Table of Contents
Privacy questions?
privacy@lucky31.im
Response within 5 business days
1. Introduction
This Privacy Policy explains how Lucky31 ("we", "us", "our") collects, uses, stores, and protects personal information provided by players ("you", "your") who use the Lucky31 platform at lucky31.im. Lucky31 is an online gaming platform built specifically for Pakistani players, offering sports betting, PSL betting, live casino, virtual sports, Aviator, fishing games, and live cricket scores.
We understand that handing over personal information — your CNIC details, mobile number, payment data — requires trust. Lucky31 takes that responsibility seriously. This policy is written to be transparent about exactly what we do with your data, why we do it, and what control you have over it. We do not collect data we don't need, and we do not use data in ways that aren't described here.
This Privacy Policy should be read alongside Lucky31's Terms and Conditions and Responsible Gaming Policy. By registering an account on Lucky31, you confirm that you have read and understood this Privacy Policy.
If you have questions about anything in this policy that aren't answered here, contact our privacy team at privacy@lucky31.im. We commit to responding within 5 business days.
2. Personal Data We Collect
Lucky31 collects the following categories of personal data from players. We only collect what is genuinely required for operating the platform, processing payments, and meeting our regulatory obligations.
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full name, date of birth, CNIC number, passport number (if provided) | Registration & KYC verification |
| Contact Data | Mobile number, email address, residential address | Registration |
| Financial Data | Easypaisa/JazzCash wallet number, bank account details (IBAN), card details (masked) | Deposits & withdrawals |
| Transaction Data | Deposit amounts, withdrawal amounts, bet history, game history, bonus usage | Ongoing platform use |
| Technical Data | IP address, device type, browser type, operating system, session duration | Automatic — every session |
| Usage Data | Pages visited, games played, features used, time spent on platform | Automatic — ongoing |
| Communications Data | Support chat transcripts, email correspondence, feedback submissions | When you contact us |
| Responsible Gaming Data | Deposit limits set, self-exclusion status, session time limits | When tools are used |
We do not collect sensitive data such as biometric data, health data, or religious or political beliefs unless specifically required by regulatory authorities and with your explicit consent.
3. How We Collect Your Data
Lucky31 collects data through the following channels:
- Directly from you: When you register an account on Lucky31, complete KYC verification, make a deposit or withdrawal, contact support, or fill in any form on the platform.
- Automatically during platform use: Lucky31's systems log technical and usage data as a standard part of operating any web platform. This includes your IP address, device information, pages visited, and session data.
- Through cookies and similar tracking technologies: Lucky31 uses cookies as described in Section 7 below. These collect browsing behaviour data on the Lucky31 platform.
- From third-party identity verification providers: When you complete KYC, Lucky31 works with identity verification partners who may cross-reference your CNIC data with available databases to confirm identity.
- From payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, and our bank and card processing partners provide transaction confirmation data that Lucky31 logs against your account.
4. Why Lucky31 Uses Your Personal Data
Lucky31 uses your personal data for the following specific purposes. We do not use data for purposes beyond those listed here without first obtaining your consent or notifying you via an updated Privacy Policy.
- Account creation and management: To create and maintain your Lucky31 account, verify your identity, and ensure your account is operating correctly.
- Processing transactions: To process your deposits and withdrawals accurately and securely through your chosen payment method (Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, Visa/Mastercard).
- Providing the gaming service: To deliver Lucky31's betting, casino, virtual sports, Aviator, and live cricket score features to you.
- Regulatory compliance and KYC: Lucky31 operates under an international gaming licence. Our licence requires us to verify the identity and age of all players and to maintain certain records for anti-money laundering (AML) compliance. This is a legal obligation, not a choice.
- Fraud prevention and security: To detect and prevent fraudulent activity, account abuse, money laundering, and other security risks on the Lucky31 platform.
- Customer support: To respond to your queries, resolve disputes, and provide assistance through Lucky31's 24/7 support channels.
- Responsible gaming: To implement and monitor deposit limits, loss limits, self-exclusion requests, and other responsible gaming tools you activate on your Lucky31 account.
- Platform improvement: To analyse usage patterns and improve Lucky31's features, performance, and user experience for Pakistani players.
- Marketing communications: To send you promotional offers, bonuses, and platform news — but only if you have opted in to receive such communications. See Section 12 for how to manage your marketing preferences.
5. Legal Basis for Processing Your Data
Lucky31 processes your personal data on the following legal grounds, depending on the purpose:
- Contract performance: Most data processing at Lucky31 is necessary for the performance of the contract between you and us — that is, providing you with the gaming services you've signed up for.
- Legal obligation: Identity verification (KYC), AML record-keeping, and certain data retention requirements are legal obligations under Lucky31's gaming licence. We are required to process this data regardless of your preferences.
- Legitimate interests: Fraud detection, security monitoring, and platform analytics are conducted on the basis of Lucky31's legitimate interest in operating a secure and efficient platform. These interests are balanced against your privacy rights.
- Consent: Marketing communications are sent only with your explicit consent, given at registration or updated at any time through your account settings. You may withdraw consent at any time.
