luck22 Privacy Policy

1.1 luck22 ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all players and visitors who interact with our online casino and sports betting platform at https://luck22.pro.

1.2 This Privacy Policy sets out in full detail: the categories of personal data we collect from you; the purposes for which we use that data; the legal bases on which we rely to process your data; the circumstances under which your data may be shared with third parties; the security measures we employ to keep your data safe; the length of time we retain your data; and the rights you have in relation to your personal data.

1.3 This Privacy Policy applies to all users of the luck22 platform, including registered account holders, visitors who browse without registering, and individuals who contact our customer support team. It applies regardless of the device or browser used to access luck22 — desktop, mobile, or tablet.

1.4 This Privacy Policy should be read alongside the luck22 Terms & Conditions and our Responsible Gaming Policy, both of which form part of your agreement with luck22.

1.5 luck22 is the data controller in respect of all personal data processed under this Privacy Policy. Our designated data protection contact can be reached at: [email protected]

2.1 luck22 collects personal data from you in three principal ways: data you provide to us directly, data we collect automatically when you use the platform, and data we receive from third parties (such as payment processors and identity verification providers). The specific categories of data we collect are described below.

2.2 Data you provide directly:

• Full legal name (as per your CNIC or passport);
• Date of birth (for age verification purposes);
• Email address;
• Mobile phone number;
• Residential address (including city, province, and postcode);
• Copies of identity documents submitted for KYC verification (e.g., CNIC front and back, passport bio page);
• Proof of address documents (e.g., utility bill, bank statement);
• Financial information including payment method details (JazzCash account number, EasyPaisa number, bank account details for HBL, UBL, Meezan Bank transfers);
• Source of funds declarations where required by our compliance team;
• Communications you send to luck22 customer support via live chat, email, or any other channel.

2.3 Data collected automatically:

• IP address and geolocation data (city-level);
• Device type, model, and operating system;
• Browser type and version;
• Session duration and pages visited within the luck22 platform;
• In-game activity logs, including games played, wagers placed, and outcomes;
• Transaction history (deposits, withdrawals, bonus activations, wagering activity);
• Login timestamps and frequency of platform access;
• Cookies and similar tracking technologies (see Section 6 for full details).

2.4 Data received from third parties:

• Identity and age verification results from third-party KYC providers;
• Transaction confirmation data from payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank);
• Fraud risk indicators from third-party fraud detection services;
• Responsible gaming flags from self-exclusion registers, where luck22 has access to such registers under its licensing obligations.

3.1 luck22 uses your personal data only for the purposes described in this Privacy Policy. We do not use your data in ways that are incompatible with the purposes for which it was collected. The primary purposes for which we process your personal data are as follows:

3.2 luck22 will never use your personal data for automated individual decision-making that produces significant legal effects without providing you the right to request human review of that decision.

4.1 luck22 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing that is necessary to perform the contract between you and luck22 — including operating your account, processing deposits and withdrawals, and providing access to games and betting markets.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC verification, AML monitoring, age verification, and responding to lawful regulatory requests.
• Legitimate interests: Processing carried out for luck22's legitimate business interests, such as fraud detection, platform security, abuse prevention, and improving platform performance, provided these interests are not overridden by your fundamental privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily in the context of marketing communications and non-essential cookies. You may withdraw this consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

4.2 Where luck22 relies on legitimate interests as the legal basis for processing, we conduct a balancing test to ensure that our interests do not override your rights and freedoms as a data subject.

5.1 luck22 does not sell your personal data to third parties. We do not share your data for third-party marketing purposes. However, luck22 may share your personal data with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment service providers, solely to the extent necessary to process your deposits and withdrawals in PKR.
• KYC and identity verification providers: Third-party identity verification services that assist luck22 in verifying your identity, age, and address in accordance with our licensing KYC obligations.
• Fraud detection and AML services: Specialised third-party services that assist luck22 in identifying and preventing fraudulent activity and financial crime on the platform.
• Game software providers: Third-party casino game developers and live dealer studios whose games are integrated within the luck22 platform. These providers may receive limited technical data (such as player ID and wager amounts) necessary to operate their games within our environment.
• Customer support tools: Third-party live chat and helpdesk software providers used to manage and record customer support interactions. These providers process data solely on luck22's instructions.
• Regulatory and law enforcement authorities: Relevant gaming regulators, financial intelligence units, tax authorities, and law enforcement agencies, where disclosure is required by law, court order, or our licensing obligations.
• Professional advisers: Lawyers, auditors, and accountants where access to your data is strictly necessary for the provision of their professional services to luck22.

5.2 All third-party service providers with whom luck22 shares personal data are required to handle that data in accordance with applicable data protection standards and are contractually prohibited from using your data for any purpose other than that for which it was shared.

6.1 luck22 uses cookies, web beacons, pixel tags, and similar tracking technologies on its platform. This section explains what these technologies are, what types we use, and how you can manage your preferences.

6.2 What are cookies? A cookie is a small text file placed on your device by a website when you visit it. Cookies allow the website to remember your actions and preferences (such as login status, language, and other settings) over a period of time, so that you do not have to keep re-entering them each time you visit.

6.3 Types of cookies used by luck22:

• Strictly necessary cookies: These are essential for the luck22 platform to function. They enable core features such as session management, login authentication, and security controls. These cookies cannot be disabled.
• Functional cookies: These remember your preferences (such as language settings and display options) to provide a more personalised experience on luck22.
• Performance and analytics cookies: These collect aggregated, anonymised information about how players use the luck22 platform — such as which pages are visited most frequently — to help us improve platform performance and user experience.
• Marketing cookies: These track your browsing behaviour to allow luck22 to deliver personalised promotional content. These are only activated if you have given explicit consent.

