luckin33 Privacy Policy

1. Definitions

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

• "luckin33", "we", "us", "our" — the operator of the luckin33 platform accessible at luckin33.one.
• "Platform" — the luckin33 website, progressive web application, and all gaming services offered thereon.
• "Member", "you", "your" — any individual who has registered a luckin33 Account.
• "Personal Data" — any information relating to an identified or identifiable natural person, as defined under applicable data protection legislation.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
• "KYC Data" — identity and verification documents submitted in connection with the Know Your Customer process required by international gaming authority standards.

2. Data Controller

luckin33 is the data controller responsible for the Personal Data processed under this Privacy Policy. For all data protection enquiries, please contact the luckin33 Data Protection team at [email protected].

luckin33 is committed to handling your Personal Data with integrity and in compliance with applicable international data protection standards, including those relevant to Malaysian data subjects under the Personal Data Protection Act 2010 (PDPA) where applicable.

3. Data We Collect

luckin33 collects the following categories of Personal Data from Members:

4. How We Collect Data

luckin33 collects Personal Data through the following means:

• Direct input: Information you provide when registering, completing KYC verification, making deposits or withdrawals, or contacting support.
• Automated collection: Technical and Usage Data collected automatically when you access and interact with the Platform, including through cookies, server logs, and session management systems.
• Third-party processors: Financial data received from payment processors (Touch n Go eWallet, Boost, GrabPay, FPX banking partners) in connection with transaction verification and fraud prevention.
• Identity verification services: Where luckin33 uses a third-party KYC verification partner to process identity documents, that partner transmits a verification outcome (pass/fail) and stores documents in accordance with its own regulated data retention obligations.

5. Legal Basis for Processing

luckin33 processes your Personal Data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between luckin33 and a Member — including account creation, game access, payment processing, and withdrawal handling.
• Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including anti-money-laundering (AML) obligations, KYC verification requirements, and international gaming authority directives.
• Legitimate interests: Processing carried out in luckin33's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement — where such interests are not overridden by your data protection rights.
• Consent: Processing of non-essential data (such as optional marketing communications) where you have provided explicit consent. You may withdraw this consent at any time by contacting luckin33 support.

6. How We Use Your Data

luckin33 uses your Personal Data for the following purposes:

• Creating and managing your luckin33 Account, including authentication and session management.
• Processing deposits, withdrawals, and other financial transactions, including verification of payment methods.
• Conducting identity verification (KYC) in accordance with anti-money-laundering and international gaming authority requirements.
• Providing and improving Platform features, game content, and the overall user experience for Malaysian players.
• Detecting and preventing fraud, bonus abuse, multi-accounting, and other prohibited conduct as defined in the luckin33 Terms & Conditions.
• Monitoring gameplay patterns as part of luckin33's responsible gaming obligations, including identifying indicators of problem gambling behaviour.
• Responding to support queries, complaints, and dispute resolution requests submitted by Members.
• Sending transactional communications (deposit confirmations, withdrawal notifications, account alerts) to your registered contact details.
• Sending promotional communications, where you have opted in to receive them, regarding luckin33 bonuses, new game releases, and sportsbook offers.
• Complying with applicable legal, regulatory, and law enforcement obligations.

7. Data Sharing & Disclosure

luckin33 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share Personal Data with third parties only in the following circumstances:

• Payment processors: Transaction data shared with eWallet operators (Touch n Go, Boost, GrabPay) and FPX banking partners solely for the purpose of processing your financial transactions.
• Identity verification providers: KYC documents shared with regulated third-party identity verification services to process verification outcomes.
• Game content providers: Anonymised usage and gameplay data shared with licensed studio partners for game performance analytics. No personally identifiable information is shared with game studios.
• Regulatory and law enforcement authorities: Personal Data disclosed in response to a lawful request from a competent regulatory authority, court order, or law enforcement agency where luckin33 is legally obliged to comply.
• Service providers: Personal Data shared with infrastructure, cloud hosting, analytics, and customer support technology providers operating under binding data processing agreements with luckin33.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or part of luckin33's business, Personal Data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

8. International Data Transfers

Some of luckin33's service providers and infrastructure partners may process Personal Data outside of Malaysia. Where such transfers occur, luckin33 takes appropriate safeguards to ensure that your data is protected to a standard equivalent to that required under applicable data protection law. These safeguards may include standard contractual clauses, binding corporate rules, or transfers to jurisdictions deemed to provide an adequate level of data protection by relevant authorities.

