Privacy Policy

01 Introduction

This Privacy Policy ("Policy") is issued by luckp ("luckp", "we", "us", "our"), the operator of the online gaming platform accessible at https://luckp.cam. It describes our practices with respect to the collection, use, storage, sharing and protection of personal data obtained from individuals ("Users", "you", "your") who visit, register on or otherwise interact with the luckp Platform.

This Policy should be read in conjunction with the luckp Terms & Conditions, which govern your use of the Platform more broadly. By accessing or using the Platform, you acknowledge that you have read this Policy and consent to the data practices described herein. If you do not agree with any aspect of this Policy, you should discontinue use of the Platform and contact us to request account closure.

02 Definitions

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

03 Data We Collect

luckp collects personal data across several categories depending on how you interact with the Platform. The categories are described in the table below:

04 How We Collect Data

Personal data is collected through the following means:

• Direct Submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support or participating in a promotion.
• Automated Technical Collection: Data captured automatically when you access or navigate the Platform, including via cookies, server logs, session trackers and analytics tools integrated into the Platform.
• Third-Party Identity Verification Providers: Where luckp uses a third-party KYC service to verify your identity documents, that provider may share verified data with us as part of the KYC process. Such providers are contractually bound to handle your data in accordance with this Policy.
• Payment Processors: Transaction confirmations and payment status updates received from payment gateway providers in connection with your deposits and withdrawals.
• Fraud Prevention and AML Services: Risk-scoring data or alert flags supplied by third-party fraud detection or anti-money laundering screening services used by the Platform.

05 Data Processing & Use

luckp processes your personal data for the following purposes:

• Account Management: Creating, maintaining and administering your registered account, including credential management, account verification and account closure processing.
• KYC and AML Compliance: Verifying your identity, age and source of funds as required by the Platform's anti-money laundering and responsible gambling obligations. This is a mandatory process — the Platform cannot process withdrawals without completed KYC.
• Transaction Processing: Processing deposits, withdrawals, bonus credits and refunds, and maintaining accurate financial records associated with your account.
• Platform Operation and Security: Detecting and preventing fraud, unauthorised access, multi-accounting, bonus abuse and other prohibited activities outlined in the Terms & Conditions.
• Customer Support: Responding to enquiries, resolving disputes, processing responsible gambling requests (such as self-exclusion and limit-setting) and providing technical assistance.
• Platform Improvement: Analysing aggregated usage data to improve the platform's performance, user experience, game library and support quality. This analysis does not individually identify users.
• Legal and Regulatory Compliance: Fulfilling obligations under applicable laws, responding to lawful authority requests, and maintaining records as required by the Platform's operating licence.
• Marketing Communications: Where you have provided explicit consent, sending promotional notifications about new games, bonuses or platform features. You may withdraw consent to marketing communications at any time via your account settings or by contacting support.

luckp does not sell, rent or trade your personal data to third parties for their own marketing or advertising purposes. This is an unconditional commitment, not a qualified assurance.

06 Legal Basis for Processing

luckp processes personal data on one or more of the following legal grounds:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you have accepted, including account creation, transaction processing and KYC verification.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including AML obligations, fraud prevention mandates and data retention requirements under the Platform's operating licence.
• Legitimate Interests: Processing carried out in furtherance of luckp's legitimate business interests — such as fraud detection, platform security and analytics — where those interests do not override your fundamental privacy rights.
• Consent: Processing for which you have provided explicit, freely given and informed consent, specifically in relation to optional marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

07 Data Sharing & Disclosure

luckp shares personal data with third parties only in the following circumstances, and only to the extent necessary for each stated purpose:

• KYC and Identity Verification Providers: Third-party services contracted to verify identity documents and conduct age and address verification checks as part of the mandatory KYC process.
• Payment Processing Partners: Payment gateways and transaction processors through which your deposits and withdrawals are facilitated. These partners receive only the data required to complete each transaction and are bound by their own data protection obligations.
• Fraud and Risk Management Services: Third-party services used to detect fraudulent transactions, screen for sanctions list matches, and conduct AML risk assessments on account activity.
• IT Infrastructure Providers: Cloud hosting, database management and cybersecurity service providers that process data on behalf of luckp under contractual data processing agreements.
• Customer Support Technology: Live chat, help desk and email ticketing providers used to deliver support services to users.
• Legal and Regulatory Authorities: Competent regulatory bodies, law enforcement agencies or courts where luckp is legally obliged to disclose data in response to a lawful order, warrant or regulatory request.
• Business Transfers: In the event of a merger, acquisition or sale of assets, user data may be transferred to the acquiring entity as part of the transaction, subject to equivalent data protection commitments.

All third-party data processors engaged by luckp are required to handle personal data in accordance with this Policy and applicable data protection standards. luckp does not authorise any third-party processor to use your personal data for their own independent commercial purposes.