6.4 Managing your cookie preferences: You can manage or withdraw your consent to non-essential cookies at any time through your web browser settings. Please note that disabling certain cookies may affect the functionality and performance of the luck22 platform. For instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

6.5 luck22 does not use cookies or tracking technologies to collect data from individuals who are known to be under 21 years of age.

7.1 luck22 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, as described in this Privacy Policy, and to comply with our legal, regulatory, and licensing obligations.

7.2 The following general retention periods apply:

7.3 Where your account is closed at your own request and there are no outstanding compliance or legal hold requirements, luck22 will anonymise or securely delete your personal data that is no longer required within a reasonable timeframe following the expiry of the applicable retention period.

8.1 luck22 employs a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and the luck22 platform;
• AES-256 encryption for sensitive data stored within our databases;
• Multi-factor authentication (MFA) options for player account access;
• Strict role-based access controls limiting internal staff access to personal data on a strict need-to-know basis;
• Regular third-party penetration testing and vulnerability assessments of platform infrastructure;
• Continuous automated monitoring for suspicious access patterns, intrusion attempts, and anomalous data queries;
• Secure data centre facilities with physical access controls, CCTV monitoring, and environmental protection systems.

8.2 Despite these measures, no internet-based platform can guarantee absolute security against all possible threats. luck22 will notify affected players and relevant authorities in the event of a data breach that is likely to result in a risk to your rights and freedoms, in accordance with applicable notification obligations.

8.3 You also play an important role in keeping your data secure. You are responsible for maintaining the confidentiality of your luck22 account password and for logging out of your account on shared devices. If you suspect that your account has been accessed without your authorisation, contact us immediately at [email protected].

9.1 As a player on luck22, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request — [Your Account ID]". We will respond within thirty (30) days of receiving a valid request.

• Right of access: You have the right to request a copy of the personal data luck22 holds about you, together with information about how it is being used.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated without undue delay.
• Right to erasure ("right to be forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where you object to processing based on legitimate interests. Note that this right may be limited where luck22 is required to retain data for legal, regulatory, or licensing purposes.
• Right to restrict processing: You may request that luck22 temporarily suspend the processing of your personal data in certain circumstances — for example, while the accuracy of data you have disputed is being verified.
• Right to data portability: Where processing is based on your consent or on contractual necessity, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format, and to transmit that data to another controller.
• Right to object: You have the right to object to processing of your personal data where luck22 relies on legitimate interests as the legal basis. luck22 will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Rights in relation to automated decision-making: You have the right not to be subject to a decision based solely on automated processing that produces significant legal effects, and to request human review of any such decision.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

10.1 luck22 operates internationally, and some of the third-party service providers we work with — including game software providers, KYC verification services, and cloud infrastructure providers — may process your personal data in countries outside Pakistan.

10.2 Where personal data is transferred internationally, luck22 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under applicable data protection law. These safeguards may include:

• Standard contractual clauses approved by recognised data protection authorities;
• Binding corporate rules where data is transferred within a corporate group;
• Transfers to countries that have been assessed as providing an adequate level of data protection;
• Specific contractual protections agreed with individual service providers.

10.3 Players may request information about the specific safeguards in place for any particular international transfer by contacting [email protected].

11.1 luck22 is strictly an adults-only platform. We do not knowingly collect personal data from any individual under the age of 21. The collection of personal data from minors is strictly prohibited.

11.2 The luck22 registration process requires all applicants to confirm that they are at least 21 years of age. Age verification checks are conducted as part of the KYC process to validate this declaration.

11.3 If luck22 discovers or has reasonable grounds to suspect that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the data in question to the extent permissible by our legal obligations, and investigate the circumstances of the registration.

11.4 If you are a parent or guardian and believe that a minor in your care may have registered on luck22, please contact us immediately at [email protected] so that we can investigate and take appropriate action without delay.

12.1 luck22 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, regulatory requirements, or the services we offer. The effective date and version number shown at the top of this document will be updated with each revision.

12.2 Where changes to this Privacy Policy are material — meaning they significantly affect your rights or how luck22 uses your data — luck22 will notify registered players via the email address associated with their account at least fourteen (14) days prior to the changes taking effect.

12.3 Minor updates, such as typographical corrections or clarifications that do not alter the substance of the policy, may take effect immediately upon publication. Continued use of the luck22 platform following any update to this Privacy Policy constitutes acceptance of the revised policy.

12.4 We encourage you to review this Privacy Policy periodically to remain informed about how luck22 is protecting your personal data.

13.1 General Privacy Enquiries. If you have any questions about this Privacy Policy, about how luck22 handles your personal data, or about exercising your data rights, please contact our data protection team at: [email protected]

13.2 Formal Privacy Complaints. If you wish to raise a formal complaint about luck22's data processing practices, please submit your complaint in writing to [email protected] with the subject line "Privacy Complaint — [Your Account ID]". luck22 will acknowledge receipt of your complaint within forty-eight (48) hours and provide a substantive written response within twenty-one (21) calendar days.

13.3 Regulatory Escalation. If you are not satisfied with luck22's response to your privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction, or to the data protection authority associated with luck22's gaming licence jurisdiction.