Privacy Policy
This Privacy Policy describes how lucy97 collects, processes, stores and protects your personal data when you access or use our platform. We are committed to handling your information with transparency, security and respect — regardless of whether you are browsing from Karachi, Lahore, Islamabad or anywhere else in Pakistan.
Privacy Highlights
Your Data Is Secure
Lucy97 applies industry-standard encryption, access controls and storage security measures to protect your personal information against unauthorised access, disclosure or loss.
No Data Selling
We do not sell, rent or trade your personal data to third parties for marketing purposes. Data sharing is limited to what is strictly necessary for platform operation, legal compliance and fraud prevention.
You Control Your Data
You have the right to access, correct, restrict or request deletion of your personal data. You may exercise these rights at any time by contacting us using the details in this policy.
Minimal Data Collection
We collect only what is necessary to provide our services, fulfil legal obligations and prevent fraud. We do not collect sensitive personal data unless required by our KYC and AML compliance obligations.
Cookie Transparency
We use cookies to improve your experience on the Platform. You can manage your cookie preferences at any time. This policy explains exactly what cookies we use and why.
Plain English Explanations
This policy is written to be understood by real people. We use plain English throughout and avoid unnecessary legal jargon — because transparency means nothing if the policy is unreadable.
Introduction
Lucy97 ("we", "us", "our" or "the Platform") is an online gaming information and guide service accessible at https://lucy97.cam. This Privacy Policy explains how lucy97 collects, uses, discloses, stores and protects personal data obtained from individuals ("you", "your" or "the User") who visit, access or register on the Platform.
We are committed to safeguarding the privacy of our users, including those based in Pakistan and internationally. This Policy is intended to be clear, honest and genuinely useful — not a document that obscures how we handle your data behind impenetrable legal language.
By accessing or using the lucy97 Platform, you acknowledge that you have read this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform.
Scope: This Privacy Policy applies to all personal data collected through the Platform, including data collected via registration forms, payment transactions, KYC submissions, live chat interactions, cookies and general browsing activity on lucy97.cam.
Definitions
The following definitions apply throughout this Privacy Policy:
- "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, postal address, date of birth, payment details, device identifiers and IP address.
- "Processing" means any operation or set of operations performed on personal data, including collection, recording, storage, use, disclosure, transmission, restriction and deletion.
- "Data Controller" means lucy97, which determines the purposes and means of processing personal data collected through the Platform.
- "Data Processor" means any third party that processes personal data on behalf of lucy97, including payment processors, KYC verification providers and analytics services.
- "KYC" means Know Your Customer — the regulatory identity verification process applied to users before certain Platform functions are enabled.
- "Cookies" means small text files placed on your device by the Platform to enable certain functionality, session management and analytics.
- "Applicable Law" means all laws and regulations relevant to the processing of personal data in the jurisdiction(s) applicable to lucy97's operations, including data protection legislation and anti-money laundering regulations.
Personal Data We Collect
Lucy97 collects personal data through several channels depending on how you interact with the Platform. The categories of personal data we collect are set out below:
3.1 Registration & Account Data
When you create an account on lucy97, we collect:
- Full name
- Date of birth (to verify minimum age eligibility)
- Email address
- Username and encrypted password
- Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar)
- Contact telephone number
3.2 KYC & Identity Verification Data
To comply with anti-money laundering (AML) obligations and to verify your identity, we may collect:
- Copies of government-issued identity documents (e.g., Pakistani CNIC, passport or driver's licence)
- Proof of address documentation
- Source-of-funds documentation where required
- Biometric verification data (if applicable, as directed by our KYC service provider)
3.3 Financial & Transaction Data
When you make deposits or withdrawals, we collect transaction records including:
- Payment method identifiers (e.g., partial bank account details, wallet IDs associated with familiar Pakistani payment rails such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah)
- Transaction amounts in PKR or other supported currencies
- Transaction timestamps and reference numbers
We do not store full payment card numbers. All payment processing is handled by our compliant payment service providers.
3.4 Technical & Usage Data
We automatically collect certain technical data when you access the Platform, including:
- IP address and approximate geolocation
- Device type, operating system and browser version
- Pages visited, time spent on pages, click patterns and referral source
- Session duration and login/logout timestamps
- Game activity logs and betting history (where applicable)
3.5 Communications Data
If you contact our support team via email or live chat, we retain records of that correspondence, including the content of your messages, your contact details and the outcome of any support interaction.
