lukpub Privacy Policy

1. Introduction

Welcome to the lukpub Privacy Policy. lukpub ("we", "our", "us") is committed to protecting the personal information of every player who registers and plays on our Platform at lukpub.net. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data in connection with the lukpub online gaming service.

This Policy applies to all persons who visit, register on, or otherwise interact with the lukpub Platform, including players based in Pakistan and accessing the Platform from any device. By creating a lukpub account or by continuing to use the Platform after this Policy has been updated, you confirm that you have read, understood, and agreed to the practices described herein.

This Privacy Policy should be read alongside our Terms & Conditions, which govern the overall relationship between you and lukpub. Defined terms used but not defined in this Policy carry the same meaning as in the Terms & Conditions. Where there is a conflict between this Policy and the Terms & Conditions on a matter of data privacy, this Policy takes precedence.

2. Data We Collect

lukpub collects personal data from you in several ways — directly when you provide it to us, automatically when you use the Platform, and occasionally from third-party sources such as identity verification providers and payment processors. The categories of personal data we collect are as follows:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health records, or biometric data unless specifically required by applicable law or regulation and with your explicit consent.

3. How We Use Your Data

lukpub uses your personal data only for the purposes set out in this Policy. We apply the principle of data minimisation — we use no more data than is necessary for each specific purpose. The primary purposes for which we process your data are:

• Account Registration and Management: To create and maintain your lukpub account, authenticate your identity at login, and manage your account preferences and settings.
• Identity Verification (KYC): To comply with our obligations under our international gaming license, we are required to verify the identity and age of all players prior to processing any withdrawal. Your submitted documents are used solely for this purpose.
• Transaction Processing: To process deposits, withdrawals, and bonus credits to and from your account, and to maintain an accurate record of all financial transactions associated with your account.
• Game Provision and Bet Settlement: To deliver cricket betting markets, live casino games, slot games, and other gaming services on the Platform, and to record, calculate, and settle all bets placed by you.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, account abuse, and other illegal conduct on the Platform, in compliance with our regulatory obligations.
• Responsible Gaming: To monitor gaming behaviour for indicators of problem gambling and to administer self-exclusion, deposit limit, and reality check tools requested by players.
• Customer Support: To respond to your enquiries, complaints, and requests submitted via live chat, email, or other support channels.
• Marketing Communications: To send you promotional offers, bonus announcements, and PSL / cricket betting market updates, where you have opted in to receive such communications. You may opt out of marketing communications at any time via your account settings or by contacting support.
• Legal and Regulatory Compliance: To comply with applicable laws, regulatory requirements, court orders, and obligations arising under our gaming license, including reporting obligations to regulatory and law enforcement authorities where required.
• Platform Improvement: To analyse usage patterns and technical performance data in order to improve the Platform's functionality, user experience, and game selection.

4. Legal Basis for Processing

lukpub processes your personal data on the following legal bases, consistent with internationally recognised data protection principles:

• Contractual Necessity: Processing your identity data, contact data, financial data, account data, and KYC documentation is necessary for us to perform our obligations under the Terms & Conditions — the contract between you and lukpub. Without this data, we cannot provide the gaming service.
• Legal Obligation: Processing required for KYC/AML compliance, age verification, regulatory reporting, and fraud prevention is carried out to comply with our legal and regulatory obligations under our international gaming license.
• Legitimate Interests: Processing for fraud detection, Platform security, abuse prevention, and analytics is carried out on the basis of lukpub's legitimate interests in operating a safe, secure, and compliant gaming platform. We have assessed that these interests are not overridden by your interests or fundamental rights.
• Consent: Processing for direct marketing communications is carried out on the basis of your explicit opt-in consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

lukpub does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We share your data only in the following limited circumstances, and only to the minimum extent necessary for each purpose:

• Payment Processors: We share financial data with our payment partners (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and bank transfer providers) to process deposits and withdrawals. These partners operate under their own privacy policies and are independently regulated.
• Identity Verification Providers: We may share identity and document data with third-party KYC service providers who assist us in verifying player identity and age in compliance with our licensing requirements. Such providers are bound by strict confidentiality and data processing agreements.
• Game Software Providers: The game providers whose titles appear on the lukpub Platform may receive limited gameplay data (such as bet amounts and session outcomes) for the purpose of game operation and RNG certification. No personally identifiable information is shared beyond what is technically necessary.
• Regulatory and Law Enforcement Authorities: We may disclose your personal data to gaming regulators, financial intelligence units, police, or courts where required by law, court order, or regulatory direction. We will notify you of any such disclosure where we are legally permitted to do so.
• Professional Advisors: We may share data with our legal advisors, auditors, and compliance consultants on a strictly need-to-know basis and subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of lukpub's assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained. You will be notified of any such transfer.

6. Cookies & Tracking Technologies

The lukpub Platform uses cookies and similar tracking technologies to provide core functionality, remember your preferences, and analyse Platform performance. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable core features such as login session management, game loading, balance display, and security token validation. These cookies cannot be disabled without breaking Platform functionality.
• Functional Cookies: These cookies remember your preferences, such as preferred language, display settings, and game lobby filters, so that you do not need to reset them on every visit.
• Analytics Cookies: These cookies collect aggregated, anonymised data about how players navigate the Platform — which pages are visited most, where players drop off, and how long sessions last. This information is used solely to improve the Platform and is not linked to your personal account.
• Security Cookies: These cookies support our fraud detection and security systems by helping us identify unusual login patterns, multiple account indicators, and suspicious access behaviour.

You may manage non-essential cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect your ability to use some features of the Platform. lukpub does not use third-party advertising or cross-site tracking cookies.

