luckpk Privacy Policy
— Your Data, Protected

§ 01 Introduction

This Privacy Policy ("Policy") applies to all personal data processed by luckpk in connection with the operation of the online gaming and sports betting platform accessible at luckpk.net ("Platform"). luckpk is committed to handling personal data with transparency, purpose limitation, and appropriate security measures in full alignment with the principles governing responsible data stewardship.

By accessing the luckpk Platform, creating an account, or otherwise providing personal data to luckpk, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. This Policy is incorporated by reference into the luckpk Terms & Conditions, and Account Holders are encouraged to read both documents together.

This Policy applies to personal data of all luckpk Account Holders regardless of their location across Pakistan — including players based in Karachi, Lahore, Faisalabad, Islamabad, Rawalpindi, Peshawar, and all other cities and regions. The Policy also applies to any individual who contacts luckpk's support team, participates in promotional activities, or interacts with the Platform in any capacity.

§ 02 Data Controller

For the purposes of this Privacy Policy, luckpk acts as the data controller in respect of all personal data collected and processed through the Platform. As data controller, luckpk determines the purposes for which personal data is collected and the means by which it is processed. Where luckpk engages third-party service providers to process personal data on its behalf, those providers act as data processors subject to luckpk's instructions and contractual data processing obligations.

§ 03 Personal Data We Collect

luckpk collects the following categories of personal data in connection with the provision of its services. Data is collected only where it serves a defined and lawful purpose.

luckpk does not collect special categories of sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) except where specifically required to fulfil a regulatory obligation, in which case explicit consent will be sought at the point of collection.

§ 04 How We Collect Your Data

luckpk collects personal data through the following channels:

• Direct provision by the Account Holder: Data provided during account registration, KYC document submission, deposit or withdrawal requests, support interactions, promotional entries, and voluntary profile updates.
• Automated technical collection: Data collected automatically when you interact with the luckpk Platform, including IP addresses, device identifiers, browser fingerprints, and session activity logs collected via server logs, cookies, and similar tracking technologies.
• Third-party sources: Identity and fraud-screening data received from KYC verification service providers, payment processors, and fraud prevention platforms engaged by luckpk to verify account information and detect prohibited activity.
• Public sources: Publicly available information used to supplement identity verification where permitted under applicable law, such as sanction screening databases and politically exposed persons (PEP) lists.

§ 05 How We Use Your Personal Data

luckpk uses personal data collected from Account Holders for the following specific purposes:

• Account creation and management: To register your account, verify your identity and age (21+ requirement), maintain your account in good standing, and process account-level changes.
• Platform services delivery: To process wagers, calculate and credit winnings, settle sports betting markets, operate live casino sessions, and deliver all gaming-related services offered on the luckpk Platform.
• Financial transaction processing: To receive deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and USDT, and to process withdrawal requests to verified payment methods.
• Legal and regulatory compliance: To satisfy our obligations under applicable anti-money laundering (AML), counter-terrorism financing (CTF), and responsible gaming regulations, including suspicious activity reporting where legally required.
• Fraud detection and security: To identify, investigate, and prevent fraudulent activity, account takeovers, bonus abuse, collusion, and other forms of prohibited conduct as defined in the luckpk Terms & Conditions.
• Responsible gaming monitoring: To identify patterns of gaming behaviour that may indicate problem gambling, to enforce deposit and session limits set by Account Holders, and to apply self-exclusion orders promptly and accurately.
• Customer support: To respond to enquiries, resolve complaints, investigate disputed transactions, and maintain records of all support interactions.
• Marketing communications: To send promotional offers, bonus notifications, and platform updates to Account Holders who have consented to marketing communications. Account Holders may opt out of marketing communications at any time via account settings.
• Platform improvement: To analyse aggregated, anonymised usage data for the purpose of improving platform performance, user experience, and product development.

