Privacy Policy — luck65

luck65 ("we", "us", "our", or "the Company") is committed to protecting and respecting the privacy of every individual who uses the luck65 platform — whether you are a registered player based in Karachi, Lahore, Islamabad, Faisalabad, or anywhere else in Pakistan, or a visitor who simply browses our website at luck65.app without registering an account.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by luck65. Please read the following carefully to understand our practices regarding your personal data and how we treat it. This policy applies to all services offered through the luck65 platform, including the website, any associated mobile applications, live casino features, sports betting markets, and customer support channels.

This Privacy Policy should be read alongside the luck65 Terms & Conditions and Responsible Gaming Policy, both of which form part of your overall agreement with luck65.

luck65 collects several categories of personal data in the course of providing its services. The specific data collected depends on how you interact with the platform. The main categories are as follows:

luck65 does not intentionally collect sensitive personal data beyond what is required for age verification and KYC compliance (such as a copy of your government-issued CNIC). Where such documents are submitted, they are processed only for the specific purpose stated and are not used for any other purpose without your explicit consent.

luck65 collects your personal data through the following primary channels:

• Direct interactions: When you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact our support team via live chat or email, or respond to a survey or promotion.
• Automated technologies: As you browse and interact with our platform, we automatically collect technical data such as your IP address, device fingerprint, browser type, and session behaviour using cookies, server logs, and similar tracking technologies.
• Third-party sources: We may receive data about you from KYC verification partners (who confirm the authenticity of identity documents), payment processors (who confirm transaction completion), and fraud prevention services (who flag suspicious activity patterns).
• Public sources: In certain cases, and only where permitted by applicable law, luck65 may cross-reference publicly available information — such as publicly listed company directors — for enhanced due diligence purposes.

luck65 processes your personal data only where we have a lawful basis to do so. The primary purposes for which we use your data are as follows:

• Account management: To create, maintain, and administer your luck65 player account, including processing your login credentials and keeping your profile accurate and secure.
• Service delivery: To enable you to place bets, play casino games, participate in promotions, make deposits and withdrawals, and access all features of the luck65 platform.
• Identity and age verification: To verify that you are at least 21 years of age and are the person you claim to be, in compliance with responsible gaming and anti-fraud obligations.
• Financial transaction processing: To process deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, Raast, and USDT TRC20, and to process withdrawal requests to your nominated payment method.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, money laundering, multi-accounting, and other prohibited conduct that could harm you, other players, or luck65.
• Regulatory compliance: To comply with applicable anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and any lawful requests from regulatory or law enforcement authorities.
• Customer support: To respond to your queries, complaints, and support requests in a timely and helpful manner.
• Marketing communications: Where you have opted in, to send you information about promotions, bonuses, new games, and platform updates. You may opt out of marketing communications at any time by contacting support.
• Platform improvement: To analyse usage patterns and player behaviour in aggregate (anonymised) form, in order to improve the features, performance, and user experience of the luck65 platform.
• Responsible gaming: To monitor your gambling behaviour and, where necessary, to apply responsible gaming interventions such as deposit limits, session reminders, or self-exclusion in accordance with our Responsible Gaming Policy.

luck65 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or having a separate lawful basis for doing so.

luck65 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We may, however, share your data with the following categories of third parties where necessary to deliver our services or comply with legal obligations:

• KYC & identity verification partners: Licensed third-party providers that verify the authenticity of your CNIC, passport, and supporting documents as part of our onboarding process.
• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, Raast, and USDT TRC20 network infrastructure providers process your financial transactions. Each processor operates under its own privacy policy and data security standards.
• Game content providers: Third-party casino game studios (such as Evolution Gaming, Pragmatic Play, and others) may receive a limited set of session data necessary to deliver their games within the luck65 platform.
• Fraud prevention and AML services: Specialist providers that help luck65 detect and prevent financial crime, money laundering, and account fraud. Data shared with these providers is strictly limited to what is necessary for that purpose.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory direction, luck65 may disclose personal data to governmental or law enforcement bodies. luck65 will notify you of any such disclosure where legally permitted to do so.
• Professional advisers: Lawyers, accountants, auditors, and insurers who provide professional services to luck65, subject to strict confidentiality obligations.

luck65 uses cookies and similar tracking technologies to enhance your experience on the platform, remember your preferences, and collect analytical information about how the site is used. A cookie is a small text file placed on your device by a web server when you visit a website.

You can control and manage cookies through your browser settings. Most browsers allow you to refuse some or all cookies, or to alert you when a cookie is being set. Please be aware that disabling essential cookies may affect the functionality of the luck65 platform — for example, you may not be able to remain logged in during a session.

luck65 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The key retention periods that apply to your data are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping obligations.
• KYC documents: Retained for a minimum of five (5) years from the date of submission, in compliance with applicable AML regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Responsible gaming records: Self-exclusion records, deposit limit history, and cooling-off period logs are retained for a minimum of seven (7) years to ensure ongoing compliance with responsible gaming obligations.
• Customer support communications: Retained for three (3) years from the date of the last interaction, or longer if the communication relates to an ongoing dispute or regulatory matter.
• Technical and usage data: Typically retained for thirteen (13) months in aggregate form for analytics purposes, after which it is anonymised or deleted.
• Marketing preference data: Retained for the duration of your account. If you close your account, opt-out records are retained for two (2) years to prevent accidental re-subscription.

