Privacy Policy — llyy

This Privacy Policy ("Policy") describes how llyy ("llyy", "we", "us" or "our") collects, uses, stores, discloses and otherwise processes personal data in connection with your use of the website located at https://llyy.cam (the "Site").

llyy is an English-language informational and educational platform providing guides and content related to online sports betting, casino gaming, payment methods and responsible gambling practices, with content specifically tailored for users in Pakistan. We do not operate a gambling service, accept bets or process any financial transactions on behalf of users.

We are committed to protecting your personal data and handling it responsibly, transparently and in compliance with applicable data protection principles. By using this Site, you acknowledge that you have read, understood and agree to the data practices described in this Policy.

This Policy should be read alongside our Terms and Conditions, which govern your general use of the Site.

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

• "Personal Data" means any information that identifies or can be used to identify a natural person, directly or indirectly, including name, email address, IP address, device identifiers and browsing behaviour.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, transfer, disclosure, deletion or any other form of handling.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, the Data Controller is llyy.
• "Data Processor" means a third party that processes Personal Data on behalf of and under the instruction of the Data Controller.
• "User" means any individual who accesses, browses or otherwise uses the Site.
• "Cookies" means small text files stored on a User's device by their web browser when they visit a website, used to retain information across browsing sessions.
• "Consent" means a freely given, specific, informed and unambiguous indication of the User's agreement to the processing of their Personal Data for a stated purpose.
• "Retention Period" means the defined period of time for which llyy stores a category of Personal Data before it is deleted or anonymised.

The Data Controller responsible for Personal Data collected through the Site is:

If you have any questions, concerns or requests relating to this Policy or to the handling of your Personal Data, please contact us using the email address above. Further contact details are set out in Section 16 of this Policy.

llyy collects the minimum Personal Data necessary to operate this informational website effectively and to understand how Users engage with our content. The categories of data we collect are described in the table below.

We do not knowingly collect sensitive personal data such as data concerning racial or ethnic origin, political opinions, religious beliefs, health information, biometric data or criminal history through the use of this Site.

llyy collects Personal Data through the following means:

• Automatic collection: When you visit the Site, certain technical and usage data is collected automatically by our web server and analytics tools without any action required from you. This includes your IP address, browser information and the pages you access.
• Cookies and similar technologies: The Site may use cookies, web beacons and similar tracking technologies to collect usage and preference data. Please refer to Section 7 of this Policy for detailed information on our use of cookies.
• Direct communications: If you contact llyy directly by email (for example, to submit a general enquiry), we collect the Personal Data you choose to include in that communication, such as your email address and the content of your message.
• Third-party analytics services: We may use third-party analytics providers that collect usage data on our behalf. These providers act as Data Processors under our instruction and are subject to appropriate data processing agreements.

llyy does not purchase Personal Data from data brokers or acquire it from third-party data sources other than through the analytics service providers described above.

llyy processes Personal Data only where there is a lawful basis to do so. The following table sets out the purposes for which we process data and the corresponding legal basis for each.

llyy does not process Personal Data for automated decision-making or profiling that produces legal or similarly significant effects on Users. We do not use Personal Data for targeted behavioural advertising.

Cookies are small text files stored on your device by your web browser when you visit a website. llyy uses cookies to enable core Site functionality, understand how Users interact with our content, and remember your preferences across sessions.

We use the following categories of cookies:

• Strictly Necessary Cookies: These are essential for the Site to function correctly and cannot be switched off. They are set in response to actions you take, such as setting privacy preferences or navigating between pages. No consent is required for these cookies.
• Analytics and Performance Cookies: These cookies collect information about how Users interact with the Site — which pages are visited most frequently, how long Users stay, and whether they encounter errors. The data collected is aggregated and anonymised where possible. These cookies require your consent where applicable law demands it.
• Preference Cookies: These cookies allow the Site to remember choices you make, such as language settings or cookie consent selections, to provide a more personalised experience.

llyy does not use cookies to deliver targeted advertising or to track your activity across third-party websites for commercial profiling purposes.

llyy does not sell, rent or trade Personal Data to third parties. We may share data in the following limited circumstances only:

