Privacy Policy

1. Introduction

Clause 1

This Privacy Policy ("Policy") describes how llyyy ("llyyy", "we", "us", "our"), operating the website located at https://llyyy.cam, collects, uses, stores, discloses and otherwise processes personal data relating to registered users, prospective users and visitors to the Platform ("you", "your", "User", "Player").

llyyy is an English-language online gaming platform serving Pakistani users who enjoy casino games, live dealer tables and sports betting — including cricket, PSL/T20, ICC tournaments, football and UFC. Account balances are displayed in PKR. References to payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are made for contextual convenience only and do not imply any data-sharing relationship with or endorsement by those providers.

By accessing, registering on or otherwise using the llyyy Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy.

2. Definitions

Clause 2

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, date of birth, device identifiers and financial data.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data. For users of the llyyy Platform, the Data Controller is the Operator as disclosed on the Platform.
• "Data Processor" means any entity that processes personal data on behalf of the Data Controller.
• "Consent" means a freely given, specific, informed and unambiguous indication of agreement to the processing of personal data for a stated purpose.
• "KYC Data" means identity and address verification documents collected in the course of the Know Your Customer process.
• "Cookies" means small text files placed on your device by the Platform to store session information, preferences and analytics data.

3. Data Controller

Clause 3

The Data Controller for personal data processed through the llyyy Platform is the Operator holding the applicable gambling license under which llyyy operates. The Operator's full legal name, registered address and license details are published on the Platform's footer or licensing disclosure page, as required by applicable regulatory obligations.

Where llyyy engages third-party service providers — such as game studios, payment processors or analytics platforms — those providers act as Data Processors operating under contractual data processing agreements that bind them to process personal data solely on llyyy's documented instructions and in compliance with applicable data protection law.

For all privacy-related queries, requests and complaints, you may contact us using the details set out in Clause 16 of this Policy.

4. Data We Collect

Clause 4

We collect personal data in the following categories, depending on how you interact with the Platform:

Category	Examples	When Collected
Identity Data	Full name, date of birth, CNIC / passport number, nationality	Registration & KYC verification
Contact Data	Email address, mobile number, city of residence (e.g., Karachi, Lahore, Islamabad)	Registration & account updates
Financial Data	Deposit and withdrawal amounts (PKR), transaction history, payment method references	Deposits, withdrawals & KYC
KYC Documents	Scanned CNIC, passport bio-page, proof of address (e.g., utility bill, bank statement)	Identity & age verification
Gameplay Data	Game sessions, bet amounts, win/loss records, bonus usage, sports markets wagered	During platform use
Technical Data	IP address, device type, browser type & version, operating system, session timestamps	Automatically on site visit
Communications Data	Support chat transcripts, email correspondence, feedback submissions	When you contact support
Marketing Preferences	Communication opt-in / opt-out status, preferred notification channels	Registration & account settings

We do not intentionally collect sensitive personal data — such as racial or ethnic origin, religious beliefs, health data or biometric data — except where strictly required by KYC obligations (e.g., processing a document that incidentally contains such information). Where such data is encountered, it is handled with the highest degree of confidentiality and not used for any purpose beyond compliance.

5. How We Use Your Data

Clause 5

We use your personal data for the following purposes:

• Account Management: To create, maintain and administer your llyyy Account, including authentication, password resets and profile updates.
• Service Delivery: To provide access to casino games, live dealer tables and sports betting markets, and to process deposits and withdrawals in PKR.
• Identity Verification: To verify your age and identity in compliance with KYC and anti-money laundering (AML) obligations applicable under the Operator's license jurisdiction.
• Transaction Processing: To process, record and reconcile deposits, withdrawals, bonuses and promotional credits to and from your Account Balance.
• Responsible Gambling: To monitor gameplay patterns and Account activity for signs of problem gambling, and to enforce any self-exclusion, deposit limit or cooling-off period you have activated. See our Responsible Gambling page for details.
• Fraud Prevention & Security: To detect, investigate and prevent fraudulent activity, money laundering, abuse of promotional offers and other prohibited conduct as defined in our Terms & Conditions.
• Legal & Regulatory Compliance: To fulfil obligations under the Operator's license conditions, respond to regulatory inquiries and comply with applicable law.
• Customer Support: To handle queries, complaints and technical issues submitted via our support channels.
• Marketing Communications: To send you promotional offers, bonus notifications and news about llyyy — where you have given consent or where we have a legitimate interest in doing so, subject to your right to opt out at any time.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the performance, reliability and user experience of the Platform.

