Privacy Policy — lucky65

1. Introduction

lucky65 ("we", "us", "our") operates the online sports betting and casino platform accessible at lucky65.bet. We are committed to protecting the privacy and personal data of every individual who registers and plays on lucky65, including all Pakistani players across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, and beyond.

This Privacy Policy describes in detail:

• The categories of personal data we collect from lucky65 Members and visitors;
• The purposes for which that data is processed;
• The legal grounds on which we rely to process personal data;
• How long we retain data and the security measures we apply;
• The circumstances under which data may be shared with third parties;
• The rights available to you as a data subject and how to exercise them.

This Privacy Policy should be read alongside the lucky65 Terms and Conditions, which also form part of the agreement between you and lucky65. In the event of any conflict between this Privacy Policy and the Terms and Conditions on a privacy matter, this Privacy Policy shall prevail.

2. Data Controller

lucky65 is the data controller responsible for personal data collected and processed through the lucky65.bet platform. As data controller, lucky65 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out lawfully, fairly, and transparently.

For all privacy-related enquiries, requests, or complaints, you may contact the lucky65 Data Protection team through the following channels:

• Live Chat: Available directly on lucky65.bet, 24 hours a day, 7 days a week;
• Email: [email protected]

3. Personal Data We Collect

lucky65 collects personal data from Members and platform visitors across the following categories. The data collected depends on the nature of your interaction with lucky65 — not all categories apply equally to visitors who have not registered an account.

lucky65 does not intentionally collect sensitive personal data such as racial or ethnic origin, religious beliefs, political opinions, or biometric data beyond what is strictly required for identity verification purposes.

4. How We Collect Your Data

lucky65 collects personal data through the following methods:

• Directly from you — when you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact the support team, or update your account settings;
• Automatically via technology — when you visit or interact with lucky65.bet, our servers and analytics tools automatically record technical data such as your IP address, browser fingerprint, session activity, and device identifiers;
• From payment providers — when you initiate a transaction via JazzCash, EasyPaisa, HBL, UBL, or Meezan Bank, we receive transaction confirmation data from the relevant payment service provider;
• From identity verification services — when you submit KYC documents, we may use regulated third-party identity verification providers to validate the authenticity of the documents submitted;
• From fraud prevention services — lucky65 uses third-party fraud detection tools that may cross-reference your data against known fraud indicators, device fingerprint databases, and velocity checks.

5. How We Use Your Personal Data

lucky65 processes your personal data only for specified, explicit, and legitimate purposes. The primary purposes for which we use your data are as follows:

• Account management: Creating and maintaining your lucky65 account, processing login credentials, and managing account preferences;
• Identity verification: Fulfilling our KYC obligations to confirm that you are who you say you are and that you meet the eligibility requirements, including the 21+ age requirement;
• Transaction processing: Processing PKR deposits and withdrawals via your chosen payment method and maintaining accurate financial records;
• Service delivery: Making sports betting markets, casino games, live dealer tables, and promotional offers available to your account;
• Responsible gaming: Monitoring your gaming patterns to identify potential signs of problem gambling, applying deposit and loss limits you have set, and enforcing self-exclusion requests;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, multi-accounting, and other prohibited conduct;
• Legal compliance: Fulfilling our obligations under applicable gaming regulations, anti-money laundering requirements, and any lawful request from a competent authority;
• Customer support: Responding to your queries, complaints, and support requests via live chat or email;
• Marketing communications: Sending you promotional offers, bonus notifications, and product updates — but only where you have opted in to receive such communications and have not subsequently withdrawn that consent;
• Platform improvement: Analysing aggregated and anonymised usage data to improve the lucky65 platform, user experience, and game offerings.

6. Legal Basis for Processing

lucky65 processes your personal data on one or more of the following legal grounds, depending on the specific processing activity:

• Contractual necessity: Processing required to fulfil our contractual obligations to you as a registered Member — including account creation, transaction processing, and service delivery — is carried out on the basis that it is necessary for the performance of the contract between us;
• Legal obligation: Certain processing activities — particularly KYC identity verification, anti-money laundering checks, and record-keeping — are required by law and are carried out to comply with our regulatory obligations;
• Legitimate interests: lucky65 may process certain data where it is necessary for our legitimate business interests, provided those interests are not overridden by your privacy rights. This includes fraud prevention, security monitoring, and platform analytics;
• Consent: Where processing is not required by contract or law, we will seek your explicit consent — in particular for marketing communications and the use of non-essential cookies. You may withdraw consent at any time.

