Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is published by Lucky6 ("Lucky6", "we", "us" or "our"), the operator of the website accessible at https://lucky6.cam. Lucky6 is an English-language online gaming information and entertainment platform designed for Pakistani users.

We understand that your personal data is important to you. This Policy is designed to be clear, honest and complete — explaining exactly what data we collect, for what purposes, on what legal basis, with whom it may be shared, and how you can exercise your rights. We are committed to handling your data responsibly and in accordance with applicable data protection principles.

By accessing or using the Lucky6 platform, you acknowledge that you have read and understood this Policy. If you do not agree with the practices described here, please discontinue using the platform.

2. Definitions

The following terms are used throughout this Policy:

• "Personal Data" means any information that identifies or could reasonably identify a living individual, directly or indirectly — for example, a name, email address, IP address or device identifier.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, that is Lucky6.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller, under instruction.
• "User" means any individual who accesses or uses the Lucky6 platform.
• "Cookies" means small text files placed on your device by a website to store preferences and usage information.
• "Third Party" means any entity other than Lucky6 and the User.

3. Data Controller

Lucky6 acts as the Data Controller for Personal Data collected and processed through the platform at https://lucky6.cam. As Data Controller, we are responsible for determining how and why your Personal Data is processed.

Where Lucky6 engages third-party service providers (such as analytics providers or hosting services) to process data on our behalf, those providers act as Data Processors and are bound by contractual obligations that require them to process data only as instructed by Lucky6 and to maintain appropriate security standards.

4. Data We Collect

Lucky6 may collect the following categories of Personal Data:

4.1 Data You Provide Directly

• Registration information: Name, email address, date of birth (for age verification purposes) and account credentials where account registration is available;
• Identity verification documents: Where KYC is required — CNIC or passport details, proof of address and selfie/liveness data submitted through secure verification flows;
• Communications: Content of enquiries, feedback or support requests sent to Lucky6 via email or contact forms.

4.2 Data Collected Automatically

• Technical data: IP address, browser type and version, operating system, device type and screen resolution;
• Usage data: Pages visited, time spent on pages, navigation paths, links clicked and session duration;
• Cookies and similar technologies: Cookie identifiers, preference data and analytics metrics as described in Section 12.

4.3 Data We Do Not Collect

Lucky6 does not intentionally collect special categories of sensitive Personal Data (such as racial or ethnic origin, religious beliefs, health data or biometric data) unless required for KYC identity verification and only to the extent strictly necessary for that purpose.

5. Lawful Basis for Processing

Lucky6 processes your Personal Data only where a lawful basis exists. The primary bases we rely on are:

• Contractual necessity: Processing required to perform our contract with you, such as providing access to the platform and managing your account;
• Legal obligation: Processing required to comply with applicable legal requirements, including identity verification, anti-money laundering obligations and regulatory reporting;
• Legitimate interests: Processing that is necessary for Lucky6's legitimate business interests — such as platform security, fraud prevention and service improvement — where those interests are not overridden by your rights and interests;
• Consent: Where you have given clear, freely given consent for a specific processing purpose (such as receiving marketing communications). You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. How We Use Your Personal Data

Lucky6 uses your Personal Data for the following purposes:

• To create and manage your User account on the platform;
• To verify your identity and age where required for compliance or account security purposes;
• To provide, maintain and improve platform content and functionality;
• To respond to your enquiries, support requests or feedback;
• To detect, prevent and investigate fraud, abuse, security breaches and other prohibited conduct;
• To comply with applicable legal and regulatory obligations;
• To analyse usage patterns and improve the platform's content and user experience;
• To send service-related communications (such as account notifications or policy updates);
• To send marketing communications where you have provided explicit consent and have not subsequently opted out.

7. Processing Activity Summary

The table below summarises the key processing activities, purposes and lawful bases applied by Lucky6:

8. Data Sharing & Disclosure

Lucky6 does not sell, rent or trade your Personal Data to third parties for their own commercial or marketing purposes. This is a firm and unconditional commitment.

We may share your Personal Data with third parties only in the following limited circumstances:

• Service providers and Data Processors: Third parties engaged by Lucky6 to provide technical infrastructure, analytics, security, identity verification or customer support services, operating under contractual obligations to process data only as instructed by us;
• Legal and regulatory requirements: Where we are required by applicable law, court order, regulatory authority or government request to disclose Personal Data;
• Protection of rights: Where disclosure is necessary to protect the rights, property or safety of Lucky6, our users or third parties — for example, in connection with fraud prevention or security incidents;
• Business transfers: In the event of a merger, acquisition or sale of assets, Personal Data may be transferred as part of the transaction. Users will be notified of any material change in data controller status.

9. International Data Transfers

Lucky6 operates a platform accessible globally. As a result, your Personal Data may be processed or stored on servers located outside of Pakistan. Where this occurs, Lucky6 takes reasonable steps to ensure that appropriate safeguards are in place to protect your data in a manner consistent with the protections described in this Policy.

