lick91 Privacy Policy — How We Handle Your Personal Data

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by lick91 ("lick91", "we", "us", "our") and applies to all personal data collected from individuals who visit, register with, or use the services available at lick91.net ("the Platform"). This Policy forms an integral part of the lick91 Terms & Conditions and should be read alongside that document.

lick91 is committed to processing personal data in a lawful, fair, and transparent manner. This Policy sets out in full detail what personal data lick91 collects, the purposes for which it is processed, the legal bases that justify that processing, how long data is retained, and the rights available to individuals whose data we process ("Data Subjects" / "Players").

By registering a lick91 account and using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, you should refrain from using lick91 Services and contact the lick91 support team to arrange account closure and data handling in accordance with your rights under Section 12 of this Policy.

2. Identity of the Data Controller

For the purposes of applicable data protection law, lick91 acts as the Data Controller in respect of the personal data of its Players and website visitors. lick91 determines the purposes for which and the means by which personal data is processed.

lick91 operates lick91.net as an internationally licensed online gaming platform. The operator is responsible for all data processing activities described in this Privacy Policy. Contact details for data protection enquiries are provided in Section 16 of this Policy.

Where lick91 engages third-party service providers (such as payment processors, KYC verification services, or game software providers) to process personal data on lick91's behalf, those parties act as Data Processors under lick91's instruction and are contractually bound to process data only for the purposes specified by lick91 and in accordance with applicable data protection standards.

3. Categories of Personal Data Collected

lick91 collects and processes the following categories of personal data:

3.1 Registration and Identity Data

• Full legal name as it appears on the Player's Pakistani CNIC;
• Pakistani CNIC number and CNIC document images (front and back);
• Date of birth (used to verify the 21+ age requirement);
• Gender (as recorded on CNIC);
• Registered Pakistani mobile number;
• Email address;
• City and province of residence.

3.2 Financial and Transaction Data

• JazzCash account number or EasyPaisa mobile wallet number;
• Bank account details (IBAN, account title) where bank transfer is used;
• USDT TRC20 wallet address where cryptocurrency is used;
• Deposit amounts, withdrawal amounts, transaction reference numbers, and timestamps;
• Balance history and wagering activity records.

3.3 Technical and Usage Data

• IP address and approximate geographic location derived therefrom;
• Device type, operating system, and browser version;
• Pakistani mobile network operator (e.g., Jazz, Zong, Telenor, Ufone);
• Session timestamps, page visit logs, and navigation paths within lick91;
• Game session logs including game titles played, stakes, and outcomes.

3.4 Communication Data

• Records of live chat conversations with lick91 support;
• Email correspondence sent to or received from lick91 support addresses;
• Records of any complaints or disputes submitted by the Player.

3.5 Responsible Gaming Data

• Deposit limit settings, session time preferences, and loss limits configured by the Player;
• Cool-off period and self-exclusion records;
• Any responsible gaming flags applied to an account by lick91's monitoring systems.

4. Methods of Data Collection

lick91 collects personal data through the following means:

4.1 Direct Collection

Data provided directly by the Player during account registration, KYC verification, payment processing, customer support interactions, and the configuration of responsible gaming tools. This is the primary source of personal data held by lick91.

4.2 Automated Collection

Data collected automatically when a Player accesses or uses lick91.net, including via cookies, session tracking, and server logs. Technical and usage data (Section 3.3) is collected by automated means. See Section 10 for the full lick91 Cookie Policy.

4.3 Third-Party Sources

In some circumstances, lick91 may receive personal data about a Player from third-party sources, including:

• KYC and Identity Verification Providers: Third-party services that assist lick91 in verifying CNIC authenticity and confirming identity data;
• Payment Processors: JazzCash, EasyPaisa, and banking partners may provide transaction confirmation data to lick91 as part of payment processing;
• Fraud Prevention Services: Third-party fraud and AML screening services may provide risk signals in connection with specific accounts or transactions.