6. Legal Basis for Processing

Clause 6

We process your personal data under one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing is necessary to perform the contract between you and the Operator — specifically, to create and manage your Account, process transactions and deliver the Services you have requested.
• Legal Obligation: Processing is required to comply with applicable legal and regulatory obligations, including KYC, AML, responsible gambling and licensing requirements.
• Legitimate Interests: Processing is necessary for our legitimate interests — such as fraud prevention, platform security, abuse detection and service improvement — where those interests are not overridden by your privacy rights.
• Consent: Where we rely on your consent as the legal basis — for example, for marketing communications or non-essential cookies — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing & Disclosure

Clause 7

We do 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 data protection safeguards:

• The Operator: The licensed entity responsible for operating the llyyy Platform receives your data as the primary Data Controller for compliance and operational purposes.
• Game Providers: Third-party game studios and live dealer platform providers receive limited technical data (such as anonymised session tokens) necessary to deliver games. They do not receive your identity or financial data beyond what is technically required.
• Payment Processors: Transaction data is shared with payment processors to facilitate deposits and withdrawals. Payment provider names referenced on the Platform (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) are cited for context only; actual payment processing is subject to the Operator's live integrations and none of these providers endorses or supports gambling services at llyyy.
• KYC & AML Service Providers: Identity verification specialists may process your KYC documents on our behalf under strict confidentiality agreements.
• Analytics Providers: Aggregated, anonymised usage data may be shared with analytics platforms to support platform performance analysis. No personally identifiable data is shared for analytics purposes.
• Regulatory Authorities & Law Enforcement: We may disclose personal data to gambling regulators, financial intelligence units or law enforcement agencies where required by law, court order or regulatory demand — including in connection with AML investigations.
• Professional Advisers: Lawyers, auditors and insurers acting in an advisory capacity may access personal data subject to professional confidentiality obligations.

All third-party Data Processors are bound by contractual data processing agreements that prohibit them from using your data for any purpose beyond the specific instructions given by llyyy.

8. International Data Transfers

Clause 8

The Operator may store and process your personal data in countries outside Pakistan, including in the jurisdiction where the Operator holds its gambling license and in countries where our service providers maintain infrastructure. Some of these countries may not have data protection laws equivalent in scope to those of the Operator's license jurisdiction.

Where personal data is transferred internationally, we implement appropriate safeguards to ensure that your data receives an adequate level of protection, which may include:

• Standard contractual clauses approved by applicable data protection authorities;
• Adequacy decisions made by relevant regulatory bodies; or
• Other legally recognised transfer mechanisms as permitted under the applicable data protection framework.

By using the llyyy Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Pakistan in the manner described above.

9. Data Retention

Clause 9

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention principles apply:

• Active Account Data: Personal data associated with an active Account is retained for the duration of your Account's existence on the Platform.
• Closed Account Data: Following Account closure, personal data — including identity, KYC and transaction records — is retained for a minimum period required by the Operator's license jurisdiction (typically five to seven years) to satisfy AML, tax and regulatory audit obligations.
• Marketing Data: Marketing consent records and communication preferences are retained until you withdraw consent or request erasure, subject to any overriding legal obligation to retain records of consent.
• Support Communications: Customer support correspondence is retained for a reasonable period to assist with dispute resolution, typically no longer than three years from the date of last interaction.
• Technical & Log Data: Server logs and technical data are retained for security monitoring purposes, typically for no longer than twelve months, unless a longer retention period is required for an ongoing investigation.

