Privacy Policy

This Privacy Policy ("Policy") describes how luck50, operating at https://luck50.cam ("Platform", "we", "us", "our"), collects, uses, stores and protects the personal data of individuals ("User", "you", "your") who access, register with or otherwise interact with the luck50 platform.

luck50 is an English-language online gaming information platform focused on the Pakistan market. This Policy applies to all users of the Platform, including visitors, registered account holders and any individual who contacts our support team, regardless of their geographic location.

By using the luck50 platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree, you must discontinue use of the Platform immediately.

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

• "Personal Data" — any information that directly or indirectly identifies a natural person, including name, date of birth, email address, phone number, residential address, IP address, device identifiers and financial account references.
• "Processing" — any operation performed on personal data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction, whether by automated or manual means.
• "Data Controller" — the entity that determines the purposes and means of processing personal data. luck50 acts as the Data Controller for data collected through this Platform.
• "Data Processor" — a third party that processes personal data on behalf of the Data Controller under written instructions and contractual data protection obligations.
• "Consent" — a freely given, specific, informed and unambiguous indication of a User's agreement to the processing of their personal data for a stated purpose.
• "KYC Data" — identity and age verification documentation, including CNIC, passport, proof of address and liveness check data, collected for regulatory compliance purposes.
• "Cookie" — a small text file placed on a User's device by the Platform for functional, analytical or security purposes.

luck50 is the Data Controller in respect of all personal data collected through the Platform. As Data Controller, luck50 determines the lawful purposes for which personal data is collected and processed, the categories of data collected, the retention periods applied, and the third-party processors to whom data may be disclosed.

For any queries relating to this Policy, the exercise of your data rights, or to raise a concern about how your personal data has been handled, please contact our Data Protection team using the contact details set out in Section 17 of this Policy.

luck50 collects personal data through several means: directly from you during registration and account use; automatically through cookies and server logs during your visit to the Platform; and from third-party verification and payment service providers during KYC and transaction processing.

Data Category	Examples	Collection Method
Registration Data	Full name, date of birth, email address, mobile number, residential city (e.g. Karachi, Lahore, Islamabad)	Provided by User at registration
Identity (KYC) Data	CNIC number, passport details, proof of address document, selfie/liveness image	Uploaded via secure verification portal
Financial Data	Payment method references (Easypaisa wallet ID, bank account reference, Raast ID), transaction history, deposit/withdrawal amounts in PKR	Provided during transaction processing
Usage Data	Login timestamps, pages visited, game sessions, betting history, session duration, device type	Automatically collected via server logs and session tracking
Technical Data	IP address, browser type and version, device identifiers, operating system, geolocation (country/city level)	Automatically collected via cookies and server logs
Communications Data	Support chat transcripts, email correspondence, complaint records	Collected when you contact support
Responsible Gambling Data	Deposit limit settings, self-exclusion status, reality check preferences	Provided by User via account settings; recorded by Platform

luck50 processes personal data only where a lawful basis for doing so exists. The primary legal bases applicable to our processing activities are as follows:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you — including account management, transaction processing and delivery of gaming services — is carried out on the basis of contractual necessity.
• Legal Obligation: KYC identity verification, AML checks, tax reporting and regulatory compliance activities are carried out on the basis of legal obligation under applicable regulations.
• Legitimate Interests: Platform security, fraud detection, responsible gambling monitoring and service improvement analytics are carried out on the basis of luck50's legitimate interests, balanced against your rights and interests.
• Consent: Non-essential processing, including certain categories of analytics cookies and promotional communications, is carried out on the basis of your freely given consent, which you may withdraw at any time.

luck50 uses personal data collected from Pakistani users and others for the following purposes, each of which corresponds to a lawful basis identified in Section 5:

luck50 does not sell, rent or trade your personal data to third parties for marketing or commercial purposes. Personal data may be shared with the following categories of recipients under strict contractual data protection obligations:

• KYC & Identity Verification Providers: Third-party identity verification services that process CNIC, passport and liveness data to confirm your identity and age. These providers act as Data Processors under our instructions.
• Payment Processors: Transaction processing services that facilitate deposits and withdrawals. Payment method references — including those relating to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are shared with the relevant payment processor only to the extent necessary to complete your transaction.
• Game & Platform Technology Providers: Software and infrastructure providers that deliver gaming functionality. Access to personal data is limited to what is technically required for service delivery.
• Regulatory Authorities & Law Enforcement: Where required by applicable law, court order or regulatory instruction, luck50 may be legally obligated to disclose personal data to the relevant authority without prior notice to the User.
• Fraud Prevention Networks: Industry fraud prevention databases to which we may contribute and query data for the purposes of detecting and preventing fraudulent account activity and payment fraud.

Identity documents submitted for KYC purposes — including CNIC, passport, proof of address and selfie/liveness images — are treated as sensitive personal data and are subject to enhanced security controls. These documents are processed exclusively through our secure HTTPS verification portal and are never accepted via unencrypted email, social media or chat applications.

KYC data is shared only with our authorised identity verification partner under a binding Data Processing Agreement. Verification results — pass, fail or refer — are communicated back to luck50 in a form that minimises ongoing exposure of the original document data.

