luck44 Privacy Policy

1 Who We Are

luck44 ("we", "us", "our") operates the online gaming platform accessible at https://luck44.bio (the "Platform"). luck44 is the data controller responsible for your personal information collected through the Platform. We hold an international gaming license and are committed to operating in full compliance with applicable data protection laws and our licensing obligations.

This Privacy Policy applies to all personal data collected from players and visitors located in Pakistan and elsewhere who access or use the luck44 Platform, including through any mobile or desktop interface. It covers all services offered by luck44, including sports betting, live casino, slots, and any promotional or support interactions.

For any privacy-related queries, you may contact our Data Protection team directly at the contact details provided in Section 15 of this Policy.

2 Personal Data We Collect

luck44 collects the following categories of personal data from players and Platform visitors. We only collect data that is necessary for the purposes described in this Policy.

2.1 Identity & Contact Data

• Full name as it appears on your CNIC or passport;
• Date of birth (used for age verification — players must be 21 years or older);
• Pakistani CNIC number or passport number;
• Residential address (city, province, postal code);
• Email address;
• Mobile phone number (used for account verification and security).

2.2 Financial Data

• JazzCash or EasyPaisa mobile wallet numbers;
• HBL, UBL, or Meezan Bank account details (where provided for bank transfers);
• USDT wallet addresses (where applicable);
• Transaction history including deposits, withdrawals, wagers placed, and winnings received;
• Source of funds documentation where required under Anti-Money Laundering (AML) obligations.

2.3 Account & Gaming Data

• Your luck44 username and account ID;
• Login timestamps and session duration records;
• Betting and gaming history, including games played, bet amounts, outcomes, and bonus usage;
• Responsible gaming settings and limit preferences applied to your account;
• Customer support and live chat interaction records.

2.4 Technical & Usage Data

• IP address and approximate geolocation data;
• Device type, operating system, and browser information;
• Pages visited on the Platform and navigation patterns;
• Referral source (how you arrived at luck44);
• Crash reports and error logs used for Platform maintenance.

2.5 Verification Documents

• Scanned or photographed copies of your CNIC, passport, or other government-issued ID;
• Proof of address documents (utility bills, bank statements);
• Selfie or liveness-check photographs where required for enhanced KYC verification.

3 How We Collect Your Data

luck44 collects personal data through the following means:

• Direct submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting support, or participating in promotions;
• Automated technology: Data collected automatically as you browse and interact with the Platform, including via cookies, session tracking tools, and server logs;
• Third-party service providers: Identity verification and KYC data obtained through our authorised verification partners; payment transaction data received from JazzCash, EasyPaisa, and banking partners;
• Fraud prevention services: Risk-scoring and device fingerprint data from third-party fraud detection providers used to protect the integrity of the Platform;
• Publicly available sources: Sanctions lists, politically exposed persons (PEP) databases, and adverse media sources consulted as part of our AML compliance obligations.

4 Why We Use Your Personal Data

The table below summarises the primary purposes for which luck44 uses your personal data and the corresponding legal basis for each processing activity.

5 Legal Basis for Processing

luck44 processes your personal data only where a valid legal basis exists under applicable data protection law. The four primary legal bases we rely upon are:

• Contractual necessity: Processing required to perform our contractual obligations to you — including account management, payment processing, and delivering gaming services — falls under this basis.
• Legal obligation: Certain processing activities are mandated by our international gaming license and applicable anti-money laundering, fraud prevention, and responsible gaming regulations. We have no discretion to refuse this processing.
• Legitimate interests: Where luck44 has a genuine business interest in processing your data (such as Platform security, fraud prevention, or service improvement) that does not override your fundamental rights and freedoms, we rely on this basis. We conduct a balancing test before relying on legitimate interests.
• Consent: Where we rely on your consent (for example, for marketing communications or optional cookies), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

luck44 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the circumstances described below, and only to the minimum extent necessary.

6.1 Service Providers

We engage trusted third-party service providers to assist in delivering the luck44 Platform, including:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT processing partners;
• Identity verification and KYC providers;
• Fraud detection and AML screening platforms;
• Cloud hosting and data storage infrastructure providers;
• Customer support software providers;
• Analytics platforms used to improve Platform performance.

All service providers are bound by contractual data protection obligations and are prohibited from using your data for any purpose other than providing services to luck44.

6.2 Regulatory & Legal Disclosure

We may be required to disclose your personal data to regulatory bodies, law enforcement agencies, gaming license supervisory authorities, or courts of competent jurisdiction where we are legally obligated to do so. This includes disclosures required under AML and counter-terrorism financing regulations.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of luck44's business or assets, your personal data may be transferred as part of that transaction. You will be notified of any such transfer and any material change in how your data is processed.

7 Data Retention

luck44 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and our gaming license obligations. The following retention periods apply:

• Active account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required under AML and gaming license record-keeping obligations;
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction;
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the transaction to which they relate;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing consent records: Retained until you withdraw consent, plus one (1) year for audit purposes;
• Technical and usage logs: Typically retained for twelve (12) months for security and performance monitoring purposes.

