Privacy Policy

This Privacy Policy ("Policy") describes how Luck67 ("the Platform", "we", "us", "our"), operating through the website luck67.cam, collects, processes, stores, and protects personal information provided by or collected about users ("User", "you", "your") in connection with their use of the Platform and its associated services.

Luck67 operates as an internationally hosted online gaming platform. This Policy has been drafted to reflect internationally recognised data-protection principles. Luck67 is not regulated by the State Bank of Pakistan, the Pakistan Telecommunication Authority (PTA), or any Pakistani data-protection authority, and this Policy does not constitute legal advice regarding the application of Pakistani data-protection law to your specific circumstances.

By registering an account, making a deposit, or otherwise using the Platform, you acknowledge that you have read this Policy in its entirety and consent to the processing of your personal data as described herein. If you do not agree with the terms of this Policy, you must not use the Platform.

This Policy should be read alongside the Terms & Conditions, which govern the overall relationship between you and Luck67.

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, phone number, date of birth, payment details, device identifiers, and IP addresses.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, transfer, alteration, erasure, or disclosure.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, Luck67.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a documented instruction.
• "Sensitive Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, health data, financial information beyond account balances, or biometric data.
• "Cookies" means small data files stored on a User's device by the Platform's web server for session management, analytics, and personalisation purposes.
• "KYC" means Know Your Customer — the identity-verification process applied to Users before material account actions such as large withdrawals are processed.

Luck67 collects only the categories of Personal Data that are necessary for the purposes described in this Policy. The table below summarises the main categories:

Luck67 does not intentionally collect Sensitive Data beyond what is strictly required for AML/KYC compliance. We do not collect biometric data, religious or political affiliations, or health information.

The majority of Personal Data is collected directly from you when you: register an account on the Platform; complete KYC document submissions; make deposit or withdrawal requests; interact with live chat or email support; respond to promotions or surveys; or update your account profile settings.

Technical and Usage Data is collected automatically through server logs, cookies, and analytics tools each time you access the Platform. This includes your IP address, device identifiers, browser fingerprint data, session start and end times, and the specific pages, games, and features you interact with during each visit.

We may receive limited data from third-party identity-verification services engaged to support KYC and AML obligations, fraud-prevention providers that flag unusual session or transaction patterns, and payment intermediaries that confirm the status of a transaction. In each case, third-party data sharing is governed by written data-processing agreements requiring compliance with appropriate data-protection standards.

Luck67 processes Personal Data on the following legal bases, consistent with internationally recognised data-protection principles:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions — including account operation, transaction processing, and support services.
• Legal Obligation: Processing necessary to comply with applicable AML, KYC, and fraud-prevention requirements under the laws of the jurisdiction in which the Platform is operated or licensed.
• Legitimate Interests: Processing carried out for purposes such as fraud detection, platform security, service improvement, and responsible-gambling monitoring — where these interests are not overridden by the User's privacy rights.
• Consent: Processing for direct-marketing communications and non-essential cookies, where explicit opt-in consent has been obtained. Consent may be withdrawn at any time by updating account preferences or contacting support.

Luck67 uses collected Personal Data for the following specific purposes:

• Account Management: Creating, maintaining, and administering your User Account, including processing your registration, verifying your identity, and enabling login access.
• Transaction Processing: Facilitating deposits, processing withdrawal requests, and maintaining an accurate PKR-denominated transaction history within your account dashboard.
• KYC & AML Compliance: Verifying identity documents, screening against applicable watchlists, and fulfilling anti-money-laundering monitoring obligations as required by the Platform's operational jurisdiction.
• Fraud Prevention & Security: Detecting and investigating suspicious activity, preventing unauthorised account access, and protecting the integrity of the Platform's gaming and financial systems.
• Customer Support: Responding to enquiries, complaints, and account-related requests submitted through live chat, email, or other support channels.
• Responsible Gambling Monitoring: Monitoring usage patterns to identify potential indicators of problem gambling behaviour, enforcing self-imposed limits, and ensuring self-exclusion requests are implemented correctly.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve game performance, interface design, and overall user experience.
• Marketing Communications: Sending promotional emails, bonus notifications, or platform updates to Users who have opted in to receive such communications. Users may unsubscribe at any time.
• Legal & Regulatory Compliance: Retaining records as required by applicable law, responding to regulatory enquiries, and fulfilling any legal disclosure obligations.

Luck67 shares Personal Data with carefully selected third-party service providers who process data solely on our behalf and under our instructions. These include KYC/identity-verification providers, payment processing intermediaries, fraud-detection service providers, cloud infrastructure and data-hosting providers, and customer-support platform operators. All such providers are bound by data-processing agreements that prohibit them from using the data for any purpose other than delivering the contracted service.

Luck67 may reference payment services familiar to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, and Bank Alfalah — in contextual communications. None of these institutions receive your personal data from Luck67, and none of them are data processors or data partners of the Platform. These references are purely contextual and do not imply any commercial relationship, endorsement, or data-sharing arrangement.