7. Sharing Your Personal Data

lucky65 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Your data may be shared in the following limited circumstances:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank receive the transaction data necessary to process your deposits and withdrawals. These providers process your data as independent data controllers under their own privacy policies;
• Identity verification partners: Regulated KYC and document verification providers may process copies of your identification documents solely for the purpose of confirming your identity and age;
• Fraud prevention services: Third-party fraud detection providers may receive technical data such as IP address, device fingerprint, and transaction patterns to assist in identifying and preventing fraudulent activity;
• Game software providers: Third-party casino game suppliers whose games are accessible via the lucky65 platform may receive the minimum data necessary to operate game sessions, including your account identifier and wager information;
• Legal and regulatory authorities: lucky65 may disclose personal data to regulatory bodies, law enforcement agencies, or courts where required to do so by a lawful order, court direction, or applicable regulation;
• Professional advisers: Lawyers, auditors, and accountants engaged by lucky65 may access personal data where strictly necessary for the provision of professional services, subject to confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or sale of all or part of the lucky65 business, personal data held by lucky65 may be transferred to the acquiring entity, subject to equivalent privacy protections.

8. Data Retention

lucky65 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The following general retention periods apply:

• Active account data: Retained for the duration of the active account relationship plus a minimum of five (5) years following account closure, in line with standard gaming regulatory requirements;
• KYC and identity documents: Retained for a minimum of five (5) years following account closure or the completion of the transaction to which they relate, whichever is later;
• Financial transaction records: Retained for a minimum of five (5) years following the transaction date, in compliance with applicable anti-money laundering regulations;
• Support communications: Retained for three (3) years following the resolution of the relevant support interaction;
• Marketing preference data: Retained until you withdraw your marketing consent, at which point it will be anonymised or deleted within 30 days;
• Technical and analytics data: Aggregated and anonymised data may be retained indefinitely; identifiable technical data (e.g., IP logs) is retained for up to 12 months.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that renders it permanently irrecoverable.

9. Security Measures

lucky65 takes the security of your personal data seriously and implements a layered set of technical and organisational security measures designed to protect your data against unauthorised access, loss, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and lucky65.bet is encrypted using industry-standard 256-bit SSL/TLS encryption;
• Access controls: Access to personal data within lucky65 is restricted on a strict need-to-know basis. Staff are granted the minimum level of data access required to perform their role;
• Password security: Account passwords are hashed using industry-standard cryptographic algorithms. lucky65 never stores passwords in plain text;
• Intrusion detection: lucky65 employs automated intrusion detection and monitoring systems to identify and respond to suspicious access patterns in real time;
• Penetration testing: The lucky65 platform undergoes regular third-party security assessments, including penetration testing, to identify and remediate vulnerabilities;
• Staff training: All lucky65 personnel who handle personal data receive mandatory data protection and information security training.

10. Cookies & Tracking Technologies

lucky65 uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse how the site is used. The categories of cookies we use are as follows:

• Strictly necessary cookies: Essential for the operation of lucky65.bet. These cookies enable core functions such as session authentication, account login state, and security protections. They cannot be disabled without breaking core platform functionality;
• Functional cookies: Used to remember your preferences and settings — such as your preferred language, odds format, and display settings — so you do not have to re-enter them on each visit;
• Analytics cookies: Used to collect aggregated, anonymised data about how visitors interact with lucky65.bet. This data helps us understand which features are most popular and where the platform can be improved. These cookies are deployed only with your consent;
• Fraud prevention cookies: Used to record device identifiers and session data that assist our fraud detection systems in identifying suspicious activity and protecting your account.

You may manage your cookie preferences through your browser settings. Please note that disabling cookies beyond the strictly necessary category may affect the functionality of lucky65.bet. Detailed cookie management instructions vary by browser — please refer to your browser's help documentation for specific guidance.

11. Your Data Subject Rights

As a data subject, you have the following rights in relation to the personal data held about you by lucky65. Requests to exercise any of these rights should be submitted to the lucky65 Data Protection team via live chat or email.