Lucky Game Privacy Policy — Pakistan

Lucky Game, operated at luckygame-khelo.com, is the data controller for all personal information collected through this platform. "Data controller" simply means that Lucky Game is the entity responsible for deciding why and how your personal data is processed. We are not a data broker or intermediary — your information is handled directly by Lucky Game's operations team under the oversight of our Data Protection Officer.

Lucky Game operates under an international gaming licence and complies with applicable data protection obligations in the jurisdictions in which we operate. Our commitment is straightforward: we collect only what we need, use it only for the purposes described in this policy, and protect it with industry-standard security measures. Pakistani players are a core audience for Lucky Game, and the way we handle your data reflects the trust you place in us when you deposit real PKR and share your personal details.

For any privacy-related queries, including requests to access, correct, or delete your data, you can contact Lucky Game at: [email protected]. We respond to privacy queries within 72 hours.

Lucky Game collects personal data through several routes: directly from you during registration and account use, automatically through your use of the platform, and occasionally from third-party verification or payment providers. Here is a clear breakdown of each category:

Lucky Game only processes your personal data when there is a valid legal reason to do so. The four legal bases we rely on are:

• Contract performance: To operate your player account, process deposits and withdrawals, settle bets, and provide the services you have signed up for. Without this data we simply cannot run your account.
• Legal obligation: To comply with anti-money laundering (AML) regulations, age verification requirements, and any requests from competent regulatory or law enforcement authorities. Lucky Game is legally required to maintain certain records and to report suspicious activity.
• Legitimate interests: To keep the platform secure, prevent fraud, improve our products, and — where you have not opted out — to send you relevant promotional communications about Lucky Game offers. We balance our legitimate interests against your rights at all times.
• Consent: For non-essential marketing communications (such as SMS promotions or push notifications) and for non-essential cookies. You can withdraw consent at any time from account settings.

Lucky Game uses your personal data for the following purposes — and only these purposes:

• Account management: Creating and maintaining your player account, verifying your identity, processing login and authentication, and managing your settings and preferences.
• Transaction processing: Handling PKR deposits via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, and Visa/Mastercard; processing withdrawals; crediting bonuses; and maintaining accurate financial records for your account.
• Bet settlement: Recording your bets, calculating outcomes, and crediting winnings to your balance correctly and on time.
• Responsible gaming: Monitoring gaming activity to identify patterns that may indicate harmful gambling behaviour, and to enforce responsible gaming tools you have set on your account. Lucky Game uses this data to look after your wellbeing — not to restrict normal, healthy gameplay.
• Fraud prevention and security: Detecting and investigating suspicious account activity, unauthorised access attempts, or financial fraud. This includes cross-referencing your data against known fraud databases where legally permitted.
• Customer support: Responding to your queries, resolving disputes, and improving our support quality using anonymised transcripts.
• Product improvement: Analysing aggregated, anonymised usage data to understand how players use Lucky Game and to make the platform better. This never involves sharing identifiable individual data.
• Marketing (with consent): Sending you personalised promotional offers, bonus alerts, and platform updates via email, SMS, or push notification — only where you have opted in, or where we have a legitimate interest in existing customer communications.

Lucky Game does not sell, rent, or trade your personal data to any third party. We share your data only where it is necessary to deliver our service, comply with legal requirements, or protect the security of the platform. Third parties who receive your data are contractually required to handle it securely and only for the purpose for which it was shared.

Categories of Third Parties

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, and card processing networks receive the minimum information necessary to process your deposits and withdrawals. They are bound by their own regulatory obligations regarding data security.
• Game providers: Ezugi, Pragmatic Play, and other certified game providers receive technical session data to deliver the game to your device and to record outcomes. They cannot access your financial or identity data beyond what is required to run the game session.
• Identity verification services: Third-party KYC providers receive your identity documents and CNIC data during the verification process. These providers are certified and operate under strict data protection agreements.
• Fraud and AML screening: Lucky Game uses certified fraud detection and anti-money-laundering screening tools that may cross-reference your data against regulatory watchlists as required by our operating licence.
• Regulatory and law enforcement: Where required by our operating licence or by lawful authority, Lucky Game will disclose player data to competent regulatory bodies or law enforcement agencies. We will not disclose more than is legally required.

Given that Lucky Game handles real PKR deposits and withdrawals, the way we manage financial data deserves its own section. When you deposit via Easypaisa, JazzCash, or any other supported method, the following applies:

• Full payment account numbers (e.g. your Easypaisa mobile number) are never stored in plaintext on Lucky Game's servers. Only a masked reference is retained.
• Transaction records — amounts, timestamps, and method type — are retained for a minimum of 5 years to comply with anti-money-laundering recordkeeping obligations.
• All payment data in transit is protected by 256-bit SSL/TLS encryption. Payment processing systems are isolated from general platform infrastructure.
• Lucky Game will only initiate withdrawals to a payment method that has been used by the account for deposits. This is a fraud-prevention measure that also protects you from having your funds misdirected.
• If you close your Lucky Game account, your remaining PKR balance will be returned to your verified payment method. Transaction records will be retained for the minimum legally required period even after account closure.

