Privacy Policy — lucky6 Data Protection Commitment

lucky6 ("lucky6", "we", "us", "our") is the operator of the online casino and sports betting platform accessible at lucky6.club. For the purposes of this Privacy Policy, lucky6 is the data controller responsible for the personal information collected from players who register for and use the lucky6 Platform.

This Privacy Policy applies to all personal data collected by lucky6 in connection with the provision of its Services, including data collected via the lucky6 website, mobile web application, customer support interactions, email communications, and any other channels through which you interact with lucky6.

By registering for a lucky6 Account or using any lucky6 Service, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, you must not use the lucky6 Platform.

2.1 lucky6 collects the following categories of personal data from registered players and Platform visitors:

2.2 lucky6 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information, except where a Player voluntarily discloses such information in the context of a responsible gaming self-exclusion request, in which case such data is used solely to administer that request.

2.3 Where lucky6 is required by its KYC or AML obligations to collect documentary evidence of identity, the original document images submitted by Players are processed securely and retained only for the minimum period required by applicable regulations.

3.1 Data Provided Directly by You. The majority of personal data lucky6 holds about you is information you provide directly, including:

• Information entered during the Account registration process;
• Identity and address documents submitted for KYC verification;
• Payment method details entered when making deposits or requesting withdrawals;
• Communications sent to lucky6 customer support via live chat, email, or any other support channel;
• Responses provided in any surveys, feedback forms, or promotional participation forms on the Platform.

3.2 Data Collected Automatically. When you visit or interact with the lucky6 Platform, certain technical and usage data is collected automatically through cookies, server logs, and similar tracking technologies. This includes your IP address, device identifiers, browser type, pages visited, session duration, and clickstream data. Please refer to Section 7 of this Policy for full details on our use of cookies and tracking technologies.

3.3 Data Received from Third Parties. In limited circumstances, lucky6 may receive personal data about you from third-party sources, including:

• Identity verification and KYC service providers used to confirm the authenticity of documents you submit;
• Payment processors (such as JazzCash and EasyPaisa) who confirm the status of deposit and withdrawal transactions;
• Fraud prevention and AML screening databases against which your details may be checked as part of our regulatory compliance obligations;
• Analytics partners who provide aggregated and anonymised data about how visitors use the Platform.

4.1 lucky6 uses the personal data we collect for the following purposes:

• Account Creation and Management: To register your Account, verify your identity and age, maintain your Account preferences, and provide you with access to lucky6 Services;
• Transaction Processing: To process PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, card payments, and USDT, and to maintain accurate records of your transaction history;
• Legal and Regulatory Compliance: To fulfil our obligations under applicable anti-money laundering, counter-terrorist financing, and know-your-customer regulations, including reporting obligations to relevant authorities where required by law;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, bonus abuse, and other security threats to the Platform and its players;
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling, to administer deposit limits, cooling-off periods, and self-exclusion requests, and to fulfil our duty of care obligations to Players;
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Platform Improvement: To analyse usage patterns, diagnose technical issues, and improve the functionality, performance, and content of the lucky6 Platform;
• Marketing Communications: To send you promotional offers, bonus notifications, and product updates, subject to your marketing preferences and consent settings in your Account.

4.2 Marketing Opt-Out. If you no longer wish to receive marketing communications from lucky6, you may update your communication preferences at any time through your Account settings or by contacting customer support. Opting out of marketing communications will not affect the delivery of essential transactional and security communications relating to your Account.

5.1 lucky6 processes your personal data on the following legal grounds, depending on the specific purpose of processing:

• Contractual Necessity: Processing required to fulfil the contract between you and lucky6, including account management, transaction processing, and Service delivery;
• Legal Obligation: Processing required for lucky6 to comply with applicable laws and regulations, including KYC, AML, and responsible gaming obligations;
• Legitimate Interests: Processing carried out in pursuit of lucky6's legitimate business interests, including fraud prevention, Platform security, and service improvement, where such interests are not overridden by your privacy rights;
• Consent: Processing carried out on the basis of your freely given, specific, and informed consent, including the sending of direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of prior processing.

6.1 lucky6 does not share your personal data with third parties except in the following circumstances:

• Service Providers: lucky6 engages carefully selected third-party service providers to assist in the delivery of its Services. These include payment processors, KYC and identity verification providers, fraud screening services, cloud infrastructure providers, and customer support platform operators. All service providers are contractually bound to process your data only on lucky6's instructions and to maintain appropriate security standards;
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order, or regulatory direction, lucky6 may disclose personal data to governmental authorities, financial intelligence units, or law enforcement agencies. lucky6 will always seek to limit such disclosures to the minimum data necessary;
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of lucky6's business assets, your personal data may be transferred to the successor entity, subject to equivalent privacy protections being maintained;
• With Your Consent: In any other circumstance, lucky6 will share your data with third parties only where you have given explicit prior consent to such sharing.

6.2 lucky6 does not share your personal data with affiliates, partner casinos, or third-party gaming operators for the purposes of cross-marketing without your explicit consent.

7.1 The lucky6 Platform uses cookies and similar tracking technologies to deliver a functional, secure, and personalised user experience. Cookies are small text files stored on your device when you visit the Platform. They allow lucky6 to recognise your browser, remember your session preferences, and gather analytical data about Platform usage.

7.2 Types of Cookies Used. lucky6 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the operation of the Platform. These include session authentication cookies, security tokens, and load-balancing cookies. The Platform cannot function correctly without these cookies and they cannot be disabled;
• Functional Cookies: Used to remember your preferences, such as language settings, game lobby filters, and notification preferences, to provide a more personalised experience;
• Analytical Cookies: Used to collect anonymised data about how visitors use the Platform, including which pages are visited most frequently and where technical errors occur. This data helps lucky6 improve Platform performance;
• Security Cookies: Used to detect fraudulent activity, protect against account takeover, and identify unusual login patterns that may indicate unauthorised access.