Payment processing on luck50 is handled by third-party payment processors. luck50 does not store full card numbers, CVV codes or equivalent sensitive payment authentication data on its own servers. Where a payment method reference — such as a mobile wallet ID associated with Easypaisa or JazzCash, or a bank account reference associated with HBL, UBL, Meezan Bank or Bank Alfalah — is retained for withdrawal processing purposes, it is stored in encrypted form and accessible only to authorised personnel for transaction management purposes.

All PKR-denominated transactions are processed in accordance with the operator's current cashier configuration and the applicable payment processor's own security standards. Users are advised to review the privacy policies of their chosen payment provider separately.

luck50 uses cookies and similar tracking technologies to operate the Platform effectively. The following categories of cookies may be set when you visit luck50.cam:

Cookie Type	Purpose	Consent Required
Strictly Necessary	Session management, login state, security tokens, CSRF protection	No — essential to Platform operation
Functional	User preferences (language, currency display, responsible gambling settings)	No — required for core functionality
Analytics	Aggregated usage statistics, page performance monitoring, error tracking	Yes — may be declined
Security / Fraud Detection	Device fingerprinting, bot detection, suspicious behaviour flags	No — legitimate interest basis

luck50 does not set third-party advertising or behavioural tracking cookies. You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect Platform functionality and may prevent you from logging in or using core account features.

luck50 retains personal data for no longer than is necessary for the purposes for which it was collected, taking into account our legal, regulatory and operational obligations. The following indicative retention periods apply:

• Account & Registration Data: Retained for the duration of the account relationship and for a period of up to five (5) years following account closure, to meet AML, fraud investigation and dispute resolution obligations.
• KYC & Identity Documents: Retained for the period required by applicable AML regulations in the operator's license jurisdiction, typically five (5) years from the date of verification or account closure, whichever is later.
• Transaction Records: Retained for a minimum of five (5) years to comply with financial record-keeping and AML obligations.
• Usage & Technical Data: Retained for up to twenty-four (24) months from collection for analytics and security purposes, after which it is anonymised or deleted.
• Support Communications: Retained for up to three (3) years from the date of the most recent communication for quality assurance and dispute resolution purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with our data disposal procedures.

Given that luck50 operates as an online platform serving users in Pakistan and engages third-party service providers that may be based in jurisdictions outside Pakistan, your personal data may be transferred to and processed in countries other than Pakistan.

Where such transfers occur, luck50 takes reasonable steps to ensure that adequate safeguards are in place to protect your personal data, including: binding contractual clauses with processors; transfers only to jurisdictions that provide an adequate level of data protection as assessed by the operator; and application of encryption and access controls during transfer.

luck50 implements technical and organisational measures designed to protect your personal data against unauthorised access, accidental loss, destruction or alteration. Key security measures include:

• TLS/SSL encryption for all data transmitted between your device and luck50 servers.
• Encryption of sensitive data fields (including payment references and identity document data) at rest.
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis.
• Multi-factor authentication available for account access.
• Regular security assessments and vulnerability testing of platform infrastructure.
• No security measure is absolute. In the event of a personal data breach that poses a risk to your rights, luck50 will notify affected users in accordance with applicable data breach notification requirements.

Subject to applicable law and our legal retention obligations, you have the following rights in respect of your personal data held by luck50. Requests to exercise any of these rights should be submitted to [email protected] with the subject line "Data Rights Request":

• Right of Access: You may request a copy of the personal data we hold about you, along with information on how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Account profile details may also be updated directly through your account settings where applicable.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to Restrict Processing: You may request that we restrict the processing of your personal data in certain circumstances, for example while a dispute is being investigated.
• Right to Data Portability: You may request a copy of personal data that you have provided to us in a structured, machine-readable format where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling, where your individual circumstances warrant it.

We aim to respond to all data rights requests within thirty (30) days of receipt. Where a request is complex or we receive multiple requests simultaneously, this period may be extended by up to a further sixty (60) days, and you will be notified accordingly.

The luck50 platform is strictly for adults aged 18 years or older — or the higher minimum age required by the operator's license jurisdiction. We do not knowingly collect personal data from individuals under the required minimum age. Age verification is conducted as part of the KYC process prior to the activation of full account functionality.

If we become aware that personal data has been collected from an individual who does not meet the minimum age requirement, we will take immediate steps to close the account and securely delete or quarantine the data associated with it, subject to any mandatory regulatory reporting obligations.

luck50 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or platform functionality. Material changes will be communicated to registered users via the email address associated with their account prior to the amended Policy taking effect, except where immediate implementation is required by regulatory instruction.

The "Last Updated" date at the top of this page reflects the most recent revision. Continued use of the Platform following notification of an amended Privacy Policy constitutes acceptance of the revised terms. Users who do not agree to the amended Policy should request account closure prior to the effective date of the change.

If you have any questions about this Privacy Policy, wish to exercise a data right, report a suspected data breach or raise a concern about how your personal data has been handled, please contact us using the details below. All communications should be in English; Urdu assistance is available on request.