Privacy Policy – Laki 101 Data Protection for Pakistan Players

1About This Privacy Policy

This Privacy Policy applies to all personal data collected, processed and stored by Laki 101 in connection with the platform available at laki101.biz and all associated services including but not limited to casino games, sports betting, payment processing and customer support.

When we say "personal data" in this document, we mean any information that identifies you or could reasonably be used to identify you – your name, mobile number, transaction history, IP address and similar data. We take our responsibility over this data seriously because we understand that Pakistani players are trusting Laki 101 with sensitive information.

This policy should be read alongside our Terms and Conditions. By accepting the Terms and Conditions, you also accept this Privacy Policy. If you have questions about anything written here, contact us at support@laki101.biz before registering.

2Data We Collect

Laki 101 collects only the personal data that is genuinely necessary to provide our services, verify your identity and maintain the security of the platform. Below is a detailed breakdown of what we collect and when.

2.1 Data You Give Us Directly

• Registration data: Full name, date of birth, Pakistani mobile number and account password (stored as a hashed value – we cannot see your actual password).
• KYC documents: If your account reaches the KYC verification threshold (withdrawals above Rs 50,000 in a 30-day period), we collect a copy of a government-issued ID such as your CNIC or Passport, and may request a selfie for identity matching.
• Payment data: Your registered payment method type (Easypaisa, JazzCash, NayaPay, SadaPay, IBFT or card) and the account identifier associated with it. We do not store full card numbers or complete mobile wallet credentials.
• Support communications: Any messages you send to Laki 101 through live chat or email, including the content and timestamps.

2.2 Data Collected Automatically

• Device and connection data: IP address, device type, operating system, browser type and version, and screen resolution. This is used for security monitoring and to optimise the Laki 101 platform for Pakistani users.
• Session data: Login times, session duration, pages visited within the platform and feature usage patterns.
• Transaction data: The date, time, amount and method of every deposit and withdrawal made on your Laki 101 account, as well as game round data and bet history.
• Cookies and similar technologies: See Section 6 for full details on how Laki 101 uses cookies.

3How We Use Your Data

Laki 101 uses the personal data we collect for specific, documented purposes. We do not use your data for anything beyond what is listed below without your explicit consent.

• Account management: Creating and maintaining your Laki 101 account, processing logins, managing your balance and handling account settings changes.
• Payment processing: Processing deposits and withdrawals in PKR via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT and card. Your payment identifier is passed to our payment partners solely to execute the transaction.
• Identity verification (KYC): Verifying that you are who you say you are, that you meet the age requirement of 18+, and that your withdrawal details match your registered identity.
• Security and fraud prevention: Monitoring for unauthorised access, detecting duplicate accounts, identifying suspicious betting patterns and preventing financial crime on the Laki 101 platform.
• Customer support: Using your account history and communication records to resolve queries and complaints efficiently.
• Regulatory compliance: Maintaining records as required under applicable financial and gaming regulations.
• Platform improvement: Analysing aggregated, anonymised usage data to identify and fix technical issues and improve the Laki 101 experience for Pakistani players.
• Responsible gaming: Monitoring account activity to identify patterns that may indicate problem gambling and applying the tools available under our Responsible Gaming policy.

4Legal Basis for Processing

Laki 101 processes personal data on one or more of the following legal grounds depending on the activity involved:

• Contract performance: Processing your registration data, payment data and game history is necessary to fulfil our agreement with you as a Laki 101 player and to provide the services you have signed up for.
• Legal obligation: Certain data processing – particularly KYC, transaction records and security monitoring – is required by applicable financial regulations and anti-money laundering obligations.
• Legitimate interests: Security monitoring, fraud prevention and platform improvement activities are carried out under Laki 101's legitimate interest in maintaining a safe, fair platform. These activities are balanced against your privacy rights.
• Consent: Where Laki 101 processes data beyond the above grounds – for example, if you opt into marketing communications – we will ask for your explicit consent and you may withdraw it at any time.

5Data Sharing and Third Parties

Laki 101 does not sell your personal data. We share data only with the categories of third parties described below, and only to the extent necessary for the stated purpose.

5.1 Payment Partners

To process deposits and withdrawals in PKR, Laki 101 shares your payment identifier and transaction amount with the relevant payment provider (Easypaisa, JazzCash, NayaPay, SadaPay, your bank via IBFT, or your card network). These providers process data under their own privacy policies and are subject to Pakistani financial regulations.

