Privacy Policy — luckin33

Introduction

luckin33 (referred to herein as "luckin33", "we", "us", or "our") is committed to protecting the privacy and personal data of all individuals who access and use the luckin33 platform at luckin33.cam (the "Platform"). This Privacy Policy ("Policy") sets out in clear and transparent terms how we collect, use, store, share, and protect your personal information in connection with your use of the Platform and related services.

This Policy applies to all registered members, visitors to the Platform, and any individual whose personal data is processed by luckin33 in connection with the provision of its online gaming and sports betting services. It should be read alongside our Terms & Conditions and our Responsible Gambling Policy.

By registering an account with luckin33 or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must refrain from using the Platform.

Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, or one or more factors specific to their identity.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.
• "Data Controller" means luckin33, which determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means any third party engaged by luckin33 to process Personal Data on its behalf under contractual obligation.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement to the processing of Personal Data.
• "KYC Data" means identity verification documents and information submitted by members in connection with the Know Your Customer compliance process, including copies of MyKad, passport, proof of address, and selfie photographs.
• "Transaction Data" means records of financial transactions conducted through the Platform, including deposits, withdrawals, wagering activity, and payment method identifiers.
• "Cookie" means a small text file placed on your device by the Platform for the purposes of session management, analytics, and functionality.

Personal Data We Collect

luckin33 collects only the Personal Data that is necessary for the legitimate purposes described in this Policy. The categories of data we collect are as follows:

3.1 Registration and Identity Data

• Full legal name as it appears on your identity document
• Date of birth (used to verify 21+ age eligibility)
• Residential address, including postcode and state
• Email address and contact telephone number
• Username and encrypted password credentials
• Nationality and country of residence

3.2 Identity Verification (KYC) Data

• Copy of Malaysian identity card (MyKad) or passport
• Proof of residential address (utility bill, bank statement)
• Selfie photograph for facial verification purposes
• Source of funds documentation where required

3.3 Financial and Transaction Data

• Deposit and withdrawal history, including amounts, dates, and timestamps
• Payment method identifiers (e-wallet reference numbers, partial bank account numbers — we do not store full card numbers)
• Wagering and gaming activity records
• Bonus and promotion redemption history
• Cryptocurrency wallet addresses where applicable

3.4 Technical and Usage Data

• IP address and geolocation data
• Device type, browser type, and operating system
• Session duration, pages visited, and click patterns
• Referring URL and search terms
• Cookie identifiers and similar tracking data

3.5 Communications Data

• Records of customer support interactions via live chat, email, or WhatsApp
• Complaint and dispute correspondence
• Feedback and survey responses where voluntarily provided

How We Collect Your Personal Data

luckin33 collects Personal Data through the following means:

4.1 Directly From You

When you complete the registration process, submit KYC documentation, make a deposit or withdrawal request, contact our customer support team, respond to surveys or promotions, or voluntarily provide information during Platform interactions.

4.2 Automatically Through the Platform

Technical and usage data is collected automatically when you access the Platform, through server logs, cookies, web beacons, and similar technologies. This data is collected without requiring any active input from you and is used primarily for security, performance, and analytics purposes.

4.3 From Third-Party Service Providers

We may receive Personal Data from third-party identity verification providers, payment processors (including FPX operators, Touch 'n Go eWallet, Boost, and other payment partners), and fraud detection services engaged by luckin33. Data received from third parties is handled in accordance with this Policy and is subject to the contractual protections described in Section 7.

Purposes of Data Processing

luckin33 processes your Personal Data for the following specific and legitimate purposes:

• Account Creation and Management: To register and maintain your luckin33 account, verify your identity, and administer your membership.
• Age and Eligibility Verification: To confirm that you are at least 21 years of age and are eligible to use the Platform in accordance with our Terms and applicable law.
• Payment Processing: To process deposits via Touch 'n Go eWallet, Boost, GrabPay, DuitNow, FPX, bank card, Bitcoin (BTC), and USDT, and to process withdrawal requests to your nominated payment method.
• AML and Regulatory Compliance: To comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and any reporting obligations imposed by applicable law.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, cheating, collusion, and other Platform integrity risks.
• Customer Support: To respond to your enquiries, resolve disputes, and maintain records of support interactions.
• Responsible Gambling: To monitor gaming activity and implement responsible gambling tools including deposit limits, session controls, and self-exclusion, and to identify patterns indicative of problem gambling.
• Platform Improvement: To analyse usage patterns and technical performance data to improve the Platform's functionality, content, and user experience.
• Marketing Communications: To send you promotional offers, bonus notifications, and event information where you have provided consent to receive such communications. You may withdraw this consent at any time by contacting our support team.
• Legal Obligations and Dispute Resolution: To comply with applicable laws, court orders, and regulatory demands, and to exercise or defend legal claims.