7. Data Retention

lukpub retains your personal data only for as long as is necessary for the purposes for which it was collected, and in accordance with our legal and regulatory obligations. The following general retention periods apply:

• Active Account Data: All personal, financial, and account data is retained for the full duration of your active account registration with lukpub.
• Post-Closure Retention: Following account closure, we retain your identity data, KYC documents, financial transaction records, and betting history for a minimum of five (5) years. This retention period is required by our international gaming license for audit, regulatory compliance, and anti-money laundering purposes.
• Marketing Data: If you have opted in to marketing communications, we retain your marketing preferences for the duration of your account. If you opt out, we remove you from active marketing lists within 5 business days, though we retain a suppression record of your opt-out to prevent future accidental contact.
• Support Communications: Live chat transcripts and support emails are retained for 24 months from the date of the interaction.
• Technical and Usage Data: Anonymised analytics and technical logs are retained for up to 12 months.

Where retention beyond these periods is required by a specific legal obligation (such as an ongoing regulatory investigation or court order), data will be retained until that obligation is discharged.

8. Your Data Rights

As a player registered with lukpub, you hold the following data rights in respect of your personal information. These rights are consistent with internationally recognised data protection standards applied under our gaming license framework:

• Right of Access: You have the right to request a copy of all personal data we hold about you. We will provide this within 30 days of receiving a verified request, at no charge for a first request in any 12-month period.
• 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. You may update most basic account details directly within your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. Please note that this right is subject to overriding legal retention obligations — we cannot delete data that we are required to retain under our gaming license or anti-money laundering regulations.
• Right to Restrict Processing: You may request that we temporarily suspend our use of your personal data in certain circumstances — for example, while you contest the accuracy of data we hold, or while a complaint is being investigated.
• Right to Data Portability: You have the right to receive a structured, commonly used, machine-readable copy of the personal data you have provided to us, and to transmit this to another data controller where technically feasible.
• Right to Object: You have the right to object to our processing of your personal data where that processing is based on legitimate interests. We will consider your objection and cease processing unless we have compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where we process your data on the basis of consent (principally, marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact our Data Protection team at the email address provided in Section 13. We will acknowledge your request within 2 business days and fulfil it within 30 days, subject to identity verification.

9. Data Security

lukpub implements technical and organisational security measures appropriate to the risk level associated with the personal data we process. Our security framework includes, but is not limited to, the following measures:

• Encryption: All data transmitted between your device and the lukpub Platform is encrypted using TLS 1.2 or higher. Sensitive data at rest, including KYC documents and financial records, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within lukpub is restricted to personnel who require it to perform their specific job functions. All staff with data access are subject to confidentiality agreements and receive mandatory data protection training.
• Password Security: Player passwords are stored as salted cryptographic hashes. lukpub staff members cannot view your password in plain text. We strongly recommend that you use a unique, complex password for your lukpub account and enable any additional authentication options available to you.
• Infrastructure Security: The lukpub Platform is hosted on security-certified infrastructure with regular penetration testing, vulnerability scanning, and security patching protocols in place.
• Incident Response: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, lukpub will notify affected players and the relevant regulatory authority within the timeframe required by our licensing obligations.

10. Children & Minors

The lukpub Platform is strictly for persons aged 21 and above. We do not knowingly collect, process, or retain personal data from any person under the age of 21. If we discover or have reason to believe that personal data has been submitted by a person under 21, we will immediately close the associated account, delete all collected data (subject to any mandatory retention requirements under our gaming license), and refund any deposits made, pending identity verification.

If you are a parent or guardian and you believe that a minor has accessed the lukpub Platform using your account, device, or payment method, please contact our support team immediately via live chat. We will investigate and take appropriate action, including account suspension, without delay.

11. International Data Transfers

The lukpub Platform is operated under an international gaming license, and certain of our service providers — including game software suppliers, KYC verification partners, and infrastructure hosting providers — may be located outside Pakistan. As a result, your personal data may be transferred to, stored in, and processed in countries other than Pakistan.

Where such international transfers occur, lukpub ensures that appropriate safeguards are in place to protect your personal data to a standard consistent with internationally recognised data protection principles. These safeguards may include:

• Standard contractual clauses incorporated into data processing agreements with third-party processors.
• Transfer to processors located in jurisdictions that are recognised as providing an adequate level of data protection.
• Binding corporate rules or equivalent frameworks where transfers occur within a group of companies.

You may request further information about the specific safeguards applied to international transfers of your personal data by contacting our Data Protection team.

12. Updates to This Policy

lukpub reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, applicable law, or regulatory requirements. When a material change is made to this Policy, we will notify registered players by email to the address associated with their account and/or by displaying a prominent notice on the Platform, no less than seven (7) days before the updated Policy takes effect.

The "Effective Date" displayed at the top of this page indicates the date on which the current version of the Policy came into effect. We recommend that you review this page periodically, particularly ahead of major Platform updates or new sporting seasons such as PSL, when data processing practices related to betting and promotions may be updated.

Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you must stop using the Platform and contact us to request account closure in accordance with the Terms & Conditions.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way lukpub processes your personal data, please contact our Data Protection team. We are committed to responding promptly and transparently to all data-related enquiries.

Our support agents are available 24 hours a day, seven days a week via live chat on the Platform for general account and privacy queries. For formal data subject rights requests, data breach reports, or written complaints, please use the email address below. Note that this address is provided as plain text only and is not a clickable link:

lukpub takes every privacy concern seriously, regardless of scale. Whether you have a question about a single data field or a formal request to delete your entire account history, our Data Protection team will handle your enquiry with care and professionalism.