirements. The following general retention principles apply:
Personal data associated with active accounts is retained for as long as the account remains open and for a defined period following account closure, to allow for dispute resolution and compliance with anti-money laundering record-keeping obligations.
Financial transaction records, including deposit and withdrawal history in PKR and other currencies, are retained for a minimum period consistent with applicable AML and financial record-keeping requirements. This period is typically five (5) years from the date of the transaction or account closure, whichever is later.
Identity and address verification documents submitted for KYC purposes are retained for the period required by applicable AML legislation applicable to the Operator's jurisdiction, typically a minimum of five (5) years following the end of the customer relationship.
Records of support interactions are retained for up to three (3) years following the resolution of the relevant issue, to allow for quality monitoring and dispute handling.
Where you have consented to marketing communications, your marketing preferences and contact data are retained until you withdraw consent or request deletion, subject to any applicable minimum retention requirement.
lack91 uses cookies and similar technologies (including web beacons, pixel tags and local storage objects) to operate the Platform effectively, improve performance and deliver a relevant user experience. This section explains the types of cookies we use and how you can manage them.
You can manage cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Note that disabling essential cookies will prevent you from using core Platform features including account login and gaming. For more information on managing cookies in your specific browser, consult your browser's help documentation.
lack91 respects your rights over your personal data. The following rights are available to you, exercisable by contacting us at the details provided in Section 16. We will respond to verified requests within a reasonable timeframe — typically within thirty (30) days, subject to complexity and volume of requests.
Request a copy of the personal data we hold about you, including details of how it is processed and with whom it is shared.
Request correction of inaccurate or incomplete personal data. Accurate data is particularly important for KYC and payment processing.
Request deletion of your personal data where it is no longer necessary, you withdraw consent or you object to processing. Statutory retention obligations may limit this right.
Request that we restrict the processing of your data — for example, while you contest its accuracy or while an objection is being assessed.
Receive your personal data in a structured, machine-readable format and, where technically feasible, have it transferred to another service provider.
Object to processing carried out on the basis of legitimate interests, including profiling. You have an unconditional right to object to direct marketing at any time.
To exercise any of these rights, please contact the lack91 support team at the email address provided in Section 16. We may require you to verify your identity before processing your request. lack91 will not charge a fee for exercising your rights under normal circumstances.
The lack91 Platform is strictly for adults. Access to and use of the Platform is limited to individuals who are at least 18 years of age, or the higher minimum age required by the operator's licensing jurisdiction or applicable local law, whichever is greater.
lack91 does not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account or provided personal data to lack91, please notify us immediately at the contact details provided in Section 16.
lack91 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:
Notwithstanding these measures, no system of data transmission or storage can be guaranteed to be 100% secure. lack91 cannot guarantee the absolute security of your personal data and users should take appropriate precautions — including using strong, unique passwords and maintaining the confidentiality of their account credentials.
In the event of a personal data breach that is likely to result in risk to your rights and freedoms, lack91 will notify affected users and, where required, relevant supervisory authorities, in accordance with applicable incident notification obligations.
The lack91 Platform may contain references to or integrations with third-party services, game studios, sports data providers and payment processors. Where such third-party services involve the separate collection or processing of personal data, that processing is governed by the privacy policies of those third parties, not by this Policy.
lack91 is not responsible for the privacy practices, content or data handling of third-party services. References to familiar Pakistani payment brands (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) and sports organisations (PSL, ICC) on this Platform are for informational context only. Their inclusion does not imply that those entities have reviewed or endorsed this Privacy Policy or the lack91 Platform.
Users are encouraged to review the privacy policies of any third-party services they interact with in connection with their use of the Platform.
lack91 reserves the right to update or revise this Privacy Policy at any time. When material changes are made, the revised Policy will be published on the Platform with an updated effective date. Where practicable and where required by applicable law, we will provide notice of significant changes through in-platform notifications or email communication to registered users.
Your continued use of the lack91 Platform following the publication of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with the updated Policy, you must cease using the Platform and may request deletion of your personal data in accordance with Section 11.
We encourage you to review this Policy periodically, particularly following significant events such as new game category launches, payment method changes or updates to our responsible gambling tools.
If you have questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by lack91, please contact us through the following channel. All requests will be acknowledged promptly and handled in accordance with applicable data protection obligations.
lack91 Data Privacy Team
Privacy enquiries, data subject requests & consent withdrawal:
[email protected]This email address is displayed as plain text only and is not a clickable link. Support is available in English, with Urdu assistance available on request. We aim to acknowledge all privacy-related enquiries within two (2) business days. Response times may be longer during peak periods such as PSL finals and ICC tournament match days.
Explore the lack91 Platform knowing your personal data is handled with transparency and care. Visit our homepage, browse the FAQ for common privacy questions, or review our full Terms & Conditions.
Adults 18+ only. This Policy does not constitute legal advice. lack91 is an informational gaming platform.