Legal Basis for Processing

luckin33 processes Personal Data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and luckin33 — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal Obligation: Processing required to comply with applicable laws, including AML regulations, KYC obligations, and regulatory reporting requirements.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, Platform security, and analytical activities, where such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given and informed consent, particularly in relation to marketing communications and the use of non-essential cookies. You have the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Data Sharing and Disclosure

luckin33 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We may share your Personal Data with the following categories of recipients under the following conditions:

7.1 Service Providers and Data Processors

We engage third-party service providers who process Personal Data on our behalf, including payment processors (such as FPX operators and e-wallet partners including Touch 'n Go eWallet, Boost, and GrabPay), identity verification providers, cloud hosting providers, customer support platform operators, and analytics service providers. All such providers are bound by data processing agreements that restrict their use of Personal Data to the purposes specified by luckin33.

7.2 Regulatory and Law Enforcement Authorities

We may disclose Personal Data to competent authorities, including financial regulators, law enforcement agencies, and courts, where required to do so by applicable law, court order, or regulatory obligation, or where disclosure is necessary to protect the rights, property, or safety of luckin33, its members, or the public.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or substantially all of the assets of luckin33, Personal Data held by the Platform may be transferred to the acquiring entity as part of the transaction, subject to equivalent data protection commitments.

Data Retention

luckin33 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with applicable legal and regulatory obligations, and to exercise or defend legal claims. The specific retention periods applicable to each category of data are set out in the table in Section 3 of this Policy.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that renders it impossible to re-identify the relevant individual. Anonymised data may be retained indefinitely for statistical and analytical purposes.

Where you request closure of your luckin33 account, we will retain your Personal Data for the post-closure retention periods stated in Section 3, as required by our legal obligations.

Data Security

luckin33 implements comprehensive technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS 1.3) encryption for all data transmitted between your device and the Platform
• AES-256 encryption for Personal Data stored at rest on our servers
• Role-based access controls limiting staff access to Personal Data on a strict need-to-know basis
• Regular security audits and penetration testing by independent security specialists
• Multi-factor authentication requirements for administrative access to systems holding Personal Data
• Zero storage of full payment card numbers — only tokenised references are retained
• Intrusion detection and 24/7 monitoring of Platform infrastructure

While we take all reasonable steps to protect your Personal Data, no transmission or storage system can be guaranteed to be completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant authorities as required by applicable law.

Cookies & Tracking Technologies

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

10.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function. They enable session management, authentication, and security features. These cookies cannot be disabled without significantly impairing Platform functionality.

10.2 Performance and Analytics Cookies

These cookies collect information about how you use the Platform, including which pages you visit most frequently and any error messages you encounter. The information collected is aggregated and anonymised. These cookies help us improve the performance and content of the Platform.

10.3 Functional Cookies

These cookies allow the Platform to remember choices you have made (such as your preferred language and regional settings) to provide enhanced, personalised features. Information collected by these cookies is not used to track your activity on third-party websites.

You may manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the functionality and performance of the Platform. Continued use of the Platform following the display of our cookie notice constitutes consent to the use of cookies as described in this section.

Your Rights as a Data Subject

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

• Right of Access: You have the right to request a copy of the Personal Data we hold about you and information about how it is processed.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete Personal Data held about you.
• Right to Erasure: You have the right to request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on our legitimate interests, and to withdraw consent for processing based on consent at any time.
• Right Not to be Subject to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing that produce significant legal or similarly significant effects on you.

To exercise any of the above rights, please contact our Data Protection team using the contact details set out in Section 15. We will respond to all valid requests within thirty (30) calendar days. We may ask you to verify your identity before processing your request.

Children's Privacy

The luckin33 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or store the Personal Data of any individual under the age of 21. All registration applicants are required to confirm their age and undergo age verification as part of the KYC process.

If we become aware that Personal Data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete all associated Personal Data, and report the matter to the appropriate authorities where required by law. If you believe that a minor has registered an account on the Platform, please contact us immediately at [email protected].

Cross-Border Data Transfers

In connection with the operation of the Platform and the engagement of third-party service providers, your Personal Data may be transferred to and processed in jurisdictions outside Malaysia. Where such transfers occur, luckin33 implements appropriate safeguards to ensure that your Personal Data receives a level of protection equivalent to that provided under Malaysian law.

Such safeguards may include contractual clauses in agreements with data processors that impose data protection obligations consistent with applicable law, or reliance on the adequacy of data protection frameworks in the recipient jurisdiction as recognised by competent authorities.

Policy Amendments

luckin33 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the features and services offered by the Platform. Material changes to this Policy will be communicated to registered members via email to the address on file and/or via a prominent notice on the Platform prior to the changes taking effect.

The date on which this Policy was last updated is displayed at the top of this page. Your continued use of the Platform following notification of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

Contact Us & Data Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or our handling of your Personal Data, please contact the luckin33 Data Protection team through the following channels:

• Email: [email protected] — please include the subject line "Privacy Enquiry" or "Data Subject Request" as appropriate (plain text, not a clickable link).
• Live Chat: Available 24/7 on the Platform in English, Bahasa Melayu, and Mandarin. Average response time 3–5 minutes.

We will acknowledge all written data subject requests within five (5) business days and provide a substantive response within thirty (30) calendar days. Where a request is particularly complex or numerous, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.