Privacy Policy

1. Introduction §1

This Privacy Policy (the "Policy") is published by Luki33 (the "Operator", "we", "us" or "our"), the operator of the online casino and sports betting platform located at https://luki33.cam (the "Platform"). This Policy describes how we collect, use, store, disclose and otherwise process personal data relating to individuals who access or use our Platform (each, a "User" or "you").

Luki33 is committed to protecting the privacy of all Users, including the many players who access our Platform from cities across Pakistan such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. This Policy has been written in plain English to make your rights and our obligations as clear as possible.

By registering an Account, accessing the Platform or using any of our Services, you acknowledge that you have read and understood this Policy. If you do not agree with how we handle personal data as described here, you should discontinue use of the Platform and may request account closure by contacting our support team.

2. Definitions §2

The following terms carry the meanings set out below throughout this Policy:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, device identifiers and financial account details.
• "Processing" — any operation or set of operations performed on Personal Data, including collection, recording, storage, use, disclosure, transfer or deletion.
• "Data Controller" — the entity (Luki33 / the Operator) that determines the purposes and means of Processing Personal Data.
• "Data Processor" — a third party that Processes Personal Data on behalf of the Data Controller, under contract and in accordance with the Controller's instructions.
• "KYC" — Know Your Customer — identity, age and source-of-funds verification procedures carried out to comply with applicable AML and regulatory obligations.
• "AML" — Anti-Money Laundering — legal obligations and internal procedures designed to detect and prevent the laundering of illicitly obtained funds.
• "Cookies" — small text files placed on your device by the Platform that allow us to recognise your browser and remember certain information.
• "CNIC" — Computerized National Identity Card — the primary national identity document issued to Pakistani citizens by NADRA.

3. Data We Collect §3

We collect Personal Data in the following categories:

We do not intentionally collect special categories of sensitive Personal Data (such as health or biometric data beyond liveness verification for KYC purposes). If a liveness check is used as part of KYC, the data is processed solely for identity verification and is not retained beyond the period necessary for that purpose.

4. Lawful Basis for Processing §4

We process your Personal Data on one or more of the following lawful grounds:

• Contractual Necessity: Processing required to register your Account, manage your use of the Platform, process deposits and withdrawals, and provide customer support.
• Legal Obligation: Processing required to comply with applicable AML legislation, KYC regulations, tax reporting obligations and any other mandatory legal requirements.
• Legitimate Interests: Processing carried out for our legitimate interests in operating a secure platform, detecting and preventing fraud, and improving our services — where those interests are not overridden by your fundamental rights.
• Consent: Where we rely on consent (for example, for certain marketing communications), you may withdraw that consent at any time by contacting our support team or using the opt-out mechanism in the communication.

5. How We Use Your Data §5

We use the Personal Data we collect for the following specific purposes:

To create and maintain your Account, authenticate your identity at login, manage your profile settings, process deposits and withdrawals in PKR, and communicate account-related notifications.

To verify your identity and age, confirm your eligibility to use the Platform, conduct source-of-funds checks, and meet our obligations under applicable anti-money-laundering legislation. KYC verification may be required before withdrawals are approved or at any point during your account lifecycle.

To process your payment transactions, record your betting and gaming activity, calculate and award any applicable bonuses, and maintain an accurate account balance displayed in PKR.

To detect, investigate and prevent fraudulent transactions, account takeovers, bonus abuse, money laundering and other unlawful activity. Technical Data including IP addresses and device fingerprints is used for this purpose.

To administer deposit limits, session controls, self-exclusion requests and other responsible gaming tools you activate. Usage data may be analysed to identify patterns consistent with problem gambling, allowing us to act in your interest.

To respond to your queries, complaints and support requests. Communications Data from support interactions is retained to provide context for future contacts and for quality assurance purposes.

To analyse aggregated usage patterns, improve the Platform's functionality, test new features, and ensure the Platform performs reliably for users across all major Pakistani cities and on the mobile devices most commonly used in the region.

Where you have given consent, we may send you promotional communications about Luki33 offers, bonuses and features by email. You may opt out at any time. We do not send marketing to users who have not consented, and we do not share your contact details with third-party marketers.

6. Data Sharing & Disclosure §6

Luki33 does not sell your Personal Data. We may share your data with the following categories of third parties, strictly for the purposes set out in this Policy:

• KYC / Identity Verification Providers: Third-party services that assist with document verification, liveness checks and AML screening. These providers act as Data Processors under contractual data processing agreements.
• Payment Service Providers: Entities involved in processing your deposits and withdrawals. Payment method names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced as familiar Pakistani payment contexts — their appearance on our Platform does not imply a data-sharing relationship with those specific providers unless a payment transaction is actually processed through them.
• Game and Technology Providers: Software providers whose games or betting markets appear on the Platform. These providers may receive limited technical data necessary for game operation and fairness certification.
• Regulatory and Law Enforcement Authorities: We may disclose Personal Data where required by applicable law, court order, or lawful request by a regulatory authority.
• Fraud Prevention Services: We may share data with specialist fraud prevention and AML screening services to protect the integrity of the Platform.

