Privacy Policy — luka55

luka55 ("we", "us", "our") operates the online gaming and entertainment platform available at luka55.cam. We are committed to protecting the personal data of every individual who visits, registers with, or uses our Platform, including our players based in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar, and across Pakistan.

This Privacy Policy explains what personal data we collect about you, the purposes for which we process it, how long we retain it, with whom we share it, and the rights available to you in relation to your personal data. It applies to all data processing activities carried out in connection with:

• Your use of the luka55 website and any associated mobile-optimised applications;
• The registration and maintenance of a luka55 account;
• Any transactions, wagers or interactions you make on our Platform;
• Communications between you and luka55 via any channel.

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, which together form the complete framework governing your relationship with luka55.

luka55 does not claim to be regulated or approved by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, or any Pakistani financial institution. This Privacy Policy is governed by the data protection laws of the jurisdiction in which luka55 holds its operating licence. Pakistani players access the Platform subject to their own local legal obligations.

In this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information that identifies or can reasonably identify a living individual, directly or indirectly, including name, email address, device identifiers, and location data.
• "Processing" means any operation performed on Personal Data — including collection, storage, use, disclosure, erasure or destruction — whether by automated means or otherwise.
• "Data Controller" means luka55, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of luka55 under a written data processing agreement.
• "Cookie" means a small text file stored on your device by the Platform for the purpose of session management, analytics, or preference storage.
• "KYC" means Know Your Customer — the identity and address verification process required by applicable compliance and anti-money-laundering obligations.
• "Platform" means the luka55 website, mobile-optimised site, any associated applications, and all related services accessible at luka55.cam.
• "Player" means any registered individual who holds a luka55 account and uses the Platform's gaming or information services.
• "Sensitive Data" means a special category of Personal Data attracting heightened protection, including health data, biometric data, or data revealing religious or political beliefs.

luka55 collects the following categories of personal data, depending on how you interact with our Platform:

3.1 Registration & Account Data

• Full legal name;
• Date of birth and age verification data;
• Email address;
• Mobile phone number;
• Residential address (including city — e.g., Karachi, Lahore, Islamabad);
• Username and encrypted password;
• Preferred currency (PKR).

3.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents (e.g., CNIC, passport, driver's licence);
• Proof of address documentation;
• Selfie or liveness-check images used for biometric identity matching (where applicable);
• Source-of-funds documentation where required by compliance procedures.

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts in PKR;
• Payment method references (e.g., masked account or wallet identifiers);
• Transaction timestamps and status records;
• Wagering history, game records, and account balance history.

3.4 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, page views, and click-path data;
• Login timestamps and Platform activity logs.

3.5 Communications Data

• Content of messages sent to luka55 support via live chat, email, or help centre;
• Survey responses and feedback submissions;
• Records of responsible gambling interactions and self-exclusion requests.

We collect personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or respond to a survey;
• Automatically — through cookies, session tracking, server logs, and analytics tools as you navigate the Platform;
• From third-party verification providers — KYC and anti-fraud service providers may supply additional verification data to supplement the information you provide;
• From payment processors — transaction confirmation and status data is received from payment partners when processing PKR deposits or withdrawals;
• From publicly available sources — in limited circumstances, where required for compliance or fraud prevention purposes, we may consult publicly available records.

luka55 processes your personal data only where a valid legal basis exists under applicable data protection law. The primary legal bases we rely upon are:

Where we rely on your consent as the legal basis for processing (such as for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

luka55 uses your personal data for the following purposes:

6.1 Platform Operation

To create and manage your account, process your wagers and transactions in PKR, verify your eligibility to use the Platform, and provide access to sports betting markets (including Pakistan cricket, PSL T20 and ICC tournaments), live casino, slots, and table games.

6.2 Compliance & Legal Obligations

To complete KYC verification, carry out anti-money-laundering checks, maintain transaction records as required by applicable law, respond to lawful requests from regulatory or law enforcement authorities, and comply with responsible gambling obligations.

6.3 Responsible Gambling

To monitor Player activity for indicators of problem gambling behaviour, enforce self-exclusion requests, apply deposit and loss limits, and contact Players where our responsible gambling procedures require us to do so.

6.4 Security & Fraud Prevention

To detect and prevent fraud, bonus abuse, money laundering, collusion, and other prohibited conduct; to protect the integrity of the Platform and the security of all Players' accounts.

6.5 Communications

To send transactional communications (account confirmations, deposit/withdrawal notifications, security alerts) and, where you have opted in, marketing communications about promotions, new features, and platform updates.

6.6 Platform Improvement

To analyse usage patterns, conduct A/B testing, troubleshoot technical issues, and improve the overall Platform experience for our players across Pakistan.

luka55 does not sell, rent or trade your personal data to third parties. We share your data only in the following limited circumstances:

• KYC & Identity Verification Providers: Third-party service providers who perform identity and document verification checks on our behalf under binding data processing agreements;
• Payment Processors: Financial technology partners who process PKR transactions — transaction data is shared to the minimum extent necessary to complete the payment;
• Fraud & Security Services: Specialist providers who assist with fraud detection, IP geolocation, and platform security monitoring;
• Customer Support Platforms: Third-party helpdesk and live chat software providers used to deliver support services to Players;
• Analytics Providers: Platform usage analytics services that help us understand aggregate player behaviour and improve the Platform;
• Legal & Regulatory Authorities: Where we are required by law, court order, or regulatory direction to disclose personal data to a competent authority;
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of luka55's business, personal data may be transferred to the acquiring entity subject to equivalent privacy protections.

