Privacy Policy — lock97 Platform

This Privacy Policy ("Policy") describes how lock97 ("lock97", "we", "us", "our") — the operator of the online gaming information platform accessible at https://lock97.cam — collects, uses, stores, shares and protects personal data relating to users ("you", "your") of the Platform.

lock97 is committed to handling personal data responsibly, transparently and in accordance with applicable data protection principles. This Policy applies to all users of the Platform regardless of location, including users accessing the Platform from cities across Pakistan such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.

This Policy should be read alongside our Terms & Conditions, which govern your overall use of the Platform. By accessing lock97, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

The following definitions apply throughout this Privacy Policy:

lock97 collects only the data necessary to operate the Platform effectively and provide a functional, personalised user experience. We do not collect excessive or unnecessary personal information. The categories of data we may collect include:

lock97 does not intentionally collect sensitive personal data such as financial account credentials, payment card numbers, biometric identifiers or government ID numbers through this Platform. If you submit a support enquiry that incidentally contains such information, we will handle it with appropriate confidentiality and request that you use secure channels for any sensitive disclosures.

Personal data is collected through the following channels:

• Direct Interaction: When you submit a contact form, support enquiry, newsletter registration or any other voluntary input field on the Platform, you provide data directly to lock97.
• Automated Collection: When you access the Platform, our servers automatically record technical data — including your IP address, device type and browser information — as part of standard web server operation. This data is collected regardless of whether you actively interact with any form.
• Cookies and Tracking Technologies: The Platform uses cookies and similar technologies to manage sessions, remember your preferences and, where you have consented, to collect aggregated analytics data about Platform usage. See Section 8 for full cookie details.
• Third-Party Analytics: Where analytics tools are deployed on the Platform, aggregated usage data may be collected through those tools. Such tools operate subject to their own privacy policies. lock97 does not authorise analytics providers to use your data for their own marketing purposes.

lock97 processes personal data only where there is a lawful basis to do so. The legal bases we rely upon include:

• Consent: Where you have explicitly agreed to a specific processing activity — such as optional analytics cookies or newsletter communications — we rely on your consent. You may withdraw consent at any time without penalty.
• Contractual Necessity: Where processing is necessary to fulfil an agreement with you — for example, to respond to a support enquiry you have submitted.
• Legitimate Interests: Where lock97 has a legitimate interest in processing data that is not overridden by your rights — for example, processing technical and usage data to maintain Platform security and improve functionality.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to lock97 — for example, retaining records as required by applicable law.

In all cases, lock97 applies the principle of data minimisation — collecting and processing only the minimum data necessary for the stated purpose.

lock97 uses personal data collected through the Platform for the following purposes:

• Platform Operation: To deliver, maintain and improve the Platform's content, features and user experience — including page personalisation, session management and content optimisation.
• Support & Communications: To respond to enquiries, support requests and feedback submitted through contact forms or via email. Communications are conducted in English; Urdu-language assistance may be available where provided.
• Security & Fraud Prevention: To detect, investigate and prevent unauthorised access, abuse, fraudulent activity or other security threats to the Platform.
• Analytics & Performance: To understand how users interact with the Platform — which content is read, how long sessions last, which pages are most visited — so that we can improve the information we provide to Pakistani users.
• Legal Compliance: To comply with applicable legal obligations, respond to lawful requests from authorities and enforce these Terms and our Privacy Policy.
• Marketing Communications: Where you have explicitly consented, to send you relevant updates or newsletters about lock97 content. You may unsubscribe from marketing communications at any time.

lock97 does not use personal data for automated individual decision-making or profiling in a way that produces legal or similarly significant effects on users.

lock97 does not sell, rent, trade or otherwise commercially exploit your personal data. We may share data in the following limited circumstances:

• Service Providers: lock97 may engage trusted third-party service providers — such as hosting companies, email delivery services and analytics platforms — to process data on our behalf. All such providers are bound by contractual data processing agreements and are prohibited from using your data for their own purposes.
• Legal Requirements: lock97 may disclose personal data where required by applicable law, court order, regulatory authority or government request. We will inform you of such requests where legally permitted to do so.
• Business Continuity: In the event of a corporate restructuring, merger or acquisition involving lock97, personal data may be transferred to the successor entity, subject to equivalent privacy protections.
• Enforcement: We may share data with legal counsel or enforcement bodies where necessary to protect lock97's legal rights, investigate suspected violations of these Terms, or respond to claims of illegal activity.