7.3 Managing Cookies. You may control cookie settings through your web browser's privacy settings. Please note that disabling strictly necessary cookies will impair the functionality of the lucky6 Platform and may prevent you from logging in or completing transactions.

8.1 lucky6 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or for as long as is required by applicable legal, regulatory, or licensing obligations.

8.2 The following general retention periods apply to the main categories of data lucky6 holds:

• Account and Identity Data: Retained for the duration of your active Account plus a minimum of five (5) years following Account closure, to satisfy AML and regulatory record-keeping requirements;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with applicable financial regulations;
• KYC Verification Documents: Retained for the period specified by the applicable licensing authority's KYC record-keeping requirements, typically five (5) years;
• Customer Support Communications: Retained for three (3) years from the date of the last communication, to support dispute resolution;
• Technical and Usage Data (Logs): Retained for up to twelve (12) months in identifiable form, after which data is anonymised or deleted.

8.3 Where lucky6 is required to retain data beyond the periods above due to an ongoing legal proceeding, regulatory investigation, or dispute, the relevant data will be retained until the matter is fully resolved.

9.1 lucky6 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security programme includes the following controls:

• Encryption in Transit: All data transmitted between your device and the lucky6 Platform is encrypted using 256-bit TLS/SSL technology. This ensures that your login credentials, payment details, and personal information cannot be intercepted in transit;
• Encryption at Rest: Sensitive personal data stored in lucky6 databases, including identity documents and financial records, is encrypted at rest using industry-standard encryption protocols;
• Password Security: Player passwords are never stored in plain text. lucky6 uses strong one-way cryptographic hashing with salt to protect stored password data;
• Access Controls: Access to personal data within lucky6's systems is restricted to authorised personnel on a strict need-to-know basis. All staff with access to personal data undergo data protection training;
• Two-Factor Authentication: lucky6 offers 2FA via SMS OTP to all registered Players and strongly recommends its use to protect Account security;
• Continuous Monitoring: lucky6 employs automated security monitoring tools to detect and respond to suspicious activity, potential breaches, and unauthorised access attempts in real time.

9.2 Data Breach Response. In the event of a personal data breach that poses a risk to your rights and freedoms, lucky6 will notify the affected Players and relevant regulatory authorities as required by applicable law, within the timeframes specified by those laws. lucky6 maintains a documented incident response procedure for this purpose.

10.1 Subject to applicable law and the conditions set out below, you have the following rights with respect to your personal data held by lucky6:

10.2 Exercising Your Rights. To exercise any of the rights listed above, please contact the lucky6 Data Protection team at [email protected]. lucky6 will respond to all valid rights requests within 30 days. In complex cases, lucky6 may extend this period by a further 30 days, in which case you will be notified of the extension and the reason for it.

10.3 Please note that certain rights are subject to exceptions. For example, lucky6 cannot delete data that it is required to retain by law, and exercising the right to erasure or restriction may result in the closure of your Account where retention of the data is a condition of continued Service provision.

11.1 The lucky6 Platform is strictly intended for adults who are 21 years of age or older. lucky6 does not knowingly collect personal data from individuals under the age of 21. The Platform's registration process includes mandatory age declarations and is followed by KYC age verification before any withdrawal is permitted.

11.2 If lucky6 discovers or reasonably suspects that personal data has been submitted by or on behalf of an individual under 21, lucky6 will immediately suspend the relevant Account, initiate an investigation, delete the associated personal data to the extent permitted by applicable law, and report the matter to relevant authorities where appropriate.

11.3 If you are a parent or guardian and believe that a minor in your care has registered or attempted to register on the lucky6 Platform, please contact our support team immediately at [email protected] so that we can take swift action.

12.1 lucky6 operates on an international basis and some of the service providers and infrastructure partners we use may process your personal data in countries outside of Pakistan. Where personal data is transferred internationally, lucky6 takes appropriate steps to ensure that adequate protections are in place to safeguard your information.

12.2 International transfers of personal data by lucky6 are conducted under one or more of the following safeguards:

• Transfer to a country or organisation that is recognised as providing an adequate level of data protection;
• Use of standard contractual clauses or data processing agreements that impose equivalent data protection obligations on the receiving party;
• Where required and available, transfer on the basis of your explicit consent after being informed of the risks.

12.3 You may request further information about the specific safeguards applied to any international transfers of your personal data by contacting the lucky6 support team.

13.1 lucky6 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or Platform functionality. All changes will be published on this page with an updated "Last Updated" date at the top of the Policy.

13.2 Where changes are material — meaning they significantly affect your privacy rights or how lucky6 uses your personal data — lucky6 will provide advance notice via the email address associated with your Account, with a minimum of 14 days' notice before the changes take effect.

13.3 Your continued use of the lucky6 Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you must cease using the Platform and may request Account closure in accordance with the lucky6 Terms and Conditions.

If you have any questions, concerns, or requests regarding this Privacy Policy or lucky6's handling of your personal data, please contact our Data Protection team. We are committed to addressing all privacy-related enquiries promptly and transparently.

Data Protection Enquiries: [email protected]

Please include "Privacy Request" in your subject line so that your message is directed to the appropriate team. lucky6 aims to acknowledge all privacy enquiries within 48 hours and to provide a substantive response within 30 calendar days.

For information on the full terms governing your use of the lucky6 Platform, please refer to our Terms & Conditions. For information on our responsible gaming tools and resources, please visit our Responsible Gaming page.