5.2 Identity Verification Services

For KYC verification, Laki 101 may use a third-party identity verification service to cross-check documents. These providers are contractually bound to process your data only for the purpose of identity verification and to maintain appropriate security standards.

5.3 Technology Infrastructure

Laki 101 uses cloud hosting and technology infrastructure providers to run the platform. These providers may technically process your data as part of hosting services. They are contractually prohibited from accessing or using your data for any purpose other than providing infrastructure services to Laki 101.

5.4 Legal and Regulatory Disclosure

Laki 101 will disclose personal data to law enforcement, regulators or courts where required by law or where we have a good-faith belief that disclosure is necessary to prevent financial crime, fraud or harm to individuals.

6Cookies and Tracking Technologies

Laki 101 uses cookies and similar technologies on the platform to make the service work correctly, keep your session active and understand how the platform is being used. Here is what we use and why:

• Essential cookies: Required for the platform to function. These maintain your login session, remember your language preference and process transactions. These cannot be switched off without breaking core functionality.
• Security cookies: Used to detect and prevent fraudulent access, bot activity and session hijacking on the Laki 101 platform.
• Analytics cookies: Aggregated, anonymised data about how pages are navigated and which features are used. This helps Laki 101 identify performance issues and improve the experience for Pakistani players. Individual users are not identified in this data.
• Preference cookies: Remember optional settings such as display preferences or notification choices you have made on the Laki 101 platform.

Laki 101 does not use advertising cookies or tracking pixels that share your data with advertising networks. You can manage non-essential cookies through your browser settings. Note that disabling essential cookies will affect platform functionality.

7How Long We Keep Your Data

Laki 101 does not keep your personal data longer than necessary. Our retention approach is as follows:

• Active account data: Maintained for as long as your account is active on the Laki 101 platform.
• Transaction records: Retained for a minimum of 5 years from the date of the transaction for compliance with financial record-keeping requirements.
• KYC documents: Retained for 5 years from the date of verification or the closure of your account, whichever is later, in line with anti-money laundering record requirements.
• Support communications: Retained for 2 years from the date of the conversation to allow follow-up on unresolved matters.
• Closed account data: Following account closure, core identity and transaction data is retained for the legally required period then securely deleted. Marketing data and non-essential records are deleted at the point of closure.

After retention periods expire, data is securely deleted or irreversibly anonymised so it can no longer be linked to you as an individual.

8Your Privacy Rights

Every Laki 101 player has the following rights regarding their personal data. To exercise any of these rights, email support@laki101.biz with the subject line "Data Rights Request". We will respond within 72 hours and action validated requests within 30 days.

9Children's Privacy

The Laki 101 platform is strictly for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18.

During registration, players are required to confirm their date of birth. Laki 101 carries out age verification checks and any account found to belong to a person under 18 will be immediately closed, with all associated data deleted in line with this policy. Funds in underage accounts will not be returned.

If you are a parent or guardian and believe your child has registered on the Laki 101 platform, please contact us immediately at support@laki101.biz. We will investigate and close the account as a priority.

10Security Measures

Laki 101 implements a layered security approach to protect the personal data we hold. The measures we have in place include:

• Encryption in transit: All data transmitted between your device and Laki 101 uses 256-bit TLS/SSL encryption. This protects your data from interception during transmission.
• Encryption at rest: Sensitive data stored on our servers – including personal information and KYC documents – is encrypted at rest using industry-standard encryption methods.
• Password hashing: Your account password is never stored as plain text. It is processed through a one-way cryptographic hash function meaning no one, including Laki 101 staff, can see your actual password.
• Access controls: Only authorised staff with a documented operational need can access player data. All data access by staff is logged and subject to periodic audit.
• Fraud monitoring: Automated systems monitor login activity, payment patterns and session behaviour for signs of unauthorised access or account compromise. Suspicious activity triggers security alerts and may result in temporary account holds pending verification.
• Penetration testing: The Laki 101 platform is subject to regular security assessments to identify and remediate vulnerabilities before they can be exploited.

11Updates to This Privacy Policy

Laki 101 reviews and updates this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements or the services we offer to Pakistani players.

When we make material changes to this policy, we will notify registered players through the mobile number or email address on their Laki 101 account at least 7 days before the changes take effect. Non-material changes (such as minor clarifications or formatting updates) may be made without advance notice.

The effective date of the most recent update is shown at the top of this page. We recommend checking this page periodically. Continued use of Laki 101 following the effective date of any update constitutes acceptance of the revised policy.