How We Use Your Personal Data
Lucy97 processes your personal data only for specified, legitimate purposes. The table below summarises the primary purposes for which your data is used and the corresponding processing activity:
| Purpose | Processing Activity |
|---|---|
| Account Management | Creating, maintaining and securing your account; processing login sessions; managing account preferences and responsible gambling settings. |
| KYC & Age Verification | Verifying your identity and age to meet legal obligations and to enforce our 18+ (or higher) access policy. |
| Payment Processing | Facilitating deposits and withdrawals; recording transaction history; preventing payment fraud. |
| Regulatory Compliance | Fulfilling anti-money laundering (AML), counter-terrorism financing (CTF) and other applicable legal obligations; cooperating with regulatory authorities upon lawful request. |
| Responsible Gambling | Monitoring activity for signs of problem gambling; applying deposit limits, loss limits and self-exclusion requests; sending responsible gambling reminders. |
| Customer Support | Responding to queries, resolving disputes and managing complaints via email and live chat. |
| Platform Improvement | Analysing usage patterns to improve site functionality, content quality and user experience. Aggregated, anonymised data is used for this purpose where possible. |
| Security & Fraud Prevention | Detecting and investigating unauthorised access, fraudulent activity, bonus abuse and other security threats. |
| Marketing Communications | Sending you promotional offers, bonus notifications and platform updates — only where you have provided consent and subject to your communication preferences. |
We do not use your personal data for automated individual decision-making that produces significant legal effects without human oversight, except where required by applicable law (such as automated fraud screening that is subject to human review upon request).
Legal Basis for Processing
Where applicable data protection law requires a legal basis for processing personal data, lucy97 relies on the following grounds:
- Contractual Necessity: Processing required to fulfil our contractual obligations to you under the Terms & Conditions, including account management, payment processing and KYC verification.
- Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, age verification requirements and regulatory reporting obligations.
- Legitimate Interests: Processing for fraud prevention, platform security, responsible gambling monitoring and analytics — where these interests are not overridden by your privacy rights.
- Consent: Processing for marketing communications and non-essential cookies — where you have expressly consented and subject to your right to withdraw consent at any time without detriment.
Where processing is based on consent, you may withdraw that consent at any time by contacting us at [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Data Sharing & Disclosure
Lucy97 does not sell, rent or otherwise trade your personal data to third parties for commercial marketing purposes. We share personal data only in the following limited circumstances:
6.1 Service Providers & Data Processors
We engage trusted third-party service providers who process personal data on our behalf and under our instruction. These include payment processors, KYC and identity verification providers, cloud hosting and infrastructure providers, customer support tools and analytics platforms. All such processors are contractually bound to handle your data securely and in accordance with applicable data protection standards.
6.2 Regulatory & Law Enforcement Authorities
We may disclose personal data to regulators, government agencies, law enforcement bodies or courts where required by applicable law, court order or regulatory direction. This includes disclosures required under anti-money laundering legislation and counter-terrorism financing regulations applicable in the operator's jurisdiction.
6.3 Business Transfers
In the event of a merger, acquisition, restructuring or sale of all or part of lucy97's business, personal data may be transferred to the acquiring entity as part of that transaction. Users will be notified of any such change to the data controller's identity in accordance with applicable law.
6.4 Fraud Prevention & Security Networks
Where we detect or suspect fraud, money laundering, bonus abuse or other prohibited conduct, we may share relevant information with fraud prevention agencies, industry bodies or other operators where lawful and proportionate to the risk identified.
International Data Transfers
Lucy97 operates internationally and your personal data may be transferred to, stored in, or processed in countries outside of Pakistan. Where such transfers occur, we take appropriate safeguards to ensure that your data receives a level of protection consistent with applicable data protection standards.
Such safeguards may include contractual data protection clauses with data processors, reliance on adequacy decisions by relevant regulatory authorities, or other legally recognised transfer mechanisms. If you require information about the specific safeguards applicable to a particular international transfer of your data, please contact us at [email protected].
Pakistani users should be aware that data protection legislation in Pakistan (including the Personal Data Protection Bill, where in effect) may differ from international standards. Lucy97 endeavours to apply appropriate protections regardless of where data is processed.
Data Retention
We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:
- Account and KYC Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, to comply with anti-money laundering record-keeping obligations.
- Transaction Records: Retained for a minimum of five (5) years following the date of the transaction, or as required by applicable financial regulations.
- Communications Data: Support correspondence retained for up to three (3) years from the date of the interaction, unless a longer period is required for dispute resolution or legal proceedings.
- Technical & Usage Data: Log files and session data retained for up to twelve (12) months, after which they are aggregated or anonymised for statistical purposes.
- Marketing Consent Records: Retained for the duration of the consent and for a reasonable period thereafter to demonstrate that consent was obtained.
Once retention periods expire, personal data is securely deleted or irreversibly anonymised. You may request early deletion of your personal data in accordance with your rights under Section 09, subject to our legal retention obligations.
Your Rights
Subject to applicable data protection law and the exceptions described below, you have the following rights in relation to your personal data held by lucy97:
Right of Access
You may request a copy of the personal data lucy97 holds about you, together with information about how it is used.