All third-party Data Processors engaged by luka55 are required to process personal data only on our documented instructions, maintain appropriate security measures, and comply with applicable data protection obligations.

luka55 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyse how Players interact with our content. The categories of cookies we use are as follows:

You may manage cookie preferences through your browser settings or through any cookie consent tool presented on the Platform. Disabling strictly necessary cookies may impair your ability to use the Platform. For full details of the specific cookies in use and how to manage them, please refer to our Cookie Settings panel within the Platform.

luka55 retains your personal data for as long as:

• Your account remains active and you continue to use the Platform;
• Retention is necessary to fulfil the purposes described in this Privacy Policy;
• Retention is required by applicable legal, regulatory, or licensing obligations.

Upon account closure, luka55 will retain your personal data for a minimum additional period as required by our legal obligations — typically five (5) years for financial transaction records and KYC documentation — after which data that is no longer required will be securely deleted or anonymised.

Backup copies of data may be retained for a short additional period beyond the primary retention period solely for disaster recovery purposes, and will not be processed for any other purpose during that time.

luka55 takes the security of your personal data seriously and maintains a comprehensive set of technical and organisational security measures, including:

• Encryption: All data in transit between your device and luka55 servers is encrypted using TLS (Transport Layer Security). Sensitive data fields at rest are encrypted using AES-256 or equivalent standards;
• Access Controls: Personal data access is restricted to authorised luka55 personnel and Data Processors on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication;
• Penetration Testing: The Platform undergoes regular security assessments and penetration testing by qualified independent security professionals;
• Incident Response: luka55 maintains a documented data breach response procedure, including timely notification of affected Players and relevant authorities where required by applicable law;
• Employee Training: All luka55 staff with access to personal data receive regular training on data protection obligations and security best practices.

Notwithstanding these measures, no electronic transmission over the internet or method of electronic storage is 100% secure. luka55 cannot guarantee absolute security and encourages you to protect your account credentials and notify us immediately of any suspected unauthorised access.

luka55 operates internationally and may transfer your personal data to third-party service providers and Data Processors located in countries outside Pakistan and outside the jurisdiction in which luka55 is licensed. Such transfers may occur in connection with KYC verification services, payment processing, cloud infrastructure, and customer support platforms.

Where personal data is transferred internationally, luka55 ensures that appropriate safeguards are in place, which may include:

• Standard contractual clauses approved by the relevant data protection authority;
• Binding corporate rules where applicable within a corporate group;
• Adequacy decisions recognising that the destination country provides an equivalent level of data protection.

You may request further information about the specific safeguards applicable to any international transfer by contacting us at the details set out in Section 16 of this policy.

Subject to applicable data protection law, you hold the following rights in relation to your personal data processed by luka55:

To exercise any of these rights, please contact luka55 as set out in Section 16. We will respond to verified requests within 30 days. Where a request is complex or numerous, this period may be extended by a further 60 days with prior notice to you.

luka55 will not charge a fee for the reasonable exercise of your data rights. We may, however, charge a reasonable administrative fee or decline to act on requests that are manifestly unfounded or excessive.

The luka55 Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the operator's licence jurisdiction. luka55 does not knowingly collect personal data from individuals under the applicable minimum age.

Our registration process incorporates age verification steps designed to prevent underage access. Where luka55 discovers or has reason to believe that personal data belonging to a minor has been collected, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered an account or submitted personal data to luka55, please contact us immediately at the details in Section 16 so that we can investigate and take appropriate action.

The luka55 Platform may contain references to third-party content, game providers, or sports data services. Where the Platform links to or embeds content from third-party sources, those third parties operate their own independent privacy policies and data practices, over which luka55 has no control.

luka55 is not responsible for the privacy practices of any third-party services accessed through or referenced on the Platform. We encourage you to review the privacy policy of any third-party service you interact with independently of luka55.

luka55 reserves the right to update or revise this Privacy Policy at any time. Where a material change is made to the way we process your personal data, we will notify you by email to the address associated with your account or by displaying a prominent notice on the Platform, with a minimum of seven (7) days' notice before the change takes effect.

The "Last Updated" date displayed at the top of this page always reflects the date of the most recent revision. We recommend reviewing this Privacy Policy periodically to remain informed of how we protect your data.

Your continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated Privacy Policy. If you do not agree with the revised policy, you must cease using the Platform and may request closure of your account.

If you wish to exercise any of your data rights, raise a privacy concern, or ask a question about this Privacy Policy, please contact luka55 through the following channels:

• Live Chat: Available 24 /7 via the Help Centre on the Platform;
• Email: [email protected]

Please include your registered account username and a clear description of your request or concern so that we can verify your identity and respond efficiently. We aim to acknowledge all privacy-related requests within 5 business days and resolve them within 30 days.