9. Data Retention

luckin33 retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, including for the duration of your Account and for such additional periods as are required by applicable law or regulation:

• Account and transaction data: Retained for a minimum of five (5) years following Account closure, in compliance with AML record-keeping requirements.
• KYC documentation: Retained for a minimum of five (5) years following the completion of the verification process, or longer if required by applicable regulatory obligations.
• Support communications: Retained for three (3) years following resolution of the relevant support interaction.
• Technical and Usage Data: Retained in aggregated or anonymised form for analytics purposes for up to two (2) years.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with industry-standard data destruction practices.

10. Cookies & Tracking Technologies

luckin33 uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies used are as follows:

• Strictly necessary cookies: Required for the Platform to function, including session authentication, load balancing, and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences (such as language and display settings) to personalise your luckin33 experience.
• Analytics cookies: Collect anonymised usage data to help luckin33 understand how players navigate the Platform and where improvements can be made. No personally identifiable data is transmitted via analytics cookies.
• Security cookies: Detect and prevent fraudulent activity, bot traffic, and unauthorised access attempts on the luckin33 Platform.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair Platform functionality and may prevent you from logging in to your luckin33 Account.

11. Your Data Rights

Subject to applicable law, you have the following rights in relation to your Personal Data held by luckin33:

• Right of access: Request a copy of the Personal Data luckin33 holds about you.
• Right to rectification: Request correction of inaccurate or incomplete Personal Data.
• Right to erasure: Request deletion of your Personal Data, subject to luckin33's legal retention obligations and any outstanding financial transactions or regulatory requirements.
• Right to restriction: Request that luckin33 restricts the processing of your Personal Data in certain circumstances.
• Right to data portability: Request a structured, machine-readable copy of Personal Data you have provided to luckin33.
• Right to object: Object to the processing of your Personal Data on the basis of legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact the luckin33 support team at [email protected]. luckin33 will respond to valid requests within thirty (30) days.

12. Security Measures

luckin33 implements a layered security framework to protect your Personal Data against unauthorised access, disclosure, alteration, or destruction:

• All data transmitted between your device and luckin33 servers is encrypted using TLS 1.3.
• Passwords are stored exclusively as salted cryptographic hashes — never in plain text.
• Access to systems containing Personal Data is restricted to authorised luckin33 personnel on a need-to-know basis, subject to role-based access controls and multi-factor authentication.
• Regular security assessments, penetration testing, and vulnerability scanning are conducted on Platform infrastructure.
• Incident response procedures are in place to detect, contain, and notify affected Members of any data breach in accordance with applicable notification obligations.

No method of transmission over the internet or electronic storage is completely secure. While luckin33 employs commercially reasonable security measures, we cannot guarantee absolute security. Members are encouraged to maintain strong, unique passwords and enable two-factor authentication on their luckin33 Accounts.

13. Children & Age Verification

The luckin33 Platform is strictly restricted to individuals aged twenty-one (21) years or older. luckin33 does not knowingly collect Personal Data from individuals under this age. Where luckin33 identifies or is notified that Personal Data has been collected from an individual under 21, such data will be deleted promptly and the Account suspended. Parents or guardians who believe a minor has accessed the luckin33 Platform should contact [email protected] immediately.

14. Third-Party Links

The luckin33 Platform does not contain links to third-party websites. This Privacy Policy applies solely to data processing activities conducted by luckin33 in connection with the Platform. luckin33 is not responsible for the privacy practices of any third-party service providers whose services are accessed independently by Members outside of the Platform.

15. Policy Changes

luckin33 reserves the right to update this Privacy Policy from time to time to reflect changes in data processing practices, applicable law, or Platform functionality. Material changes will be communicated to registered Members via the email address associated with their Account, or via a prominent notice on the Platform, no less than fourteen (14) days before the updated Policy takes effect. Your continued use of the luckin33 Platform following the effective date of any update constitutes your acceptance of the revised Policy.

16. Contact

For any questions, concerns, or requests relating to this Privacy Policy or luckin33's data processing practices, please contact the luckin33 Data Protection team:

• Email: [email protected]
• Live Chat: Available 24/7 through the luckin33 Platform
• Response Time: luckin33 targets a response within 5 business days for data rights requests and within 30 days for formal subject access requests.