5. Legal Basis for Processing

lick91 processes personal data on one or more of the following legal bases:

Where lick91 processes personal data on the basis of legitimate interest, lick91 has conducted and documented a legitimate interest assessment confirming that the processing is necessary, proportionate, and does not override the fundamental rights and freedoms of the Data Subject.

6. How lick91 Uses Your Personal Data

lick91 uses personal data collected from Pakistani players for the following specific purposes:

6.1 Account Management

To create, maintain, verify, and administer Player accounts on the lick91 Platform, including processing registration, conducting KYC verification, managing account settings, and facilitating login and session management.

6.2 Financial Processing

To process deposit and withdrawal transactions using the Pakistani payment methods supported by lick91 (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, USDT TRC20), to maintain accurate transaction records, and to comply with anti-money laundering requirements applicable to financial transactions processed through the Platform.

6.3 Compliance and Regulatory Obligations

To fulfil lick91's legal obligations under applicable gaming regulation, anti-money laundering (AML) legislation, and Know Your Customer (KYC) requirements. This includes retaining transaction records for the minimum period required by regulation and reporting obligations.

6.4 Responsible Gaming

To monitor Player activity for indicators of problematic gambling behaviour, to apply responsible gaming measures requested by Players (deposit limits, self-exclusion, cool-off periods), and to enforce the lick91 21+ age restriction at the point of registration and on a continuing basis.

6.5 Customer Support

To respond to Player enquiries, process complaints and disputes, and maintain records of support interactions for quality assurance and audit purposes.

6.6 Marketing Communications

To send promotional communications regarding lick91 bonuses, new game launches, and platform updates — but only to Players who have explicitly consented to receive such communications. Players may withdraw marketing consent at any time by contacting lick91 support or using the unsubscribe mechanism in any lick91 marketing email.

6.7 Platform Security and Fraud Prevention

To detect, investigate, and prevent fraudulent activity, bonus abuse, money laundering, underage access, and other prohibited conduct on the lick91 Platform. lick91 employs automated and manual fraud detection systems that analyse transaction and behavioural data for risk signals.

7. Sharing of Personal Data with Third Parties

lick91 does not sell, rent, or trade personal data. lick91 may share personal data with the following categories of third parties, strictly to the extent necessary for the purposes described in this Policy:

7.1 Payment Service Providers

JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and any other payment processor through which a Player conducts transactions. Data shared is limited to what is necessary to process the specific transaction (e.g., mobile number, account reference, transaction amount).

7.2 KYC and Identity Verification Services

Third-party providers contracted to assist lick91 in verifying CNIC authenticity and Player identity as part of mandatory KYC compliance. These providers are Data Processors acting under lick91's instruction and are prohibited from using the data for any other purpose.

7.3 Game Software Providers

Third-party game providers whose titles are accessible through the lick91 Platform may receive a Player's account identifier and session token to facilitate game delivery. These providers do not receive full identity or financial data and operate under data processing agreements with lick91.

7.4 Regulatory and Law Enforcement Authorities

lick91 will disclose personal data to regulatory bodies, law enforcement authorities, or courts of competent jurisdiction where required to do so by applicable law, valid legal process, or a binding regulatory directive. lick91 will, where legally permitted, notify the affected Player of such a disclosure request.

7.5 Fraud Prevention and AML Services

Third-party fraud prevention and anti-money laundering screening services contracted by lick91 to assist in identifying high-risk transactions and account behaviours. Data shared with these services is used exclusively for fraud and AML screening purposes.

8. International Data Transfers

As an internationally operated platform, lick91 may transfer personal data to and process it in countries outside Pakistan. Where such transfers occur, lick91 takes steps to ensure that appropriate safeguards are in place to protect the personal data transferred, including:

• Contractual data protection clauses with the receiving third party that impose data protection obligations equivalent to those applicable to lick91;
• Limiting cross-border data transfers to countries or recipients that maintain data protection standards adequate for the nature of the data being transferred;
• Ensuring that any Data Processor receiving personal data in another country is contractually prohibited from sub-processing that data without lick91's prior written authorisation.

