Your Privacy Matters to
pkluck

1 Who We Are

This Privacy Policy is issued by pkluck ("we", "us", "our", "the Platform"), the operator of the online casino and sports betting website accessible at pkluck.vu. pkluck acts as the data controller in respect of all personal information collected from players and prospective players who access or use the platform.

For the purposes of this policy, "personal data" means any information that can identify you directly or indirectly as an individual, including your name, contact details, account credentials, transaction history, device identifiers, and browsing behaviour on the pkluck platform.

This policy applies to all individuals who register an account with pkluck, visit the pkluck website without registering, use pkluck's customer support services, or interact with pkluck's communications. It should be read in conjunction with the Terms & Conditions and the Responsible Gaming Policy.

2 Data We Collect

pkluck collects personal data from you through several channels: information you provide directly during registration and KYC verification, information generated by your use of the platform, and — in limited circumstances — information received from third-party service providers. The categories of data we collect are set out in the table below.

2.1 Data You Are Not Required to Provide

Certain fields during registration are optional, such as secondary contact preferences. You are under no obligation to provide optional data, though doing so may enhance your experience or expedite account verification. Mandatory fields are clearly marked during the registration process.

2.2 Data Collected Automatically

When you visit pkluck.vu, our servers automatically log technical data including your IP address, browser type, referring URL, and session timestamps. This data is collected for security monitoring, fraud prevention, and platform performance analysis, and is not used to identify you personally beyond what is necessary for these purposes.

3 How We Use Your Data

pkluck uses your personal data for the following defined purposes. We will not use your data for any purpose that is incompatible with those listed below without first obtaining your explicit consent.

• Account creation and management: To register your player account, verify your identity, maintain your account settings, and communicate account-related notifications.
• Payment processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, and banking channels, and to maintain accurate transaction records.
• KYC and anti-money laundering compliance: To verify your identity, assess the source of funds where required, and fulfil our obligations under applicable anti-money laundering standards.
• Platform delivery and improvement: To provide access to casino games, sports betting markets, and all other platform features; to diagnose technical faults; and to develop and improve platform performance.
• Fraud and security monitoring: To detect, investigate, and prevent fraudulent activity, account takeover attempts, bonus abuse, and other prohibited conduct as defined in the Terms & Conditions.
• Customer support: To respond to your queries, complaints, and support requests, and to maintain records of communications for quality assurance purposes.
• Responsible gaming: To monitor betting patterns that may indicate problem gambling behaviour, enforce self-exclusion requests, and apply deposit and loss limits set by you or by our responsible gaming team.
• Marketing communications: To send you promotional offers, bonus notifications, and news about pkluck products and events — but only where you have opted in or where a legitimate interest applies and you have not opted out. See Section 12 for full details.
• Legal and regulatory obligations: To comply with applicable laws, respond to lawful requests from competent authorities, and enforce our Terms & Conditions.

4 Legal Basis for Processing

pkluck processes your personal data on the following legal bases depending on the specific purpose of processing:

• Contractual necessity: Processing required to fulfil the contract between you and pkluck — i.e., to provide the services described in the Terms & Conditions — including account management, payment processing, and platform access.
• Legal obligation: Processing required to comply with anti-money laundering requirements, financial record-keeping obligations, and any lawful requests from competent regulatory or law enforcement authorities.
• Legitimate interests: Processing carried out for pkluck's legitimate business interests where those interests are not overridden by your data protection rights, including fraud prevention, platform security, and internal analytics. Where we rely on legitimate interests, we have conducted a balancing assessment to confirm that the processing is proportionate.
• Consent: Processing for marketing communications and the use of non-essential cookies, where you have provided freely given, specific, informed consent. You may withdraw consent at any time without affecting the lawfulness of any prior processing.

5 Sharing Your Data

pkluck does not sell, rent, or trade your personal data to any third party. Data sharing is limited to the categories of recipients listed below, each of which is bound by contractual data protection obligations:

5.1 Payment Service Providers

Transaction data is shared with the relevant payment service operators — including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Visa, and Mastercard — to the extent necessary to process your deposits and withdrawals. Each payment provider operates under its own privacy and data security framework.

5.2 KYC and Identity Verification Partners

Identity documents and verification data are shared with pkluck's contracted KYC and anti-money laundering compliance service providers. These providers process identity data solely for the purpose of completing the verification requested and are prohibited from using it for any other purpose.

5.3 Game Studio Partners

When you play a live casino game or a game provided by a third-party studio — including Evolution Gaming, Ezugi, Pragmatic Play, NetEnt, Microgaming, or Spribe — certain technical session data (such as session identifiers and bet amounts) is shared with the relevant studio to facilitate game delivery. No additional personal data is transmitted beyond what is technically required to run the game session.

5.4 IT and Security Service Providers

pkluck uses contracted third-party providers for cloud hosting, content delivery, cybersecurity monitoring, and platform analytics. These providers access personal data only as data processors acting on pkluck's documented instructions and are prohibited from processing the data for their own purposes.

5.5 Legal and Regulatory Disclosure

pkluck may disclose personal data to competent authorities, courts, or regulators where required to do so by law, to respond to a lawful court order or government request, or to protect the rights, property, or safety of pkluck, its players, or the public. We will notify you of any such disclosure where legally permitted to do so.

6 International Data Transfers

pkluck's primary servers are located in secure, certified data centres. Some of our contracted service providers — including game studios, KYC providers, and cloud infrastructure partners — may process your data in jurisdictions outside Bangladesh. Where such transfers occur, pkluck ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that which would apply within Bangladesh, including the use of contractual data transfer agreements that impose obligations on the recipient equivalent to those that apply to pkluck.

