Privacy Policy

1.1   luck95 ("the Platform", "we", "us" or "our") takes the privacy and security of your personal data seriously. This Privacy Policy sets out our practices with respect to the collection, use, storage, sharing and protection of personal information obtained through your access to and use of luck95.cam.

1.2   The Platform is an English-language online gaming and sports betting service designed with Pakistani users in mind. While we aim to reflect locally familiar context — including PKR currency display, Pakistan cricket and PSL sports markets, and payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — we operate under an international gaming licence. Those payment and sports references are for contextual familiarity and do not constitute a formal partnership or endorsement by those entities.

1.3   By creating an Account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the practices described herein to the extent that consent is required as a legal basis for processing.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person — in other words, any data that could directly or indirectly identify you.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, the luck95 operator.
• "Data Processor" means any third party that processes Personal Data on behalf of the Data Controller under a written agreement.
• "KYC" means Know Your Customer — the identity and age verification process required to comply with anti-money laundering and responsible gambling obligations.
• "User" (or "you") means any individual who accesses the Platform or holds a registered Account at luck95.cam.
• "Sensitive Personal Data" means a subset of Personal Data warranting enhanced protection, including government-issued identification numbers (e.g., CNIC), financial account details and health information.

3.1   We collect Personal Data in the following categories, depending on how you interact with the Platform:

3.2   We do not intentionally collect Sensitive Personal Data beyond identity documents required for KYC and AML compliance. Where such documents are submitted, they are handled with enhanced security controls and access restrictions.

3.3   We do not collect data relating to racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, or health data, except where a health-related self-exclusion or responsible gambling request is made voluntarily by the User.

4.1   luck95 processes Personal Data on one or more of the following legal bases:

• Contractual necessity: Processing is required to fulfil our obligations under the Terms & Conditions — for example, operating your Account, processing deposits and withdrawals, and settling bets.
• Legal obligation: Processing is required to comply with applicable legal and regulatory requirements, including KYC/AML obligations under the Operator's gaming licence and anti-fraud controls.
• Legitimate interests: Processing is necessary for our legitimate business interests — including fraud prevention, platform security, responsible gambling monitoring and improving our services — where those interests are not overridden by your fundamental rights.
• Consent: Where we rely on your consent (for example, for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

4.2   We do not process your Personal Data for purposes that are incompatible with the purposes for which it was originally collected without first seeking your consent or establishing an alternative legal basis.

5.1   We use Personal Data collected through the Platform for the following purposes:

• Account management: Creating, maintaining and securing your Account; processing logins; managing password resets and account settings.
• Service delivery: Providing access to sports betting markets (including PSL, ICC and international cricket), live casino, slots, table games and other Platform features.
• Financial processing: Processing deposits and withdrawals via available payment rails; displaying transaction history in PKR; reconciling financial records.
• Identity and age verification: Conducting KYC checks to confirm your identity and confirm you meet the applicable minimum age requirement (18 or higher where the licence jurisdiction requires).
• AML and fraud prevention: Monitoring account activity for unusual patterns; conducting checks required under AML and counter-terrorism financing obligations; reporting to competent authorities where required.
• Responsible gambling: Monitoring for signs of problem gambling; enabling deposit limits, session controls and self-exclusion; delivering responsible gambling communications.
• Customer support: Responding to enquiries, complaints and technical issues submitted via [email protected] or the live chat function.
• Platform improvement: Analysing anonymised usage data to improve navigation, game loading performance and the overall user experience for Pakistani users across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.
• Marketing (with consent): Sending promotional communications, bonus offers and platform updates where you have opted in. You may unsubscribe at any time.
• Legal compliance: Meeting our obligations under the Operator's gaming licence, applicable data protection frameworks and any court orders or regulatory directions.

6.1   We do not sell your Personal Data. We do not transfer your Personal Data to third-party marketing networks, advertising brokers or data aggregators for commercial purposes.

6.2   We may share your Personal Data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual protections:

• Identity verification providers: Third-party KYC service providers that process your identity documents to verify your name, date of birth and document authenticity on our behalf.
• Payment processors: Financial technology providers that facilitate the processing of deposits and withdrawals. These processors handle transaction data necessary to execute the payment.
• Game content providers: Software studios that supply games to the Platform may receive non-identifiable session-level data for game fairness and performance monitoring.
• Fraud and AML screening services: Specialist providers that screen transactions and account activity against watch-lists and suspicious-activity indicators.
• Regulatory and law enforcement authorities: Where required by law, regulation, court order or gaming licence obligation, we may disclose Personal Data to competent authorities.
• Professional advisers: Lawyers, auditors and accountants who are bound by confidentiality obligations and process data only as necessary.

6.3   Any third party acting as a Data Processor on our behalf is required to process Personal Data only on our documented instructions and to implement appropriate technical and organisational security measures.

6.4   In the event of a corporate restructuring, merger, acquisition or sale of assets, Personal Data held by the Platform may be transferred to a successor entity. You will be notified of any such transfer and of any changes to this Privacy Policy that result from it.

7.1   The Platform uses cookies and similar tracking technologies to maintain session state, remember your preferences, analyse Platform usage and support security functions. Cookies are small text files stored on your device by your browser.