• Service Providers (Data Processors): We engage third-party service providers to assist us in operating the Site and analysing usage data. These may include website hosting providers, analytics service providers and content delivery networks. Such providers process data solely on our behalf, under written data processing agreements that require them to apply equivalent data protection standards.
• Legal and Regulatory Requirements: We may disclose Personal Data where required to do so by applicable law, court order, regulatory authority or government directive. We will, where lawfully permitted, notify affected users of such disclosures.
• Protection of Rights: We may disclose data where necessary to protect the rights, property or safety of llyy, its users or the public, including for the purposes of fraud prevention and Site security.
• Business Transfers: In the event that llyy undergoes a merger, acquisition, asset sale or restructuring, Personal Data may be transferred as part of that transaction. Users will be notified of any change in data controller identity and their rights in connection with such a transfer.

llyy operates as an internationally accessible website. As a result, Personal Data collected through the Site may be stored on or processed by servers located outside Pakistan. In particular, third-party analytics and hosting providers engaged by llyy may store data in jurisdictions that have their own data protection regimes.

Where Personal Data is transferred internationally, llyy takes reasonable steps to ensure that appropriate safeguards are in place to protect that data, which may include:

• Engaging only service providers who operate under established data protection frameworks;
• Including appropriate data protection clauses in contracts with service providers;
• Verifying that service providers maintain security standards commensurate with the sensitivity of the data transferred.

By using this Site, you acknowledge that your Personal Data may be transferred to and processed in jurisdictions outside Pakistan. If you have concerns about international data transfers, please contact us using the details in Section 16.

llyy retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

Upon expiry of the applicable Retention Period, Personal Data will be securely deleted or rendered permanently anonymous in a manner that prevents re-identification. Where anonymised, such data may be retained for statistical and analytical purposes without restriction.

llyy implements appropriate technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include, but are not limited to:

• Transmission of data over encrypted HTTPS connections using industry-standard SSL/TLS protocols;
• Access controls restricting Personal Data to authorised personnel only, on a need-to-know basis;
• Regular review of data processing practices and security controls;
• Vendor due diligence processes for third-party service providers who process data on our behalf;
• Procedures for detecting, reporting and responding to suspected data breaches.

Subject to applicable data protection law, you have the following rights in relation to your Personal Data held by llyy. You may exercise these rights by contacting us using the details in Section 16.

We will respond to all legitimate rights requests within a reasonable timeframe, ordinarily within 30 days of receipt of a valid request. We may need to verify your identity before processing certain requests. There is no charge for exercising your rights in most circumstances; however, we reserve the right to charge a reasonable administrative fee for manifestly unfounded or excessive requests.

This Site is intended exclusively for adults aged 18 years or older — or the higher minimum age required by the applicable operator or license jurisdiction. llyy does not knowingly collect, use or retain any Personal Data from individuals under the age of 18.

If we become aware that Personal Data has been collected from a person under 18 years of age without appropriate parental or guardian consent, we will take immediate steps to delete that information from our records. If you are a parent or guardian and believe that your child has submitted Personal Data to llyy, please contact us immediately at [email protected] and we will act promptly.

Access to this Site by minors is strictly prohibited. Users confirm, by accessing the Site, that they meet the applicable minimum age requirement.

llyy is an English-language information platform with content specifically designed for users in Pakistan, including those located in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and other cities across the country.

Pakistan does not currently operate a comprehensive general-purpose data protection statute equivalent to certain international frameworks. However, llyy is committed to applying data protection principles — including data minimisation, purpose limitation, accuracy, storage limitation and security — to all Personal Data processed through this Site, regardless of the User's location.

Users in Pakistan should note the following:

• llyy does not collect or process data in connection with gambling accounts, deposits, withdrawals or wagers — no such activity occurs on this Site.
• References to payment services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on this Site are for contextual informational purposes only. llyy has no data-sharing arrangement with any of these entities.
• Users are responsible for understanding and complying with applicable Pakistani law, including in relation to online privacy and gambling-related activities, when using this Site or any third-party platform accessed following a visit to this Site.

llyy 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 the nature of the Site. The most current version of this Policy will always be published at https://llyy.cam/privacy-policy, with the Effective Date at the top of the page updated accordingly.

Where we make material changes to this Policy — particularly changes that affect how we use your Personal Data or your rights in relation to it — we will make reasonable efforts to bring those changes to Users' attention, which may include a prominent notice on the Site.

Your continued use of the Site following the publication of an updated Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must cease using the Site.

We recommend that you review this Policy periodically to remain informed of how llyy processes your Personal Data.

If you have any questions, concerns or requests regarding this Privacy Policy or the handling of your Personal Data by llyy, please contact our data team using the information below.

Please note that llyy is an informational website only. We are not able to assist with account issues, payment disputes or queries relating to any third-party gambling platform. For such matters, please contact the relevant operator directly.