§ 06 Legal Basis for Processing

luckpk processes personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between luckpk and the Account Holder, including account operation, transaction processing, and platform service delivery.
• Legal obligation: Processing required to comply with AML, CTF, responsible gaming, and other applicable regulatory requirements to which luckpk is subject as a licensed gaming operator.
• Legitimate interests: Processing for fraud prevention, security monitoring, duplicate account detection, and platform integrity purposes, where luckpk's legitimate interests are not overridden by the Account Holder's privacy interests.
• Consent: Processing for marketing communications and optional data collection beyond what is required for the above purposes, where the Account Holder has provided explicit, informed, and freely given consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

§ 07 Data Sharing & Third Parties

luckpk does not sell personal data to third parties. Personal data may be shared with third parties only in the following defined and controlled circumstances:

• KYC and identity verification providers: Third-party services engaged to verify the identity, age, and address of Account Holders as required by our regulatory obligations.
• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa acquiring networks, and USDT processing services — to facilitate deposits and withdrawals. Data shared is limited to what is strictly necessary for the transaction.
• Fraud prevention and AML screening platforms: Services used to screen Account Holders against sanction lists, PEP databases, and fraud intelligence networks.
• Gaming software and live casino providers: Game providers whose titles are hosted on the luckpk Platform may receive limited session data required to operate and certify fair game outcomes.
• Regulatory and law enforcement authorities: Where luckpk is under a legal obligation to disclose data to a government authority, court, regulator, or law enforcement body, such disclosure will be made in accordance with applicable law.
• IT infrastructure and cloud service providers: Hosting, backup, and infrastructure providers engaged by luckpk under contractual data processing agreements that require equivalent data protection standards.

All third-party data processors engaged by luckpk are subject to data processing agreements that impose obligations consistent with applicable data protection principles and prohibit any use of personal data beyond the stated purpose.

§ 08 International Data Transfers

In the course of providing its services, luckpk may transfer personal data to recipients located in jurisdictions outside of Pakistan. Where such transfers occur, luckpk ensures that appropriate safeguards are in place to protect the transferred personal data, including contractual clauses that impose data protection obligations on the receiving party equivalent to those applied by luckpk.

luckpk will not transfer personal data to any jurisdiction that does not provide an adequate level of protection for personal data without first implementing appropriate technical and contractual safeguards. Account Holders who wish to obtain further information about the safeguards in place for international transfers may contact luckpk at the details provided in Section 16.

§ 09 Data Retention

luckpk retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to any overriding legal retention requirements. The following general retention periods apply:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, to satisfy AML and regulatory record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, consistent with financial crime prevention obligations.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of the session or wager, for dispute resolution and responsible gaming monitoring purposes.
• Support communications: Retained for a minimum of two (2) years from the date of the last communication in a given enquiry or complaint thread.
• Technical and session data: Retained for up to twelve (12) months, after which it is aggregated or anonymised for analytics purposes.
• Marketing consent records: Retained for the duration of the consent plus three (3) years following withdrawal, to demonstrate compliance with consent obligations.

Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised such that it can no longer be associated with any individual Account Holder.

§ 10 Cookies & Tracking Technologies

The luckpk Platform uses cookies and similar tracking technologies to operate core platform functionality, maintain session security, detect fraudulent access attempts, and analyse aggregated platform usage for performance improvement purposes. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens, security cookies, and load balancing identifiers. They cannot be disabled without disrupting platform functionality.
• Functional cookies: Used to remember Account Holder preferences such as language settings and preferred display options. These enhance the user experience but are not required for core functionality.
• Analytics cookies: Used to collect aggregated, anonymised data about how Account Holders interact with the Platform — such as pages visited, session durations, and feature usage. This data is used solely for internal platform improvement and is not shared with third-party advertising networks.
• Security cookies: Used to detect and prevent fraudulent access, bot activity, and other malicious behaviour on the Platform.

Account Holders may manage their cookie preferences through their browser settings. Disabling strictly necessary cookies may prevent certain Platform features from functioning correctly. luckpk does not use advertising or retargeting cookies and does not share cookie data with third-party marketing platforms.