All third parties with whom we share Personal Data are required to handle it in accordance with applicable data protection standards and are prohibited from using it for any purpose other than the specific service they are contracted to provide.

7. International Data Transfers §7

The Luki33 Platform operates internationally. Your Personal Data may be transferred to, and processed in, countries other than Pakistan, including countries where the Operator's infrastructure or service providers are located. Such countries may have data protection laws that differ from those applicable in Pakistan.

Where we transfer Personal Data internationally, we take appropriate steps to ensure that the receiving party applies an adequate level of protection, which may include contractual safeguards, data processing agreements or other recognised transfer mechanisms.

8. Data Retention §8

We retain your Personal Data only for as long as is necessary for the purposes described in this Policy, or as required by applicable law. The following retention principles apply:

• Active Accounts: Personal Data is retained throughout the period your Account is active and for a reasonable period following account closure to handle any outstanding queries or disputes.
• KYC and AML Records: Identity verification documents and transaction records may be retained for a period of five (5) years or longer following the end of the customer relationship, in accordance with applicable AML legislation.
• Financial Records: Transaction records are retained for the period required by applicable financial and tax regulations.
• Support Communications: Support interaction records are typically retained for a period of two (2) years following the resolution of the relevant query.
• Technical and Usage Data: Anonymised or aggregated usage data may be retained indefinitely for analytical purposes once it no longer identifies individual users.

Upon the expiry of applicable retention periods, Personal Data is securely deleted or anonymised in accordance with our internal data destruction procedures.

9. Cookies & Tracking Technologies §9

Luki33 uses cookies and similar tracking technologies to operate the Platform, maintain your session, analyse usage and improve your experience. The following types of cookies may be placed on your device:

You may manage cookie preferences through your browser settings. Disabling essential cookies will impair Platform functionality and may prevent you from logging in or placing bets. Most modern browsers allow you to review, delete and block cookies — consult your browser's help documentation for instructions.

10. Your Rights §10

Subject to applicable law and any overriding legal obligations (including AML record-keeping requirements), you have the following rights in relation to your Personal Data:

To exercise any of these rights, please contact us at [email protected] with your full name, Account username and a clear description of your request. We will respond within a reasonable timeframe and, where we cannot fulfil a request in full, we will explain why.

11. Minors §11

The Luki33 Platform is strictly for adults aged 18 years or older, or the higher minimum age required by the applicable licence jurisdiction. We do not knowingly collect Personal Data from individuals under the applicable minimum age. If we become aware that an Account was registered by a minor, we will immediately suspend the Account, delete the associated Personal Data and void any transactions, in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor has registered an Account on Luki33 or submitted Personal Data without your consent, please contact us immediately at [email protected] so that we may take prompt action.

12. Security Measures §12

Luki33 implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• 256-bit TLS/SSL encryption for all data transmitted between your device and our servers — indicated by the HTTPS padlock in your browser.
• Restricted access controls ensuring that Personal Data is accessible only to authorised personnel on a need-to-know basis.
• Encrypted storage of KYC documents and sensitive personal information.
• Regular security assessments and vulnerability monitoring of Platform infrastructure.
• Multi-factor authentication options for account access to reduce the risk of unauthorised login.

While we take security seriously, no system is completely impenetrable. In the event of a data breach that poses a material risk to your rights, we will notify you and relevant authorities as required by applicable law.

You also play an important role in keeping your Account secure. Never share your password, always log out on shared devices, and contact [email protected] immediately if you suspect unauthorised access.

13. Third-Party Links & Services §13

The Luki33 Platform may contain references to third-party services, including payment method providers referenced for context (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah). This Policy applies only to data processed by Luki33 directly. Where data is transmitted to or processed by a third-party payment provider in the course of executing a transaction, that provider's own privacy policy governs the handling of data on their side.

We do not control and are not responsible for the privacy practices of any third-party platforms, payment processors or service providers. Users are advised to review the relevant third-party privacy policies before submitting personal data to those services.

14. Changes to This Policy §14

We may update this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law or business practices. The "Last reviewed" date shown in the Table of Contents indicates when this Policy was most recently revised.

Where changes to this Policy are material, we will provide reasonable notice via a notification on the Platform or by email to your registered address. Continued use of the Platform following notification of a revised Policy constitutes your acceptance of the updated terms.

We encourage you to review this Policy periodically to stay informed about how we protect your Personal Data.

15. Contact Us §15

If you have any questions, concerns or requests regarding this Privacy Policy or the way your Personal Data is handled, please reach out to the Luki33 support team using the following contact details:

When submitting a data subject rights request, please include your full registered name, Account username and a clear description of your request. We may need to verify your identity before processing the request to protect your data security.