7.2   The following categories of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function — for example, maintaining your login session. These cannot be disabled without impairing core functionality.
• Functional cookies: Remember your preferences such as language and currency display (PKR). Disabling these may degrade your experience.
• Analytics cookies: Collect anonymised or pseudonymised data on how users navigate the Platform, helping us identify performance bottlenecks and improve the user journey.
• Security cookies: Used to detect and mitigate fraud, bot activity and unauthorised access attempts.

7.3   You can manage cookie preferences through your browser settings. Blocking all cookies may prevent certain Platform features from operating correctly. We do not use cookies to serve third-party behavioural advertising.

8.1   We retain Personal Data only for as long as is necessary for the purposes for which it was collected, subject to applicable legal and regulatory retention obligations.

8.2   General retention principles applied by luck95:

• Active Account data: Retained for the duration of your Account and for a period thereafter to meet post-closure compliance obligations.
• KYC and identity documents: Retained for the minimum period required under the Operator's gaming licence and applicable AML regulations, typically five years from the date of the last transaction or Account closure.
• Transaction records: Financial transaction data is retained for the period required under applicable law and licence conditions to support audit, AML and dispute resolution functions.
• Support communications: Retained for a reasonable period to support ongoing service quality and complaint resolution processes.
• Marketing data: Retained until you withdraw consent or for a reasonable period following your last interaction with marketing communications.

8.3   When retention periods expire or data is no longer required, Personal Data is securely deleted or anonymised in accordance with our internal data destruction procedures.

9.1   Depending on the applicable data protection law in your jurisdiction, you may hold some or all of the following rights in respect of your Personal Data. To exercise any of these rights, contact us at [email protected].

10.1   luck95 implements appropriate technical and organisational measures to protect your Personal Data against accidental loss, unauthorised access, disclosure, alteration or destruction. These measures include:

• SSL/TLS encryption for all data in transit between your browser and Platform servers;
• Encrypted storage of sensitive account and KYC data at rest;
• Role-based access controls limiting internal access to Personal Data to authorised personnel on a need-to-know basis;
• Regular review of security systems, vulnerability assessments and access logs;
• Secure document handling procedures for identity verification files.

10.2   In the event of a Personal Data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required, affected users in accordance with applicable breach notification obligations.

10.3   Your own account security also matters. You are responsible for maintaining the confidentiality of your login credentials and for notifying us promptly at [email protected] if you suspect any unauthorised access to your Account.

10.4   Important security reminder for Pakistani users: Never submit copies of your CNIC, passport or financial documents via WhatsApp, unencrypted email or third-party chat. Always use the official HTTPS verification portal within the luck95 Platform for document submission.

11.1   The Platform is strictly for adults aged 18 or older, or the higher minimum age required by the Operator's licence jurisdiction. We do not knowingly collect Personal Data from individuals below the applicable minimum age.

11.2   If we become aware that Personal Data has been submitted by a person below the minimum age, we will promptly suspend the associated Account, delete the data and refund any deposits made, subject to verification. Age verification is a core component of the KYC process for this reason.

11.3   If you are a parent or guardian and believe that a minor in your care has registered an Account or submitted Personal Data to the Platform, contact us immediately at [email protected].

12.1   As an internationally operating Platform, your Personal Data may be transferred to and processed in countries outside your country of residence, including countries whose data protection laws may differ from those of Pakistan or the Operator's licence jurisdiction.

12.2   Where such transfers occur, we ensure that appropriate safeguards are in place — such as contractual clauses that bind third-party recipients to data protection standards consistent with this Policy — before transferring your Personal Data internationally.

12.3   By using the Platform, you acknowledge that your Personal Data may be transferred internationally in connection with the provision of the Services described in these terms.

13.1   The Platform may reference or integrate with third-party services such as payment processors, game content providers and identity verification platforms. These third parties operate under their own privacy policies and are not governed by this document.

13.2   Payment method names referenced for contextual familiarity — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — represent independently operated services with their own data practices. Any data you provide directly to those services is subject to their own privacy policies and terms. luck95 does not control those third-party data practices.

13.3   We conduct due diligence on third-party processors and require Data Processing Agreements (or equivalent instruments) before engaging any third party to process Personal Data on our behalf.

14.1   We may update this Privacy Policy periodically to reflect changes in our data practices, legal requirements or Platform features. The "Last reviewed" date at the top of this page will be updated accordingly.

14.2   Where changes are material — for example, a change in the categories of data we collect or the purposes for which we use it — we will notify registered Users via the email address on file or by displaying a prominent notice on the Platform prior to the changes taking effect.

14.3   Your continued use of the Platform following notification of a material change constitutes your acknowledgement of the updated Policy. We encourage you to review this page periodically.

15.1   For any privacy-related query, rights request or complaint, please contact the luck95 support team:

• Privacy & Account Support: [email protected]
• General Enquiries: [email protected]

15.2   Please include your full name, Account username and a clear description of your request or concern. To process rights requests, we may need to verify your identity before acting on the request.

15.3   Support is available 24 hours a day, 7 days a week in English, with Urdu assistance available on request. Email addresses above are displayed as plain text only — they are not clickable links.