When personal data is no longer required for any legitimate purpose, it is securely deleted or anonymised in accordance with our data disposal procedures.

10. Cookies & Tracking Technologies

Clause 10

The llyyy Platform uses cookies and similar tracking technologies to operate and improve the Platform, remember your preferences and understand how users interact with our Services. We use the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable core features such as Account authentication, session management and security. These cookies cannot be disabled.
• Functional Cookies: These cookies remember your preferences — such as language, display settings and responsible gambling limit configurations — to personalise your experience. You may disable these through your browser settings, though doing so may affect Platform functionality.
• Analytics Cookies: We use anonymised analytics data to understand aggregate usage patterns, identify performance bottlenecks and improve the Platform. Analytics cookies do not identify you personally.
• Marketing Cookies: Where consent has been given, marketing cookies may be used to serve relevant promotional content. You can withdraw consent and disable marketing cookies at any time through your browser or Account settings.

Most browsers allow you to refuse or delete cookies through their settings menus. Disabling strictly necessary cookies may prevent you from accessing certain features of the Platform. For detailed guidance on managing cookies, refer to your browser's official help documentation.

11. Your Data Rights

Clause 11

Subject to applicable law and the Operator's license jurisdiction data protection framework, you have the following rights in respect of your personal data:

To exercise any of these rights, please contact our support team using the details in Clause 16. We will respond to verified requests within 30 days. We may need to verify your identity before actioning a request. These rights are not absolute and may be subject to limitations under applicable law — for example, we cannot erase data that we are legally required to retain for AML or regulatory purposes.

12. Children & Minors

Clause 12

The llyyy Platform is strictly intended for adults aged 18 and over — or the higher minimum age required by the Operator's license jurisdiction. We do not knowingly collect personal data from individuals under the applicable minimum age. If we become aware that a minor has registered an Account or provided personal data to the Platform, we will immediately suspend the Account, delete the associated data, and take steps to prevent re-registration.

If you believe that a minor has accessed the Platform or provided their personal data to llyyy, please contact us immediately at [email protected] so that we can take prompt action.

13. Security Measures

Clause 13

llyyy implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include, but are not limited to:

• Encryption of data in transit using Transport Layer Security (TLS) protocols;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security assessments, vulnerability scanning and penetration testing of Platform infrastructure;
• Staff training on data protection obligations and secure data handling practices;
• Incident response procedures for identifying, containing and reporting personal data breaches in accordance with applicable regulatory timeframes.

While we take data security seriously and maintain robust safeguards, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of data transmitted over the internet. You are responsible for maintaining the security of your Account credentials, as described in our Terms & Conditions.

14. Third-Party Links

Clause 14

The llyyy Platform does not include links to external third-party websites as a matter of policy. However, to the extent that any third-party content, embedded technology or game provider interface accessible through the Platform operates under a separate privacy framework, llyyy is not responsible for the privacy practices of those third parties.

We encourage you to review the privacy policies of any third-party service providers whose technology you interact with through the Platform, including game studios and payment processors, where their own privacy notices are made available to you.

15. Changes to This Policy

Clause 15

We reserve the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations or the Operator's operational requirements. The effective date at the top of this page will be updated accordingly whenever a material change is made.

Where changes are significant, we will endeavour to notify registered users by email or by displaying a prominent notice on the Platform prior to the changes taking effect. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms.

We recommend reviewing this page periodically to remain informed about how llyyy protects your personal data.

16. Contact & Complaints

Clause 16

If you have any questions, concerns or complaints regarding this Privacy Policy or our data processing practices, or if you wish to exercise any of your data rights as described in Clause 11, please contact our Privacy support team using the details below:

We take all privacy complaints seriously and will work to resolve your concern promptly and transparently. If you are not satisfied with our response, you have the right to escalate your complaint to the relevant data protection supervisory authority in the Operator's license jurisdiction.