Players who have questions about the safeguards applicable to specific international data transfers may contact lick91 using the details in Section 16 of this Policy.

9. Data Retention Periods

lick91 retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulation. The following indicative retention periods apply:

At the expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with lick91's data destruction procedures. Anonymised data (which can no longer be linked to an individual) may be retained indefinitely for statistical and analytical purposes.

10. Cookie Policy

lick91.net uses cookies and similar tracking technologies to deliver, improve, and secure the Platform. A cookie is a small data file stored on the Player's device by the browser when lick91.net is visited.

10.1 Types of Cookies Used by lick91

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session authentication cookies, security tokens, and load balancing cookies. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember Player preferences such as language, preferred payment method display, and responsible gaming tool settings. These improve the lick91 user experience but are not required for core functionality.
• Analytical Cookies: Allow lick91 to understand how Players navigate and use the Platform, which pages are most visited, and where technical issues arise. Analytical data is processed in aggregated, anonymised form where possible. lick91 uses only first-party analytical tools for this purpose.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic, and multiple account creation attempts. These cookies are essential for Platform integrity.

10.2 Third-Party Cookies

lick91 may permit third-party game providers to set functional cookies necessary for the delivery of their game clients within the lick91 Platform. These cookies are strictly functional and are not used for third-party marketing or advertising tracking. lick91 does not permit advertising network cookies or marketing retargeting cookies on lick91.net.

10.3 Managing Cookies

Players may manage cookie preferences through their browser settings. Disabling strictly necessary cookies will impair the ability to use lick91 Services. Most modern browsers allow Players to view, manage, and delete cookies stored on their device through the browser's privacy settings menu.

11. Technical and Organisational Security Measures

lick91 implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Key security measures in place at lick91 include:

• 256-bit SSL/TLS Encryption: All data transmitted between a Player's device and lick91.net is encrypted using industry-standard SSL/TLS protocols. HTTPS is enforced across the entire Platform.
• Encrypted Data Storage: Sensitive data — including CNIC images, CNIC numbers, and payment method identifiers — is stored in encrypted form at rest. Encryption keys are managed separately from the encrypted data.
• Access Controls: Access to personal data within lick91's systems is restricted on a strict need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and receive data protection training.
• Two-Factor Authentication: lick91's internal administrative systems require multi-factor authentication for staff access. Players are also offered 2FA for their own lick91 accounts.
• Regular Security Reviews: lick91 conducts periodic internal security assessments and engages third-party security professionals to review Platform security on a scheduled basis.
• Incident Response: lick91 maintains a documented data breach response procedure. In the event of a data breach that poses a risk to Players' rights, lick91 will notify affected Players and relevant regulatory authorities in accordance with applicable legal obligations.

Notwithstanding these measures, no online platform can guarantee absolute security against all threats. Players are encouraged to use strong, unique passwords for their lick91 accounts and to enable two-factor authentication to maximise their own account security.

12. Your Rights Over Your Personal Data

Players whose personal data is processed by lick91 have the following rights, which may be exercised by contacting the lick91 support team using the details in Section 16:

• Right of Access: You have the right to request a copy of the personal data lick91 holds about you, including the categories of data held, the purposes for which it is processed, and the recipients to whom it has been disclosed.
• Right of Access: You have the right to request a copy of the personal data lick91 holds about you, including the categories of data held, the purposes for which it is processed, and the recipients to whom it has been disclosed.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and there is no other legal basis), or where the data has been unlawfully processed. Note that lick91 may be required to retain certain data for regulatory compliance periods as set out in Section 9 — erasure requests cannot override mandatory legal retention obligations.
• Right to Restriction: You have the right to request that lick91 restricts the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending verification of whether lick91's legitimate interests override your rights.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interest, including profiling for fraud prevention purposes. lick91 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests or that processing is necessary for legal claims.
• Right to Withdraw Consent: Where processing is based on your consent (such as marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

lick91 will not charge a fee for handling data rights requests unless a request is manifestly unfounded, repetitive, or excessive, in which case a reasonable administrative fee may be applied.