Luck67 may disclose Personal Data to competent law-enforcement or regulatory authorities where required to do so by applicable law, court order, or in connection with an investigation into fraud, money laundering, or other unlawful activity. We will notify affected Users of such disclosures where legally permitted to do so.

Luck67 does not sell, rent, or trade Personal Data to third parties for their own marketing or commercial purposes under any circumstances.

Luck67 uses the following categories of cookies and similar tracking technologies:

• Strictly Necessary Cookies: Essential for Platform functionality — session authentication, security tokens, and load-balancing. These cannot be disabled without affecting core Platform operation.
• Functional Cookies: Retain User preferences such as language settings, game-lobby filters, and responsible-gambling limit configurations between sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how Users interact with the Platform to help us identify performance issues and improve the user experience.
• Marketing Cookies: Used only where you have given explicit consent to receive personalised promotional content. You may withdraw this consent at any time through your account settings.

You can control and manage cookie preferences through your web browser settings. Note that disabling strictly necessary cookies will impair your ability to use core Platform features including login, game sessions, and cashier transactions. Instructions for managing cookies vary by browser — please consult your browser's help documentation for guidance.

Luck67 retains Personal Data only for as long as is 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: Retained for the duration of the account's active status.
• KYC & AML Records: Retained for a minimum of five (5) years following account closure, or longer where required by the laws of the Platform's operational jurisdiction.
• Transaction Records: Retained for a minimum of five (5) years to satisfy financial-record-keeping obligations.
• Support & Complaint Records: Retained for a minimum of three (3) years from the date the matter was resolved.
• Marketing Data: Retained until you withdraw consent to receive marketing communications, after which it is deleted or anonymised within 30 days.

Following the expiry of the applicable retention period, Personal Data is either permanently deleted or irreversibly anonymised so that it can no longer be associated with any identifiable individual.

Luck67 implements appropriate technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• TLS/SSL encryption (256-bit) for all data transmitted between Users' devices and the Platform's servers;
• Encryption of sensitive data fields at rest within our database infrastructure;
• Tokenisation of payment instrument details — full card or bank-account numbers are not stored on Luck67's systems;
• Role-based access controls limiting internal staff access to Personal Data on a strict need-to-know basis;
• Regular security assessments and penetration testing of critical Platform infrastructure;
• Incident-response procedures for detecting, reporting, and managing personal-data breaches.

Luck67 operates as an internationally hosted platform. Personal Data you submit may be transferred to, stored in, and processed in countries other than Pakistan, including the country in which the Platform's servers and operational infrastructure are hosted.

Where Personal Data is transferred internationally, Luck67 takes steps to ensure that appropriate safeguards are in place — including contractual protections in our agreements with data processors — to provide a level of protection comparable to the standards described in this Policy.

By using the Platform, you acknowledge and consent to the transfer of your Personal Data outside of Pakistan for the purposes described in this Policy.

Luck67 recognises the following data-subject rights, which you may exercise by contacting our support team at the details provided in Section 16:

Luck67 will acknowledge rights requests within 48 hours and aims to provide a substantive response within 30 calendar days. We may request identity verification before fulfilling a data-subject request. Where a request is refused, we will provide written reasons. Legal retention obligations — such as AML/KYC record-keeping requirements — may limit the extent to which erasure requests can be fulfilled.

The Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required under the laws of the User's jurisdiction. Luck67 does not knowingly collect Personal Data from individuals under the age of 18.

If we become aware that Personal Data has been submitted by or on behalf of a minor, we will take immediate steps to suspend the associated Account and delete the relevant data from our systems. If you believe that a minor has registered an Account on the Platform, please contact us immediately at the address in Section 16.

The Luck67 Platform does not include links to third-party websites. In the event that any promotional material, email correspondence, or platform communication references a third-party resource, Luck67 is not responsible for the privacy practices, data-security standards, or content of those third-party services. Users who access any external resources do so at their own risk and should review the privacy policies of those services independently.

Luck67 reserves the right to amend this Privacy Policy at any time. Where changes are material — for example, where we intend to process your data for new purposes not previously disclosed, or where we materially change our data-sharing arrangements — we will notify registered Users by email and/or through a prominent notice on the Platform prior to the change taking effect.

Continued use of the Platform following the effective date of any revised Policy constitutes acceptance of the updated terms. The "Last Updated" date at the top of this document reflects when the most recent revision was implemented.

We encourage you to review this Policy periodically to stay informed about how Luck67 handles your personal information.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by Luck67, please contact our support team through the following channels:

• Live Chat: Available 24/7 within your logged-in account dashboard. This is the fastest channel for most data-subject requests.
• Email: [email protected] — please include "Privacy Request" in the subject line for data-subject right enquiries.
• Language: Support is available in English. Urdu-speaking agents are available on request for Users who prefer assistance in Urdu.

We aim to acknowledge data-related queries within 48 hours and to provide a full written response within 30 calendar days.