The lock97 Platform uses cookies and similar tracking technologies to ensure the Platform functions correctly and to improve user experience. The following types of cookies may be used:

You can manage, restrict or delete cookies through your browser settings at any time. Most browsers allow you to block or delete cookies. Note that disabling essential cookies may impair certain Platform features. For detailed instructions, consult your browser's help documentation.

lock97 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal obligations. Our retention practices are as follows:

• Support Enquiries: Records of support communications are retained for up to 24 months from the date of the last interaction, unless a longer retention period is required by applicable law.
• Technical & Log Data: Server logs and technical data are typically retained for 12 months before being anonymised or securely deleted, except where required for security investigation purposes.
• Analytics Data: Aggregated, anonymised analytics data may be retained indefinitely as it does not constitute personal data once fully anonymised. Individual-level usage data linked to identifiable users is deleted or anonymised within 24 months.
• Newsletter / Marketing Data: Contact details provided for marketing purposes are retained until you unsubscribe or request deletion, at which point they are removed within 30 days.
• Legal Compliance Records: Where retention is mandated by applicable law, data is kept for the legally required period and no longer.

Upon expiry of the applicable retention period, personal data is securely and permanently deleted or fully anonymised so that it can no longer be associated with an identifiable individual.

lock97 implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration, disclosure or unlawful processing. Security measures in place include:

• Encryption in Transit: All data transmitted between your browser and the Platform is protected using TLS (Transport Layer Security) encryption. Pages are served over HTTPS.
• Access Controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis. All internal access is logged and audited.
• Server Security: Platform infrastructure is hosted in secure data centre environments with firewalls, intrusion detection systems and routine security patching.
• Breach Response: In the event of a personal data breach that poses a risk to your rights and freedoms, lock97 will notify affected users and relevant authorities within the timeframes required by applicable law.

Depending on your jurisdiction, you may have some or all of the following rights in relation to your personal data held by lock97. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request".

lock97 will respond to all valid rights requests within 30 calendar days of receipt. We may ask you to verify your identity before processing a rights request to ensure we do not disclose or delete data belonging to another individual.

The lock97 Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the applicable operator's license jurisdiction. The Platform contains information about online gambling and is not suitable for minors in any circumstances.

lock97 does not knowingly collect personal data from any individual under the age of 18. If we become aware that personal data has been submitted by or on behalf of a minor, we will delete that data immediately and without delay.

If you are a parent or guardian and believe that a child in your care has accessed this Platform or submitted personal data, please contact us immediately at [email protected] with the subject line "Minor's Data Concern".

The lock97 Platform may contain informational references to third-party gambling operators, payment providers or sports organisations. This Privacy Policy applies solely to data processed by lock97 in connection with this Platform. It does not extend to any third-party websites, products or services that users may access independently following links or references found on this Platform.

lock97 does not accept responsibility for the privacy practices of third parties. We encourage you to read the privacy policy of any third-party service before providing any personal data to them. Payment providers referenced on this Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — each operate under their own independently maintained privacy policies.

lock97 is an online platform with server infrastructure that may be located outside Pakistan. As a result, personal data submitted through the Platform may be transferred to, stored in, or processed in countries other than Pakistan.

Where personal data is transferred internationally, lock97 takes steps to ensure that appropriate safeguards are in place to protect data to a standard consistent with the principles described in this Policy. These safeguards may include contractual protections with service providers or reliance on recognised international data transfer mechanisms.

By using the Platform and submitting personal data, you acknowledge and consent to any such international transfer of your data as described in this Policy.

lock97 reserves the right to update, modify or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or Platform functionality. Any revised Policy will be posted on this page with an updated "Last updated" date.

For material changes that significantly affect your privacy rights or how your data is used, lock97 will take reasonable steps to communicate the update — such as a prominent notice on the Platform homepage or a direct email notification where we hold your email address.

Your continued use of the Platform after any Policy revision constitutes your acceptance of the updated terms. If you do not agree with any changes, you should discontinue use of the Platform and contact us to request deletion of your data.

For any question, concern or request relating to this Privacy Policy — including data access requests, consent withdrawal, data deletion and privacy complaints — please contact lock97 using the details below. All privacy correspondence should be submitted in English.

lock97 takes all privacy concerns seriously. If you are dissatisfied with our response to a privacy complaint, you may have the right to escalate your concern to the relevant data protection authority in your jurisdiction.