Pakistan's data protection framework continues to evolve. The Personal Data Protection Bill, when enacted, may affect how data relating to Pakistani citizens is required to be handled. Lucky6 monitors regulatory developments in Pakistan and will update its practices accordingly.

10. Data Retention

Lucky6 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, and to comply with applicable legal and regulatory obligations. General retention guidelines are as follows:

• Account data: Retained for the duration of your account and for a reasonable period thereafter to comply with legal obligations and resolve disputes;
• KYC and identity verification records: Retained for the period required by applicable anti-money laundering regulations — typically a minimum of five years from the date of verification;
• Transaction and communication records: Retained for the period required to fulfil legal obligations and as needed for dispute resolution;
• Analytics and usage data: Typically retained in aggregated or anonymised form for service improvement purposes, without attribution to identified individuals;
• Marketing preferences and consent records: Retained until you withdraw consent or opt out, and for a reasonable period thereafter as evidence of your consent.

When Personal Data is no longer required, it is securely deleted or anonymised in accordance with our internal data management procedures.

11. Security Measures

Lucky6 applies technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration or destruction. These measures include:

• HTTPS/TLS encryption for all data in transit between your browser and our servers;
• Access controls limiting Personal Data access to authorised personnel on a need-to-know basis;
• Monitoring and logging of access to sensitive data systems;
• Regular review of security practices and infrastructure;
• Contractual requirements imposed on Data Processors regarding security standards.

12. Cookies & Similar Technologies

Lucky6 uses cookies and similar tracking technologies to operate the platform effectively, understand how it is used and improve the experience for all users. Cookies are small text files stored on your device by your browser when you visit a website.

12.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the platform to function correctly — for example, maintaining session state and authentication. These cannot be disabled without significantly disrupting platform functionality.
• Analytics and performance cookies: Used to understand how users interact with the platform — which pages are most visited, where users navigate from and how long sessions last. Data collected is used in aggregate and is not attributed to identified individuals without consent.
• Preference cookies: Store your preferences such as language settings or display options to improve your experience on return visits.
• Marketing and targeting cookies: Used only where you have provided explicit consent. These may be used to deliver relevant content based on your browsing behaviour on the platform.

12.2 Managing Cookies

You can manage or disable cookies through your browser settings. Most modern browsers allow you to refuse all cookies, accept only certain types or delete cookies already stored on your device. Please refer to your browser's help documentation for instructions.

Please note that disabling strictly necessary cookies may prevent certain parts of the platform from functioning correctly.

13. Minors & Age Restriction

The Lucky6 platform is intended solely for users aged 18 years or older — or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect Personal Data from minors.

If you believe that a minor has provided Personal Data to Lucky6 without appropriate parental or guardian consent, please contact us immediately at the details in Section 17. We will take prompt steps to verify the situation and, where appropriate, delete the relevant data.

14. Exercising Your Data Rights

To exercise any of the rights described in the "Your Data Rights" section above — including rights of access, rectification, erasure, restriction, portability or objection — please contact Lucky6 using the details provided in Section 17.

When making a rights request, please provide sufficient information to allow us to identify your account and verify your identity. We will respond to all valid requests within a reasonable period, generally within 30 calendar days. Where a request is complex or numerous, we may extend this period by a further 30 days, in which case we will notify you of the extension.

We will not charge a fee for reasonable, good-faith data rights requests. However, where requests are manifestly unfounded or excessive — particularly if repetitive — we reserve the right to charge a reasonable fee or refuse to comply, in which case we will explain our reasons.

15. Privacy Context — Pakistan

Pakistan's data protection landscape is evolving. At the time of this Policy's publication, the primary legislative framework governing personal data in Pakistan continues to develop. Lucky6 acknowledges the importance of applicable Pakistani data protection principles and aims to handle Personal Data of Pakistani users in a manner consistent with good data governance practice.

Lucky6 does not claim authorisation, endorsement or oversight by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan (SBP), or any other Pakistani regulatory body in respect of its data handling practices. References to Pakistani payment providers — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are made in the context of content and education only and do not reflect any data-sharing arrangement with those entities.

If you are a Pakistani resident and have questions about how your data is handled in the context of applicable local law, we encourage you to contact us directly. This Policy does not constitute legal advice. For specific data protection legal advice relevant to your situation, please consult a qualified legal professional.

16. Policy Amendments

Lucky6 reserves the right to update or amend this Privacy Policy at any time. The "Last Updated" date at the top of this page reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how we protect your data.

Where changes are material — for example, a significant change in how we use your Personal Data or a new category of data collection — we will endeavour to notify registered Users by email or by posting a prominent notice on the platform prior to the change taking effect. Your continued use of the platform following notification of changes constitutes your acceptance of the revised Policy.

17. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or Lucky6's data handling practices, please contact our team. All data-related enquiries should be submitted in English. Urdu-language assistance may be arranged on request.