If you would like further information about the safeguards in place for any specific international data transfer, please contact us at [email protected] with the subject line "International Transfer Enquiry".

7 Data Retention

pkluck retains your personal data for the periods set out in the table below. Where multiple retention periods may apply to the same data category, the longer period takes precedence. After the applicable retention period has elapsed, data is securely deleted or anonymised so that it can no longer be associated with you.

Where your account is subject to a self-exclusion order or has been suspended pending investigation, data retention periods may be extended as necessary to support the administration of those processes.

8 Your Rights

Subject to applicable law and certain limited exceptions, you have the following rights in respect of the personal data pkluck holds about you:

• Right of Access: You may request a copy of all personal data pkluck holds about you. We will provide this within 30 days of a verified request, free of charge for the 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 or completed.
• Right to Erasure: In certain circumstances — such as where data is no longer necessary for the purpose for which it was collected — you may request that pkluck delete your personal data. This right is subject to our legal obligations to retain data for specified periods (see Section 7).
• Right to Restriction: You may request that pkluck restrict the processing of your personal data in certain situations, such as while the accuracy of data is being contested.
• Right to Data Portability: You may request that personal data you have provided to pkluck be transmitted to you or to another controller in a structured, machine-readable format, where technically feasible.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling. pkluck will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Rights Request". We may need to verify your identity before processing the request. We will respond within 30 days; if additional time is required, we will notify you within the initial 30-day period.

9 Cookies & Tracking Technologies

pkluck uses cookies — small text files stored on your device — and similar tracking technologies to operate and improve the platform. We do not use third-party advertising cookies or track your activity across unrelated websites.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These include session management cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
• Performance and Analytics Cookies: Used to measure how players interact with the platform — pages visited, session duration, error rates — so that we can identify and address performance issues. Data collected is aggregated and does not identify individual users by name.
• Functional Cookies: Remember your preferences such as language settings and preferred payment method to provide a more personalised experience on return visits.
• Fraud Prevention Cookies: Used to detect and prevent suspicious activity including automated bot traffic, account takeover attempts, and multi-accounting behaviour.

9.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies; however, disabling strictly necessary cookies will prevent you from using the pkluck platform. Instructions for managing cookies in the most common browsers are available via each browser's help documentation. Your cookie preferences (for non-essential cookies) can also be updated at any time via the privacy preferences panel accessible from the platform footer.

10 Children's Privacy

The pkluck platform is strictly intended for adults aged 18 years and over. pkluck does not knowingly collect personal data from individuals under the age of 18. If pkluck becomes aware that personal data has been collected from a person under 18, that account will be closed immediately, all funds will be returned to the verified payment source, and all associated personal data will be deleted as soon as practicable.

Parents and guardians are encouraged to use parental control software to restrict access to gambling websites where minors may have access to devices used by adults. If you believe a minor has opened or used a pkluck account, please contact us immediately at [email protected].

11 Data Security

pkluck implements a layered, defence-in-depth approach to information security. The technical and organisational measures in place to protect your personal data include:

• 256-bit SSL/TLS encryption for all data in transit between your device and pkluck's servers.
• AES-256 encryption for personal data and financial records stored in pkluck's databases.
• Two-factor authentication (2FA) available to all players for account access and withdrawal requests.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need.
• 24/7 automated security monitoring with real-time alerting for anomalous access patterns.
• Regular staff training on data protection obligations and information security best practices.

Despite these measures, no online platform can guarantee absolute security against all possible threats. In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, pkluck will notify affected individuals without undue delay and take all reasonable steps to contain and remediate the breach.

12 Marketing Communications

pkluck may send you promotional communications — including bonus offers, new game announcements, tournament invitations, and seasonal promotions relevant to the Bangladesh market — via SMS, email, or in-platform notifications. Marketing communications are sent only where:

• You have explicitly opted in to receive such communications during or after registration, or
• You are an existing player and pkluck has a legitimate interest in informing you about directly relevant offers, and you have not opted out.

You may opt out of marketing communications at any time by clicking the "Unsubscribe" link in any marketing email, adjusting your notification preferences in your account dashboard, or by submitting a written opt-out request to [email protected]. Opting out of marketing communications will not affect your ability to receive transactional or account-related notifications, which are necessary for the operation of your account.

pkluck will never send unsolicited marketing messages via WhatsApp, Telegram, or other third-party messaging platforms to numbers not registered to your pkluck account. If you receive a message purportedly from pkluck on an unregistered channel, please treat it as suspicious and report it to our support team.

13 Changes to This Privacy Policy

pkluck may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or platform services. Where changes are material — meaning they affect the way in which we process your personal data in a manner that could meaningfully impact your rights — we will provide advance notice via email to your registered address and/or via a prominent notice on the pkluck platform, at least 7 days before the changes take effect.

For minor or administrative updates that do not affect the substance of how your data is processed, we will update the "Last Updated" date at the top of this policy without advance notice. We encourage you to review this Privacy Policy periodically. The most current version will always be available at pkluck.vu/privacy-policy.

Your continued use of the pkluck platform after the effective date of any update to this Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with the updated Privacy Policy, you may close your account by contacting our support team.

14 Contact & Complaints

For any questions, concerns, or requests related to this Privacy Policy or the way pkluck handles your personal data, please contact our Data Protection team using the details below:

• Email: [email protected] — include "Privacy Request" or "Data Rights Request" in the subject line.
• Response Time: We aim to acknowledge all privacy-related enquiries within 48 hours and to provide a substantive response within 30 days of receipt of a verified request.
• Complaint Escalation: If you are not satisfied with our response to a privacy complaint, you may escalate the matter to the competent data protection supervisory authority in your jurisdiction.