Data security is not a checkbox exercise at Lucky Game — it is an operational priority. The following technical and organisational measures are in place to protect your personal data at all times:

• 256-bit SSL/TLS encryption on all web pages, API communications, and data transmissions
• Encrypted storage for sensitive data fields including identity documents and payment references
• Role-based access controls — Lucky Game staff can only access the player data fields necessary for their specific role; no single employee has unrestricted access to all player data
• Two-factor authentication available for all player accounts and mandatory for Lucky Game administrative staff accounts
• Regular penetration testing conducted by independent security specialists to identify and remediate vulnerabilities before they can be exploited
• Incident response plan — in the event of a data breach, Lucky Game has a documented response procedure that includes notifying affected players within 72 hours of becoming aware of the incident
• Secure data deletion — data that is no longer needed and is not subject to legal retention requirements is securely deleted using certified data destruction processes

Lucky Game uses cookies and similar technologies to make the platform work properly and to improve your experience. Here is a breakdown of the cookie types in use and your control over each:

Cookies set by Lucky Game do not track your activity on other websites. We do not use third-party advertising cookies or cross-site tracking pixels. Cookie preferences can be updated at any time from your browser settings or from the cookie settings panel within your Lucky Game account.

Lucky Game retains your personal data only for as long as it is needed for the purposes described in this policy, or as required by law. The following retention periods apply:

• Active account data — retained for the duration of your account and for 5 years after account closure, in line with standard AML record-keeping requirements.
• Transaction and financial records — retained for a minimum of 5 years from the date of the transaction, as required by anti-money-laundering regulations.
• Gaming activity logs — retained for 5 years. Used for dispute resolution, responsible gaming monitoring, and regulatory compliance.
• Customer support communications — retained for 3 years after the last interaction. Used for quality assurance and dispute context.
• KYC documents — retained for 5 years after account closure or verification, whichever is later.
• Marketing preference records — retained for 3 years after you last opted in, to maintain an accurate record of consent.

When data reaches its retention limit and there is no legal reason to retain it further, Lucky Game securely deletes or anonymises it. Anonymised, aggregated data (with no individual identifiers) may be retained indefinitely for statistical and product improvement purposes.

You have meaningful rights over your personal data at Lucky Game. These rights are not buried in settings or difficult to exercise — they are a core part of how we operate.

Lucky Game may send you promotional communications about bonuses, new games, PSL betting specials, and other platform updates. Your control over these communications is straightforward and always available:

• Email marketing: You can opt out of promotional emails at any time by clicking "Unsubscribe" in any marketing email, or by toggling email marketing off in your Lucky Game account notification settings.
• SMS promotions: Reply STOP to any Lucky Game SMS to opt out immediately. You can also manage SMS preferences from account settings.
• Push notifications: Manage or disable push notifications from your device's notification settings or from within the Lucky Game platform settings.
• Transactional communications: Emails and SMS messages that are necessary for your account — deposit confirmations, withdrawal notifications, security alerts — cannot be opted out of as they are essential to operating your account safely.

Opting out of marketing communications will not affect your ability to play, deposit, withdraw, or access any feature of Lucky Game. We will process your opt-out within 48 hours, though you may receive one further communication in that window if it was already scheduled before your opt-out was processed.

Lucky Game is strictly an 18+ platform. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, you must not register, deposit, or use the Lucky Game platform under any circumstances.

During registration, all players confirm that they are 18 years of age or older. Lucky Game may request CNIC or equivalent identity documents to verify age. If we discover that personal data has been collected from a player who was under 18 at the time of registration, we will immediately close the account, return any deposited funds, and securely delete all associated personal data.

Lucky Game will update this Privacy Policy from time to time — for example, when we add new payment methods, introduce new product features, or when our legal obligations change. The version date shown at the top of this page always reflects the most recent update.

If we make material changes that significantly affect how your personal data is processed, we will notify registered players by email and via a prominent notice on the platform at least 7 days before the changes take effect. Continuing to use Lucky Game after the effective date of a policy update means you accept the revised policy.

For changes that are minor, administrative, or clarifying in nature, we may update this policy without advance notice, though the version date will always be updated to reflect any change.

For any question, concern, or request related to this Privacy Policy or to your personal data, please reach out through one of the following channels. Lucky Game's support team is available 24 hours a day, 7 days a week:

• Email: [email protected] — please write "Privacy" in the subject line for fastest routing
• Live Chat: Available at the bottom-right of every Lucky Game page — average response time under 5 minutes

For formal data subject requests (access, deletion, portability etc.), email is the preferred channel as it provides a written record for both parties. We respond to all privacy queries within 72 hours and complete formal data subject requests within 30 calendar days of receiving sufficient information to process them.

If you are not satisfied with how Lucky Game has handled a privacy concern, you have the right to raise the matter with the relevant data protection supervisory authority in the jurisdiction under which Lucky Game operates. We will provide details of the relevant authority upon request.