§ 11 Your Data Rights

Subject to applicable law, luckpk Account Holders hold the following rights in respect of their personal data. Requests to exercise any of these rights should be submitted in writing to the contact details provided in Section 16.

• Right of access: You have the right to request a copy of the personal data luckpk holds about you, together with information about how it is processed.
• Right of rectification: You have the right to request correction of any inaccurate or incomplete personal data held by luckpk. Some corrections may require supporting documentation.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to any overriding legal retention obligations.
• Right to restriction of processing: You have the right to request that luckpk restricts the processing of your personal data in certain circumstances, such as where the accuracy of the data is contested.
• Right to data portability: You have the right to receive the personal data you provided to luckpk in a structured, commonly used, machine-readable format for transfer to another service provider where technically feasible.
• Right to object: You have the right to object to processing of your personal data for direct marketing purposes at any time. You may also object to other processing based on legitimate interests, subject to luckpk demonstrating compelling legitimate grounds.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

§ 12 Children's Privacy

The luckpk Platform is strictly intended for adults aged 21 years and above. luckpk does not knowingly collect personal data from any individual under the age of 21. Age verification is conducted as part of the mandatory KYC process, and no real-money activity is permitted on any account prior to completion of this verification.

If luckpk becomes aware that personal data has been collected from an individual who is under 21 years of age, that account will be immediately suspended, all associated data will be deleted without undue delay, and any funds held in the account will be handled in accordance with applicable regulatory requirements. If you believe a minor has registered on the luckpk Platform, please contact us immediately at the details provided in Section 16.

§ 13 Security Measures

luckpk implements a layered approach to data security, combining technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between Account Holder devices and luckpk servers.
• Encryption at rest for stored personal and financial data using AES-256 standard encryption.
• Two-factor authentication (2FA) available for all Account Holder logins.
• Role-based access controls limiting internal access to personal data to personnel with a defined operational need.
• Regular penetration testing and security audits conducted by independent third-party security firms.
• Automated anomaly detection systems monitoring for unusual account activity, login attempts, and data access patterns.
• Secure, access-controlled data centre environments for all luckpk server infrastructure.

Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. Account Holders are responsible for maintaining the security of their login credentials and should report any suspected account compromise to luckpk support immediately.

§ 14 Third-Party Platform Links

The luckpk Platform does not contain links to third-party websites or external services other than those strictly required to operate its payment and game-provider integrations. However, where Account Holders access luckpk via third-party applications, mobile browsers, or payment provider interfaces, those third parties operate under their own privacy policies over which luckpk has no control.

luckpk is not responsible for the privacy practices or data handling of any third-party service, platform, or application. Account Holders are encouraged to review the privacy policies of any third-party provider they interact with in connection with their luckpk account, including JazzCash, EasyPaisa, and any bank used for deposit or withdrawal transactions.

§ 15 Changes to This Privacy Policy

luckpk reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or luckpk's data processing practices. When material changes are made to this Policy, luckpk will notify Account Holders via the email address or mobile number registered to their account no less than 7 days before the updated Policy takes effect, except where an immediate update is required to comply with a legal or regulatory obligation.

The most current version of this Privacy Policy will always be available at luckpk.net/privacy-policy, with the effective date clearly displayed at the top. Continued use of the luckpk Platform following the effective date of any updated Policy constitutes acceptance of the revised terms. If you do not accept the updated Policy, you must cease using the Platform and close your account.

§ 16 Contact Us

For all privacy-related enquiries, requests to exercise your data rights, questions about this Policy, or to report a suspected privacy breach, please contact the luckpk privacy team using the details below. All privacy correspondence must be submitted in writing. luckpk's support team is available 24 hours a day, 7 days a week.

If you are dissatisfied with luckpk's response to a privacy complaint or data rights request, you have the right to escalate the matter to the relevant data protection authority or regulatory body in the jurisdiction applicable to your situation.