08 Data Retention

luckp retains personal data for as long as is necessary to fulfil the purposes described in this Policy, comply with legal obligations and resolve any outstanding disputes. The following general retention principles apply:

• Active Accounts: Personal data associated with an active registered account is retained for the lifetime of the account and for a period thereafter as required by applicable AML and regulatory record-keeping obligations.
• Closed Accounts: Following account closure, personal data including identity verification records, transaction histories and correspondence logs is typically retained for a minimum period of five (5) years, or longer where required by law or ongoing investigation.
• KYC Documents: Identity and address verification documents are retained for the duration required by the Platform's AML obligations, which typically extends to a minimum of five (5) years following the end of the account relationship.
• Marketing Data: Contact details held for marketing purposes are retained until consent is withdrawn, at which point they are removed from active marketing lists promptly. Residual records may be retained in suppression lists to ensure the withdrawal of consent is honoured.
• Technical and Usage Data: Log data and technical session data are typically retained for a shorter period, aligned with operational security and analytics requirements.

When data is no longer required, luckp applies secure deletion or anonymisation procedures to ensure it cannot be recovered or re-identified.

09 Data Security

luckp implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the luckp Platform is encrypted using industry-standard SSL/TLS protocols. The presence of a padlock icon in your browser address bar confirms this encryption is active.
• Access Controls: Access to personal data within luckp's internal systems is restricted on a strict need-to-know basis. Staff who access personal data are subject to confidentiality obligations.
• Two-Factor Authentication: Account-level two-factor authentication is available to all users and is strongly recommended to protect against unauthorised account access.
• Secure Data Storage: Personal data is stored on infrastructure with appropriate access controls, firewalls and intrusion detection systems.
• Regular Security Reviews: The Platform's security practices are reviewed periodically to ensure they remain effective against evolving threats.

10 Cookies & Tracking Technologies

luckp uses cookies and similar tracking technologies to operate the Platform and improve the user experience. The categories of cookies used are described below:

You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of some Platform features. Strictly necessary cookies cannot be disabled without preventing Platform use.

11 User Rights

Subject to applicable law and the Platform's legitimate interests, you have the following rights in relation to your personal data. To exercise any of these rights, please contact the luckp support team via Live Chat or by email at [email protected].

luckp will acknowledge data rights requests within a reasonable timeframe and respond substantively within the period required by applicable law. Requests that are manifestly unfounded, excessive or repetitive may be declined or subject to a reasonable administrative fee, with explanation provided.

12 Minors & Age Restriction

The luckp Platform is strictly intended for adults aged 18 and above, or the higher minimum age required by the operator's licensing jurisdiction. luckp does not knowingly collect personal data from individuals below the minimum permitted age.

Mandatory age verification is conducted as part of the KYC process for all users before withdrawal processing is enabled. If luckp becomes aware that personal data has been collected from a minor — including through falsified registration details — the account will be closed immediately, any funds held will be handled in accordance with regulatory requirements, and the personal data of the minor will be deleted from our systems as promptly as practicable.

If you are a parent or guardian and believe your child has registered on this Platform, please contact us immediately at [email protected].

13 International Data Transfers

As an international platform, luckp may transfer personal data to, or process it in, countries other than the country from which you access the Platform — including countries where you reside, such as Pakistan. Where such transfers take place, luckp ensures that appropriate safeguards are in place to protect personal data to a standard consistent with this Policy, including contractual data transfer mechanisms with processors and sub-processors.

By using the Platform, you acknowledge that your personal data may be transferred internationally as described in this section and consent to such transfer where required.

14 Third-Party Links & Services

The luckp Platform may contain references to third-party payment services, or users may navigate to third-party payment provider interfaces in order to complete deposit or withdrawal transactions. luckp is not responsible for the privacy practices of any third-party website or service. When you leave the luckp Platform, you should review the privacy policy of the third-party service you are using.

This Policy applies solely to data collected and processed by luckp directly. It does not extend to data processed independently by payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — these are referenced as familiar payment options only and each has its own privacy and data practices.

15 Policy Amendments

luckp reserves the right to update or revise this Privacy Policy at any time in response to changes in applicable law, Platform features or data processing practices. Where revisions are material, we will notify registered users by email or via an in-Platform notification prior to the effective date.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the Platform following the publication of a revised Policy constitutes acceptance of the revised terms. If you do not accept the revised Policy, please cease use of the Platform and contact support to close your account.

16 Contact & Data Enquiries

For any questions, concerns or requests relating to this Privacy Policy or the personal data luckp holds about you, please contact us through the following channels:

• Live Chat: Available 24/7 on the Platform. For urgent data concerns — including suspected unauthorised access — Live Chat is the fastest channel, with typical response times under 3 minutes.
• Email: Written data enquiries and formal data rights requests may be submitted to [email protected]. This address is displayed as plain text only and is not a clickable link. Please include your registered account email and a description of your request. We aim to respond within 24 hours for general support queries and within the statutory period for formal data rights requests.
• Help Centre: The self-service Help Centre accessible from your account dashboard covers common privacy and data queries and allows ticket submission for more complex matters.
• Urdu Support: Urdu-speaking support agents are available between 12:00–22:00 PKT for users who prefer to communicate in Urdu. Please request a Urdu-speaking agent at the start of your Live Chat session.