13. Protection of Minors

The lick91 Platform is strictly intended for players who are 21 years of age or older. lick91 does not knowingly collect personal data from individuals under the age of 21. CNIC-based age verification is mandatory at the point of registration, and lick91 employs automated controls to prevent underage access.

If lick91 becomes aware that personal data has been collected from an individual who is under 21 years of age — whether through a registration error, fraudulent documentation, or any other means — lick91 will immediately:

• Suspend the relevant account and cease all processing of that individual's personal data for gaming purposes;
• Retain only the data strictly necessary to document the incident for regulatory compliance and to prevent the individual from re-registering;
• Process a refund of any deposits made to the underage account via the original payment method where technically feasible;
• Report the incident to relevant authorities where required by applicable law or regulatory obligation.

Parents and guardians in Karachi, Lahore, Islamabad, Faisalabad, and across Pakistan are advised to use parental control software to prevent minors from accessing online gaming or gambling platforms. If you believe a minor has accessed or attempted to access lick91, please contact the lick91 support team immediately.

14. Third-Party Websites and Services

The lick91 Platform may contain references to or integrations with third-party services, including payment providers such as JazzCash and EasyPaisa. When a Player initiates a transaction through a third-party payment provider's interface, they are subject to that provider's own privacy policy and data practices.

lick91 is not responsible for the privacy practices, content, or data security measures of any third-party website, application, or service. Players are encouraged to review the privacy policies of any third-party service they use in connection with their lick91 account, including the privacy policies of their chosen payment provider.

Game software delivered within the lick91 Platform by third-party providers is subject to the provider's own terms and data practices in respect of in-game data. lick91 ensures through contractual arrangements that such providers do not use Player data for purposes beyond game delivery and fraud prevention.

15. Updates to This Privacy Policy

lick91 reserves the right to update or amend this Privacy Policy at any time to reflect changes in lick91's data practices, applicable law, or regulatory requirements. The effective date displayed at the top of this Policy will be updated each time a material change is made.

Where changes are material — meaning they significantly affect how lick91 processes personal data or affect Players' rights — lick91 will notify affected Players via their registered email address and/or via a prominent notice in their lick91 account dashboard at least seven (7) days before the changes take effect.

Continued use of the lick91 Platform following the effective date of an updated Privacy Policy constitutes acceptance of the updated terms. If you do not accept the updated Policy, you should stop using lick91 Services and contact support to exercise your data rights as described in Section 12.

The most current version of this Privacy Policy will always be available at lick91.net/privacy-policy. Players are encouraged to review this Policy periodically to stay informed of how lick91 handles their personal data.

16. Contact Information for Privacy Enquiries

For all data protection and privacy-related enquiries, including the exercise of data rights under Section 12, Players should contact the lick91 support team through the following channels:

• Live Chat: Available 24/7 directly within the lick91 Platform — average response time under two minutes. Please select "Privacy / Data Request" as the subject category when initiating the chat.
• Support Email: [email protected] (plain text only — not a clickable link; copy and paste into your email client). Please use the subject line "Privacy Policy Enquiry" or "Data Rights Request" to ensure your message is directed to the appropriate team.

When submitting a data rights request, please include your registered lick91 username and the registered Pakistani mobile number associated with your account so that the support team can verify your identity before actioning the request. lick91 will not process data rights requests without first verifying the identity of the requesting individual, to ensure that personal data is not disclosed to or amended at the request of an unauthorised party.