Privacy Policy
lack33 Data Commitment

1. Who We Are

lack33 operates the online casino and sports betting platform accessible at https://lack33.net (the "Platform"). In this Privacy Policy, references to "lack33", "we", "us", or "our" refer to the Company responsible for operating the Platform. References to "you" or "your" refer to any individual who registers an account, visits the Platform, or otherwise interacts with our services.

lack33 acts as the data controller in respect of personal data collected through the Platform. This means we determine the purposes for which, and the means by which, your personal data is processed. If you have any questions about how your data is handled, please contact us using the details provided in Section 13 of this Policy.

2. Data We Collect

2.1 Data You Provide Directly

When you register an account, deposit funds, request a withdrawal, complete KYC verification, or contact our support team, you provide us with personal data directly. This includes:

• Identity data: Full legal name, date of birth, gender, nationality
• Contact data: Email address, Pakistani mobile number, residential address
• Identity documents: CNIC, passport, or driving licence (for KYC purposes)
• Financial data: JazzCash or EasyPaisa account details, HBL/UBL/Meezan Bank account references, Visa/Mastercard details (tokenised, not stored in full)
• Communications data: Records of your interactions with our support team via email or live chat
• Responsible gaming data: Self-exclusion preferences, deposit limits, and session limit settings you configure

2.2 Data Collected Automatically

When you access the lack33 Platform, certain technical data is collected automatically by our systems. This includes:

• Device & technical data: IP address, device type, operating system, browser type and version
• Usage data: Pages visited, games played, session duration, click-stream data, betting history
• Location data: General geographic location derived from IP address (used for jurisdiction compliance checks)
• Cookie data: Session identifiers, preference cookies, and analytics data as described in Section 5

2.3 Data from Third Parties

In certain circumstances lack33 may receive personal data about you from third-party sources, including: payment processors confirming transaction status; identity verification service providers during KYC processing; and fraud prevention databases used to protect the integrity of our Platform. Data received from third parties is handled with the same standard of care as data you provide directly.

3. How We Use Your Data

lack33 uses your personal data only for clearly defined operational and legal purposes. The table below summarises the primary uses and the corresponding legal basis for each:

4. Legal Basis for Processing

lack33 processes your personal data on one or more of the following legal bases, depending on the purpose of the processing:

• Contract performance: Processing is necessary to provide the services you have requested by registering an account and agreeing to our Terms & Conditions.
• Legal obligation: Processing is required to comply with applicable anti-money laundering regulations, KYC requirements, responsible gaming obligations, and other statutory duties.
• Legitimate interests: Processing is necessary for the purposes of our legitimate business interests — such as fraud prevention, platform security, and service improvement — where those interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent (for example, for direct marketing communications), you may withdraw that consent at any time by contacting [email protected] or updating your account preferences.

5. Cookies & Tracking Technologies

5.1 What Are Cookies

Cookies are small text files placed on your device when you visit the lack33 Platform. They allow us to recognise your browser, remember your preferences, maintain your session, and collect analytical data about how the Platform is used. lack33 uses both first-party cookies (set by us directly) and limited third-party cookies (set by service providers acting on our behalf).

5.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled and do not require your consent. They include session authentication tokens and security cookies.
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and display choices. Disabling these may reduce your experience.
• Analytics cookies: Collect aggregated, anonymised data about how visitors use the Platform. This helps us identify which features are popular and where improvements are needed.
• Marketing cookies: Used only where you have given explicit consent to receive personalised offers and promotions from lack33.

5.3 Managing Cookies

You may manage cookie preferences through your browser's settings at any time. Please note that disabling strictly necessary cookies will prevent the Platform from operating correctly. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.

6. Sharing Your Data

lack33 does not sell your personal data. We may share your data with carefully selected third parties only where necessary and only in the following circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and Visa/Mastercard partner networks, solely for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers who assist us in verifying the identity and age of registered players as required by our regulatory obligations.
• Fraud and AML screening services: Databases and services used to screen transactions and account activity for potential money laundering, fraud, or other prohibited activity.
• IT infrastructure providers: Cloud hosting and data storage providers who process data on our behalf under strict data processing agreements that prohibit independent use of your information.
• Regulatory and law enforcement authorities: Where we are required by law, court order, or regulatory instruction to disclose personal data, we will comply with such obligations and, where permitted, notify you of the disclosure.
• Business transfers: In the event of a merger, acquisition, or sale of assets involving lack33, your personal data may be transferred as part of that transaction. You will be notified of any such transfer in advance where reasonably practicable.

7. Data Retention

lack33 retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account data and transaction records: Retained for a minimum of five years following account closure, in accordance with anti-money laundering record-keeping requirements.
• KYC documentation: Retained for a minimum of five years from the date of verification, or longer if required by applicable regulatory guidance.
• Customer support communications: Retained for three years from the date of the communication.
• Marketing consent records: Retained for the duration of your consent and for two years thereafter to evidence compliance.
• Technical and usage logs: Typically retained for 12 months on active servers, with selected records archived for longer periods where required for security investigation purposes.

When personal data is no longer required, lack33 securely deletes or anonymises it so that it can no longer be associated with you as an individual.

8. Your Data Rights

Subject to applicable law and certain regulatory limitations, you hold the following rights in respect of personal data that lack33 holds about you. To exercise any of these rights, please contact us at [email protected] with your full name, registered email address, and a clear description of the right you wish to exercise. We will respond within 30 calendar days of receiving a verified request.

Please note that certain rights are subject to limitations where lack33 is required to retain data to comply with legal obligations — for example, AML record-keeping requirements may prevent immediate erasure of transaction records even upon a valid request.

9. Data Security

lack33 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers
• AES-256 encryption at rest for sensitive data fields including identity documents and payment information
• Multi-factor authentication requirements for administrative access to production systems
• Regular penetration testing and vulnerability assessments conducted by qualified third-party security specialists
• Role-based access controls ensuring that only personnel with a legitimate operational need can access personal data
• Incident response procedures that include mandatory notification protocols in the event of a data breach affecting your personal data

While lack33 takes every reasonable precaution to protect your personal data, no system is completely immune to security risks. You are responsible for maintaining the security of your account credentials and for ensuring that your own device and network are adequately protected.

10. Children's Privacy

The lack33 Platform is strictly intended for individuals aged 21 years or older. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. If we discover that personal data has been submitted by a person under the minimum age, the associated account will be immediately closed, all data will be deleted in accordance with our data retention policy, and the matter will be handled in accordance with our responsible gaming obligations.

If you believe that a minor has registered an account on the lack33 Platform, please notify us immediately at [email protected] so that we may take prompt action.

11. Third-Party Links

The lack33 Platform may contain links to third-party websites or resources where contextually relevant. lack33 has no control over the content, privacy practices, or data handling of any third-party website and is not responsible for their privacy policies. We encourage you to review the privacy policy of any third-party website you visit. The presence of a link on the lack33 Platform does not constitute an endorsement of the linked site's privacy practices.

12. Amendments to This Policy

lack33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Where a material change is made, we will notify you via your registered email address or via a prominent notice on the Platform prior to the change taking effect. The "last updated" date at the top of this Policy will be revised with each amendment.

Continued use of the lack33 Platform following notification of any amendment to this Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with any changes, you must cease using the Platform and contact us to request account closure.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which lack33 handles your personal data, please contact our Data Support team. We aim to acknowledge all privacy-related enquiries within 48 hours and to resolve them fully within 30 calendar days.

Email: [email protected]

This Privacy Policy was last reviewed and updated in January 2026. The English-language version of this document is the definitive governing version. In the event of any inconsistency between a translated version and this English version, the English version shall prevail.