Where you request deletion of your personal data and we are not legally obligated to retain it, luck65 will action the deletion request within thirty (30) days of receipt of the verified request.

luck65 has implemented a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security infrastructure includes:

• TLS 1.2 / TLS 1.3 encryption for all data in transit between your device and luck65 servers.
• AES-256 encryption for all sensitive data stored at rest, including KYC documents and financial records.
• Multi-factor authentication (MFA) options available for all registered player accounts.
• Role-based access controls ensuring that luck65 staff can only access personal data where strictly necessary for their job function.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Real-time intrusion detection systems monitoring for anomalous access patterns or data exfiltration attempts.
• Documented incident response procedures with defined escalation paths and regulatory notification timelines in the event of a data breach.

Despite our best efforts, no data transmission over the internet or storage system can be guaranteed to be 100% secure. luck65 cannot warrant the absolute security of data you transmit to us. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, luck65 will notify you without undue delay through your registered contact details.

luck65 respects your rights in relation to your personal data. Depending on your jurisdiction and the applicable legal framework, you may have some or all of the following rights:

• Right of Access: You have the right to request a copy of all personal data that luck65 holds about you. We will provide this in a structured, commonly used, machine-readable format within 30 days.
• Right to Rectification: If any personal data luck65 holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure: You may request that luck65 delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations that may prevent deletion.
• Right to Restriction: You may request that luck65 restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data is being contested.
• Right to Data Portability: You may request that luck65 provide your personal data in a portable format so that you can transfer it to another service provider.
• Right to Object: You have the right to object to luck65 processing your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, subject to an assessment of competing interests.
• Right to Withdraw Consent: Where luck65 is processing your data on the basis of your consent (such as for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

luck65 is strictly an adults-only platform. We do not knowingly collect personal data from individuals under the age of 21. Our registration process requires all users to confirm that they are at least 21 years old, and we employ age verification procedures as part of our mandatory KYC process to substantiate this confirmation.

If luck65 becomes aware that a user under the age of 21 has registered and provided personal data without appropriate parental or guardian consent, we will take the following steps:

• Immediately suspend the account and cease all processing of personal data associated with it.
• Delete or securely destroy all personal data collected from the underage user, to the extent permitted by applicable legal retention obligations.
• Return any deposits made to the originating payment method, net of any winnings, which shall be voided.
• Document the incident and report it to the relevant regulatory or child protection authority where legally required to do so.

luck65 operates as an international gaming platform and, as such, your personal data may be processed on servers located outside Pakistan. In particular, our payment processors, KYC verification partners, and game content providers may operate data centres in jurisdictions outside your country of residence.

Where your personal data is transferred outside of Pakistan to a jurisdiction that may not have equivalent data protection laws, luck65 ensures that appropriate safeguards are in place before the transfer occurs. These safeguards may include:

• Standard contractual clauses approved by recognised international data protection bodies, incorporated into agreements with the relevant third-party processors.
• Binding corporate rules where data is transferred within luck65's group of companies.
• Adequacy decisions or equivalent frameworks recognised by applicable data protection standards.

By registering on luck65 and providing your personal data, you acknowledge and consent to the transfer, storage, and processing of your data in jurisdictions outside Pakistan where luck65's service providers operate, subject to the safeguards described above.

The luck65 platform integrates with a number of third-party service providers to deliver core features, including payment processing, live casino games, sports data feeds, and customer support infrastructure. Each of these providers has its own privacy policy and data handling practices, which are independent of this policy.

luck65 is not responsible for the privacy practices of third-party game studios, payment processors, or other external service providers. However, we only engage third parties who can demonstrate adequate data protection standards and who agree to process data only on our instructions.

luck65 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or platform features. All changes will be published on this page with an updated effective date displayed at the top of the document.

Where changes are material — meaning they significantly affect the way we collect or use your personal data — luck65 will notify registered users via their registered email address or through a prominent in-platform notification at least fourteen (14) days before the changes take effect, where practicable.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way luck65 handles your personal data, please do not hesitate to get in touch with our dedicated Privacy & Support team. We aim to respond to all privacy-related enquiries within five (5) business days.

When contacting us regarding a data rights request, please include your registered email address, the nature of your request, and any relevant account details to help us verify your identity and process your request as efficiently as possible. luck65 will never ask for your password via email or live chat.

For responsible gaming concerns, self-exclusion requests, or queries about deposit limits, please refer to our Responsible Gaming page or contact support directly — we have a dedicated responsible gaming team available around the clock.