Privacy Policy

This Privacy Policy ("Policy") is published by lake97 ("we", "us", "our"), the operator of the website located at https://lake97.cam ("Platform"). This Policy describes the types of personal data we collect from users ("you", "your") who access or use the Platform, the purposes for which that data is processed, the legal bases on which we rely, and the rights available to you in relation to your personal data.

lake97 is an independent online gaming and sports betting information platform. We are not a casino operator, bookmaker or financial services provider. Our Platform provides educational content, guides and transparent information to assist adults in making informed decisions about online gambling platforms. We do not directly operate gambling services, process gambling transactions or handle deposits or withdrawals on behalf of users.

By accessing or using the Platform, you acknowledge that you have read and understood this Policy. We encourage you to read this Policy carefully alongside our Terms & Conditions and our Responsible Gambling Policy.

For the purposes of this Policy, the following terms carry the meanings assigned below:

• "Personal Data" means any information relating to an identified or identifiable natural person — i.e., information that can be used directly or indirectly to identify you, such as your name, email address, IP address or device identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, transmission, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this context, lake97.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller, under binding contractual arrangements.
• "User" means any natural person who accesses, browses or registers on the Platform.
• "Cookies" means small text files placed on your device by the Platform to facilitate certain functionality and analytical purposes.
• "Third-Party Operator" means any external gambling, casino or sports betting platform referenced within the Platform's content.

lake97 collects the minimum personal data necessary to operate the Platform effectively and to fulfil the purposes described in this Policy. The categories of personal data we may collect include:

Personal data is collected through the following mechanisms:

• Direct Provision: When you create an Account, submit a support enquiry, complete a feedback form or otherwise voluntarily provide information to lake97.
• Automated Collection: Technical and usage data is collected automatically when you access the Platform, through server logs, cookies and similar tracking technologies described in Section 10.
• Third-Party Sources: In limited circumstances, we may receive technical or analytical data from trusted third-party analytics providers (e.g., aggregated, anonymised traffic data). We do not purchase personal data from data brokers.

You are not required to create an Account to access most of the Platform's content. Where registration is optional, only Technical Data and Usage Data will be collected automatically if you choose to browse without registering.

lake97 processes personal data only for specific, clearly defined purposes. We will not use your personal data for purposes incompatible with those stated at the time of collection. The purposes for which we process personal data are as follows:

• Account Management: To create, maintain and administer user Accounts on the Platform, including verifying eligibility and age where required.
• Service Delivery: To provide access to Platform features, content guides and educational resources tailored to your profile and usage patterns.
• Customer Support: To respond to enquiries, complaints and support requests submitted via our support channels.
• Security & Fraud Prevention: To detect, investigate and prevent fraudulent activity, unauthorised access and other misuse of the Platform.
• Analytics & Improvement: To analyse usage patterns, measure content performance and improve the Platform's user experience and editorial quality.
• Legal Compliance: To comply with applicable legal obligations, respond to lawful requests from authorities and enforce our Terms & Conditions.
• Communications: To send you service-related communications, updates to policies and — where you have opted in — promotional notifications about Platform content.

Where applicable data protection law requires a legal basis for the processing of personal data, lake97 relies on the following bases:

Where we rely on legitimate interests, we have assessed that our interests do not override your fundamental rights and freedoms as a data subject. You may contact us for further detail on this balancing assessment.

lake97 does not sell, rent or trade your personal data to third parties for commercial purposes. We may share your personal data with third parties only in the following limited circumstances:

• Service Providers (Data Processors): We may engage trusted third-party service providers — such as hosting providers, analytics platforms and email delivery services — to process data on our behalf. These providers are bound by data processing agreements and may only process your data under our documented instructions.
• Legal Obligations: We may disclose personal data to law enforcement agencies, courts, regulatory authorities or other public bodies where we are required to do so by law, court order or binding regulatory instruction.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or substantially all of our assets, personal data may be transferred to the successor entity. We will notify users of any such transfer that materially affects the processing of their personal data.
• Protection of Rights: We may disclose personal data where necessary to investigate, prevent or take action against suspected fraud, illegal activity, threats to safety or violations of our Terms & Conditions.