6. Who Lucky31 Shares Your Data With
Lucky31 does not sell personal data to third parties. We share data only where it is necessary to operate the platform, comply with legal requirements, or protect the interests of players and the platform. The following categories of third parties may receive your data:
- Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, and our bank and card processing partners receive the data necessary to process your deposit or withdrawal transactions. These providers are contractually bound to handle your data securely and solely for payment processing purposes.
- Identity verification providers: When you complete KYC, Lucky31 works with third-party identity verification services to confirm your identity and age. These providers receive the data you submit during verification and may cross-reference it with official databases.
- Regulatory and licensing authorities: Lucky31's gaming licence requires disclosure of certain player data to the licensing authority upon request. We are legally obligated to comply with such requests.
- Law enforcement and government bodies: Lucky31 will disclose data to law enforcement, courts, or government agencies when required by law or when we have a good-faith belief that disclosure is necessary to prevent crime, fraud, or harm.
- Technology and infrastructure providers: Lucky31 uses cloud hosting, database management, and other technology services from reputable providers. These providers may process data on Lucky31's behalf but are contractually restricted from using it for any other purpose.
- Fraud prevention and AML screening services: Lucky31 uses specialist services to detect and prevent fraud and money laundering. Certain account and transaction data is processed by these services.
All third parties who receive Lucky31 player data are subject to data processing agreements that require them to maintain appropriate security standards, use the data only for the stated purpose, and not disclose it further without authorisation.
7. Cookies & Tracking Technologies
Lucky31 uses cookies — small text files stored on your device by your browser — to make the platform work correctly and to understand how players use it. Here is a breakdown of the cookies Lucky31 uses:
| Cookie Type | Purpose | Can Be Disabled? |
|---|---|---|
| Required for the platform to function — session authentication, keeping you logged in, maintaining your bet slip, security tokens. | No — disabling these will prevent Lucky31 from working. | |
| Remember your language and display preferences, remember your responsible gaming settings, personalise your Lucky31 experience. | Yes — may affect personalisation features. | |
| Anonymised data about how players navigate the Lucky31 platform — which pages are visited, where users drop off, how features are used. Used to improve the platform. | Yes — opt out via cookie preferences or browser settings. |
Lucky31 does not use advertising cookies or retargeting cookies that track your behaviour across other websites. Our cookie use is limited to what is described above.
You can manage cookies through your browser settings. Most browsers allow you to view, delete, and block cookies. Note that disabling essential cookies will prevent you from logging in and using the Lucky31 platform. For functional and analytics cookies, you can use the cookie preferences option in your Lucky31 account settings.
8. How Long Lucky31 Retains Your Data
Lucky31 retains personal data for as long as is necessary for the purposes described in this policy. The key retention periods are:
- Active account data: Retained for the duration of your Lucky31 account plus a minimum of 5 years after account closure. This is required by anti-money laundering regulations applicable to gaming operators.
- Transaction data: Retained for a minimum of 5 years from the date of each transaction. This is a regulatory requirement under Lucky31's gaming licence.
- KYC and identity documents: Retained for a minimum of 5 years from the date of verification, or longer if required by law.
- Support communications: Retained for 2 years from the date of the last communication.
- Technical and usage data: Retained in aggregated, anonymised form indefinitely for platform improvement purposes. Identifiable technical data is retained for 12 months.
- Marketing consent records: Retained for the period of your account plus 1 year after account closure, to demonstrate compliance with consent requirements.
When personal data is no longer required beyond the retention periods above, it is securely deleted or anonymised so that it can no longer be linked to you.
9. Data Security Measures at Lucky31
Lucky31 takes the security of your personal data seriously and implements technical and organisational measures to protect it against unauthorised access, loss, destruction, or alteration. These measures include:
- Encryption in transit: All data transmitted between your device and Lucky31's servers is encrypted using TLS (Transport Layer Security). The padlock icon in your browser confirms this when you access lucky31.im.
- Encryption at rest: Sensitive data stored in Lucky31's databases — including financial data and identity documents — is encrypted at rest using industry-standard encryption.
- Access controls: Access to personal player data within Lucky31's team is strictly limited to personnel who need it to perform their role. Access is logged and reviewed.
- Secure payment processing: Payment data is processed through PCI-DSS compliant payment processors. Lucky31 does not store full card numbers on its own systems.
- Regular security reviews: Lucky31's platform and infrastructure undergo regular security assessments to identify and address vulnerabilities.
- Incident response: In the event of a data breach that affects your rights or freedoms, Lucky31 will notify you and the relevant regulatory authority without undue delay and in accordance with applicable law.
While Lucky31 implements robust security measures, no online platform can guarantee 100% security. You also have a role to play — keep your Lucky31 password secure, do not share your credentials, and contact us immediately if you suspect unauthorised access to your account.
10. Your Data Rights as a Lucky31 Player
As a Lucky31 player, you have the following rights regarding your personal data. To exercise any of these rights, contact privacy@lucky31.im. Lucky31 will respond within 5 business days.