Right to Rectification
You may request correction of inaccurate or incomplete personal data held about you.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
Right to Restriction
You may request that we restrict the processing of your data in certain circumstances, such as while the accuracy of the data is being contested.
Right to Portability
Where processing is based on consent or contract, you may request receipt of your personal data in a commonly used, machine-readable format.
Right to Object
You may object to processing of your personal data for direct marketing purposes or where processing is based on legitimate interests, subject to applicable legal grounds.
To exercise any of the above rights, please submit a written request to [email protected]. We will acknowledge your request within 5 business days and respond substantively within 30 days, or such other period as required by applicable law. We may request proof of your identity before processing your request to protect your data against unauthorised access.
Some rights are subject to limitations. For example, we may be unable to delete data that we are required to retain under AML legislation, or restrict processing where it is necessary for legal proceedings. We will always explain the reason if we are unable to fulfil a rights request in full.
Cookies & Tracking Technologies
Lucy97 uses cookies and similar tracking technologies to support Platform functionality, maintain your session, remember your preferences and analyse site performance. Cookies are small text files stored on your device by your browser when you visit the Platform.
Strictly Necessary Cookies
These cookies are essential for the Platform to function correctly. They enable core features such as session management, login security and account preference storage. They cannot be disabled without breaking basic Platform functionality.
Analytics Cookies
We use analytics cookies to understand how users interact with the Platform — which pages are most visited, how long sessions last and where users encounter difficulties. This data is aggregated and used solely to improve the Platform experience. Analytics cookies are only placed where you have provided consent.
Functional Cookies
Functional cookies remember choices you have made on the Platform — such as language preferences, responsible gambling settings and display preferences — to provide a more personalised experience on subsequent visits.
Marketing & Targeting Cookies
Where you have provided consent, marketing cookies may be used to present relevant promotional content based on your activity on the Platform. You may withdraw consent for marketing cookies at any time. We do not use third-party advertising networks to serve ads on external websites using data collected on lucy97.
You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, though doing so may affect the functionality of the Platform. Your consent choices for non-essential cookies are recorded and respected for the duration of your browser session and, where technically feasible, for subsequent visits.
Data Security
Lucy97 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:
- Transport Layer Security (TLS/HTTPS) encryption for all data transmitted between your device and our Platform.
- Encryption of stored sensitive personal data, including KYC documents and financial records.
- Strict role-based access controls ensuring that personal data is accessible only to staff with a legitimate operational need.
- Regular security audits, vulnerability assessments and penetration testing.
- Incident response procedures to identify, contain and respond to data security incidents promptly.
- Staff data protection training and confidentiality obligations.
While we apply robust security measures, no system is entirely immune to security risks. In the event of a data breach that is likely to result in significant risk to your rights and freedoms, we will notify you and any applicable regulatory authority in accordance with our legal obligations and without undue delay.
You are also responsible for maintaining the security of your own account credentials. Never share your password with anyone and notify us immediately at [email protected] if you suspect your account has been compromised.
Minors & Age Verification
The lucy97 Platform is intended exclusively for adults. Access is restricted to individuals who are at least 18 years of age — or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect, store or process personal data relating to individuals under this age threshold.
Age verification is conducted as part of the KYC process. If we discover that an account has been registered by an individual who does not meet the minimum age requirement, that account will be immediately suspended, any balance will be returned (subject to verification of the legitimate account holder's identity), and all associated personal data will be deleted in accordance with applicable law.
Parents & Guardians: If you believe a minor has registered on or accessed lucy97, please contact us immediately at [email protected]. We will investigate and take appropriate action promptly.
Changes to This Privacy Policy
Lucy97 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements or Platform functionality. All amendments will be published on this page with an updated "Last Updated" date.
Where amendments are material — meaning they significantly affect how we collect or use your personal data — we will provide advance notice via a prominent notice on the Platform or by email to your registered address, where reasonably practicable.
We encourage you to review this Privacy Policy periodically. Continued use of the Platform following publication of an updated Policy constitutes acceptance of the changes. If you do not agree with any amendment, you should cease using the Platform and request account closure in accordance with our Terms & Conditions.
Contact Us
If you have any questions about this Privacy Policy, wish to exercise your data rights, or want to make a privacy-related complaint, please contact our data protection team using the details below. All contact information is provided as plain text — it is not a clickable link.
Please include "Privacy Request" in your subject line. We respond within 30 days of receipt.
For general support. English and Urdu languages available. Hours as stated by operator.
When submitting a data rights request, please provide your full name, registered email address and a clear description of your request or concern. We may ask for proof of identity before processing requests involving sensitive personal data.
Your Privacy, Our Priority
Now that you understand how lucy97 handles your data, explore the rest of our platform — game guides, payment information, responsible gambling resources and more.
18+ only, or the higher minimum required by the operator/license jurisdiction. Local laws may restrict gambling in Pakistan.