Payment providers referenced on this Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are mentioned for contextual informational purposes only. lake97 does not share data with these providers and does not process transactions through them.

lake97 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or to comply with applicable legal, regulatory or contractual obligations. Our retention principles are as follows:

• Account Data: Retained for the duration of the active Account relationship, plus a reasonable period following Account closure to address any outstanding queries, disputes or legal obligations.
• Support Communications: Retained for up to twenty-four (24) months following resolution of the support interaction, unless a longer period is required by law or ongoing dispute resolution.
• Technical & Usage Data: Typically retained in identifiable form for up to twelve (12) months, after which data is anonymised or deleted. Anonymised aggregate data may be retained indefinitely for analytical purposes.
• Legal Hold Data: Where data is subject to a legal hold, regulatory investigation or litigation, it will be retained until the hold is lifted, regardless of standard retention periods.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with industry best-practice data disposal procedures.

lake97 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. Our security measures include:

• Encryption: Data transmitted between your device and our servers is encrypted using TLS (Transport Layer Security). Passwords are stored using industry-standard one-way hashing algorithms.
• Access Controls: Access to personal data is restricted to authorised personnel who require it to fulfil their job responsibilities. Access is governed by role-based controls and audit logging.
• Infrastructure Security: Our hosting infrastructure incorporates firewall protections, intrusion detection monitoring and regular security patching.
• Incident Response: We maintain a data breach response procedure. In the event of a breach affecting your personal data that creates a risk of harm, we will notify affected users and relevant authorities in accordance with applicable legal requirements.

lake97 uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are as follows:

You can manage your cookie preferences at any time through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies may affect the functionality of the Platform. Third-party analytics tools used on the Platform process data in accordance with their own privacy policies.

Subject to applicable law, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact us using the details in Section 15.

We will respond to all verifiable data rights requests within thirty (30) days. Where a request is complex or numerous, we may extend this period by a further thirty (30) days, with prior notification. We may request proof of identity before processing a request to protect your data from unauthorised access.

The lake97 Platform is strictly intended for adults aged eighteen (18) years and above, or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect personal data from individuals under the age of eighteen.

During registration, users are required to confirm that they meet the applicable minimum age requirement. lake97 reserves the right to request documentary proof of age — such as a valid CNIC or passport — at any time in order to enforce this requirement.

If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated Account. If you are a parent or guardian and believe your child has registered on the Platform, please contact us immediately using the details in Section 15.

lake97 may transfer, store or process your personal data in countries outside the country in which you reside, including jurisdictions that may not provide the same level of data protection as your home country.

Where such transfers occur, lake97 takes steps to ensure that appropriate safeguards are in place to protect your personal data, which may include:

• Standard contractual clauses approved by competent data protection authorities;
• Transfers to recipients in jurisdictions recognised as providing an adequate level of data protection;
• Binding corporate rules where applicable;
• Other lawful transfer mechanisms as permitted by applicable law.

By using the Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Pakistan. lake97 will take all reasonable steps to ensure your data is treated securely and in accordance with this Policy, regardless of where it is processed.

lake97 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements or Platform features. When material changes are made, we will update the "Last Updated" date displayed at the top of this page.

For significant changes that materially affect the way we process your personal data, we will take reasonable steps to provide more prominent notice — such as a notification on the Platform homepage or, where we hold your email address, a direct communication. It remains your responsibility to review this Policy periodically.

Your continued use of the Platform following an update to this Policy constitutes acceptance of the revised terms. If you disagree with any changes, you should discontinue use of the Platform and may request Account deletion in accordance with your rights under Section 11.

If you have questions, concerns or requests regarding this Privacy Policy or the processing of your personal data, please contact lake97 using the following details:

When submitting a data rights request, please include your registered Account email address and a clear description of the right you wish to exercise. We may ask for proof of identity before processing your request to protect your data from third-party access.