Upon expiry of the applicable retention period, your data will be securely deleted or anonymised so that it can no longer be associated with you as an individual.

8 Cookies & Tracking Technologies

luck44 uses cookies and similar tracking technologies to provide, secure, and improve the Platform. A "cookie" is a small text file stored on your device when you visit a website. We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled. They include session management, security, and load-balancing cookies.
• Functional cookies: Remember your preferences (such as language settings and responsible gaming limits you have configured) to provide a personalised experience.
• Analytics cookies: Help us understand how players navigate the Platform so we can improve it. Data collected is aggregated and anonymised where possible.
• Marketing cookies: Used to deliver promotions relevant to your gaming interests. These are only placed with your explicit consent.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled without preventing core Platform features from operating.

9 Data Security

luck44 implements robust technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the luck44 Platform is encrypted using TLS (Transport Layer Security) protocols. Sensitive data at rest is encrypted using industry-standard AES-256 encryption;
• Access controls: Access to personal data is restricted on a strict need-to-know basis. All staff with access to player data undergo regular data protection training;
• Two-factor authentication (2FA): Available on all luck44 accounts and strongly recommended for all players;
• Penetration testing: The Platform undergoes regular security assessments and vulnerability testing by independent cybersecurity professionals;
• Incident response: luck44 maintains a documented data breach response procedure. In the event of a breach affecting your data, we will notify you and the relevant authorities within the timeframes required by applicable law.

While luck44 takes all reasonable precautions to secure your data, no digital platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

10 International Data Transfers

luck44 operates under an international gaming license and may engage service providers located outside Pakistan. As a result, your personal data may be transferred to, processed in, or stored in countries other than Pakistan.

Where such transfers occur, luck44 ensures that appropriate safeguards are in place to protect your data to an equivalent standard as required under our licensing obligations. These safeguards may include:

• Standard contractual clauses incorporated into agreements with service providers;
• Transfers to jurisdictions recognised as providing an adequate level of data protection;
• Binding corporate rules where applicable within our group of companies.

If you would like further information about the specific safeguards in place for international data transfers, please contact us using the details in Section 15.

11 Your Data Protection Rights

As a luck44 player, you hold the following rights in respect of your personal data. To exercise any of these rights, please contact our support team using the details in Section 15. We will respond to all valid requests within 30 days of receipt.

• Right of access: You have the right to request a copy of the personal data luck44 holds about you, together with information about how it is processed.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to erasure: In certain circumstances, you may request the deletion of your personal data. This right is subject to our legal obligations — for example, we cannot erase transaction records that we are legally required to retain.
• Right to restrict processing: You may request that we temporarily stop processing your data while a dispute about its accuracy or our use of it is resolved.
• Right to data portability: Where processing is based on your consent or a contract with you, you may request that we provide your data in a structured, machine-readable format.
• Right to object: You may object to processing based on legitimate interests, including direct marketing. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing.

12 Children & Minors

The luck44 Platform is strictly prohibited to persons under the age of 21. We do not knowingly collect personal data from anyone under 21 years of age. Our registration process includes age verification steps designed to prevent underage access.

If we discover or receive notification that personal data has been collected from an individual under 21, we will take immediate steps to delete that data, close the associated account, and return any deposited funds (net of any winnings, which shall be forfeited). Where required, the matter may be escalated to the relevant licensing authority.

If you are a parent or guardian and believe that a minor has created a luck44 account, please contact us immediately at the details provided in Section 15 so that we can investigate and act promptly.

13 Marketing Communications

luck44 may send you promotional communications about bonuses, new games, PSL cricket betting offers, slot tournaments, and other Platform news via email or SMS, but only where you have given your explicit consent to receive such communications at the time of registration or subsequently through your account settings.

You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link included in any luck44 marketing email;
• Updating your communication preferences within your luck44 account settings;
• Contacting our support team directly and requesting removal from all marketing lists.

Please allow up to 5 business days for opt-out requests to take effect. Opting out of marketing will not affect service-related communications such as deposit confirmations, withdrawal notifications, account security alerts, and KYC requests, which are sent as part of our contractual obligations to you.

14 Amendments to This Policy

luck44 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. The date of the most recent revision is always displayed at the top of this document.

Where changes are material — for example, where we introduce a new category of data processing or change the basis on which we rely — we will notify you by email or via a prominent on-Platform notice prior to the changes taking effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy.

We recommend that you review this Privacy Policy periodically. The most current version is always accessible at https://luck44.bio/privacy-policy.

15 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data protection rights, or have a concern about how luck44 handles your personal data, please contact our support team through the following channels:

• Support Email: [email protected]
• Live Chat: Available 24/7 directly from the luck44 Platform — average response time under 90 seconds

We take all privacy-related enquiries seriously and will acknowledge your request within 48 hours. We aim to resolve all complaints within 14 business days. If you remain dissatisfied with our response, you may have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction, or with the regulatory body overseeing our gaming license.

Our support team serves players across Karachi, Lahore, Islamabad, Faisalabad, and all cities across Pakistan, around the clock.