lock33 Privacy Policy

1 Who We Are

lock33 is Pakistan's premier online casino and sports betting platform, accessible at lock33.app. In this Privacy Policy, references to "lock33", "we", "us", or "our" refer to the operator of the lock33 platform and all associated digital services.

lock33 acts as the data controller in respect of the personal information you provide when registering an Account, making deposits and withdrawals, placing wagers, accessing customer support, or interacting with the platform in any other way. As data controller, lock33 determines the purposes and means by which your personal data is processed and is responsible for ensuring that processing is carried out lawfully, fairly, and transparently.

For all privacy-related enquiries, requests, and complaints, you may contact lock33 at: [email protected]

2 Data We Collect

lock33 collects personal data across several categories, depending on the nature of your interaction with the platform. The categories of personal data we may hold about you include the following:

lock33 does not collect or process special category data (such as health data, biometric data, or data revealing racial or ethnic origin) except where strictly required for the fulfilment of Responsible Gaming obligations — for example, where a player discloses a gambling-related health condition in connection with a self-exclusion request.

3 How We Collect Your Data

lock33 collects personal data through the following channels and mechanisms:

• Direct interactions: Data you provide when completing the lock33 registration form, updating your Account profile, making a deposit or withdrawal, contacting customer support, or responding to surveys and promotions.
• Automated technologies: Technical and usage data collected automatically via cookies, server logs, and similar tracking technologies each time you access or use the lock33 platform. This includes data collected during every lock33 Login session.
• Third-party sources: Identity and financial verification data received from KYC service providers, payment processors (such as JazzCash and EasyPaisa), fraud prevention agencies, and credit reference agencies where lawfully permitted.
• Publicly available sources: In limited circumstances, lock33 may supplement Account data with information obtained from publicly available registers or databases as part of our anti-money laundering due diligence obligations.

4 Lawful Basis for Processing

Every processing activity carried out by lock33 is supported by one or more lawful bases under applicable data protection law. The primary lawful bases we rely on are as follows:

1. Contractual necessity: The majority of lock33's processing activities are necessary for the performance of the contract between you and lock33 — i.e., to operate your Account, process transactions, and deliver the gaming services you have requested.
2. Legal obligation: lock33 is required by its licensing conditions and applicable law to carry out KYC verification, maintain transaction records, and report certain activities to regulatory authorities. Processing for these purposes is mandatory and cannot be opted out of.
3. Legitimate interests: lock33 processes certain technical and usage data on the basis of our legitimate interest in maintaining platform security, detecting fraud and abuse, improving the quality of our services, and conducting responsible gaming monitoring. We have assessed that these legitimate interests are not overridden by your rights and freedoms in respect of this processing.
4. Consent: Where lock33 sends you direct marketing communications or deploys non-essential cookies, we do so on the basis of your consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 How We Use Your Data

lock33 uses the personal data it collects for the following purposes:

• Account registration and management: To create, verify, and maintain your lock33 Account, including processing your lock33 Login credentials securely.
• Service delivery: To provide access to casino games, sports betting markets, live dealer games, slots, cricket betting, virtual sports, and all other lock33 services.
• Payment processing: To process PKR deposits via JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, and to process withdrawal requests to verified payment methods.
• Identity and age verification: To confirm that you are at least 21 years of age and to verify your identity as required by our licensing obligations. lock33 is a strictly adult platform and age verification is a non-negotiable legal requirement.
• Anti-money laundering compliance: To monitor transactions for suspicious activity and to fulfil our reporting obligations to relevant regulatory authorities.
• Responsible Gaming: To monitor for indicators of problem gambling behaviour, to enforce deposit and loss limits you have set, to process self-exclusion requests, and to comply with player protection obligations under our licence.
• Customer support: To respond to your enquiries, complaints, and requests through our 24/7 English and Urdu support service.
• Platform improvement: To analyse usage patterns and player behaviour in aggregate in order to improve the lock33 platform, fix technical issues, and enhance the overall player experience.
• Fraud prevention and security: To detect and prevent cheating, bonus abuse, multi-accounting, and other forms of fraud or prohibited conduct as defined in the lock33 Terms & Conditions.
• Marketing communications: To send you promotional offers, bonus notifications, and platform news where you have given consent to receive such communications. You may unsubscribe at any time.

6 Sharing Your Data

lock33 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following limited and controlled circumstances:

• Licensed game providers: Providers such as Evolution Gaming and Pragmatic Play receive limited technical data (such as session tokens and bet data) necessary to deliver their games within the lock33 platform. These providers are bound by strict contractual data protection obligations.
• Payment processors: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank receive the financial and identity data necessary to process your deposit and withdrawal transactions. Each provider operates under its own applicable data protection and banking regulations.
• KYC and identity verification providers: Third-party KYC service providers receive identity documents and verification data solely for the purpose of fulfilling our age and identity verification obligations.
• Fraud prevention and AML agencies: Where required for the prevention of fraud or money laundering, lock33 may share data with recognised fraud prevention agencies or report suspicious activity to relevant regulatory or law enforcement authorities.
• Regulatory and licensing authorities: lock33 is obligated to provide certain Account and transaction data to its licensing authority upon request. Such disclosures are made in strict accordance with our licensing conditions.
• Professional advisers: Lawyers, auditors, and insurers acting as service providers to lock33 may access limited personal data in the course of providing their services, subject to confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or transfer of all or part of lock33's business, personal data may be transferred to the acquiring entity as part of that transaction, subject to the same or equivalent data protection standards.

7 International Data Transfers

The lock33 platform operates across international infrastructure and some of our third-party service providers — including game studios and technology partners — may process data in jurisdictions outside of your country of residence. Where personal data is transferred internationally, lock33 ensures that appropriate safeguards are in place to protect that data to an equivalent standard as required under applicable data protection law.

Safeguards for international transfers may include:

• Standard contractual clauses approved by the relevant data protection authority.
• Transfers to jurisdictions that have been recognised as providing an adequate level of data protection.
• Binding corporate rules where applicable.

You may request details of the specific transfer mechanisms in place for any particular processing activity by contacting the lock33 support team at the address provided in Section 14.

8 Data Retention

lock33 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law and licensing conditions. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that ensures it can no longer be linked to any identifiable individual.

9 Cookies and Tracking Technologies

lock33 uses cookies and similar tracking technologies on the platform. A cookie is a small text file placed on your device by our web server when you visit the platform. Cookies allow lock33 to recognise your device, maintain your session state, and collect usage data.

The categories of cookies used by lock33 are as follows:

• Strictly necessary cookies: Essential for the platform to function. These cookies maintain your logged-in session after lock33 Login, protect against cross-site request forgery, and enable core gaming functionality. They cannot be disabled without breaking the platform.
• Analytical cookies: Used to collect aggregated, anonymised data about how players navigate the platform — which pages are visited most often, where players encounter errors, and how game sessions are initiated. This data helps lock33 improve the platform experience for all users.
• Functional cookies: Used to remember your platform preferences, such as language settings and display options, so you do not have to re-enter them each time you log in.
• Marketing cookies: Only deployed where you have provided explicit consent. Used to deliver promotional communications relevant to your interests and to measure the effectiveness of lock33 marketing campaigns.

You can manage or disable non-essential cookies at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the lock33 platform. Most modern browsers provide guidance on cookie management in their help documentation.

10 Your Rights

Subject to applicable data protection law and certain limitations arising from our legal and licensing obligations, you have the following rights in respect of the personal data that lock33 holds about you:

1. Right of access: You may request a copy of the personal data lock33 holds about you, together with information about how it is processed. lock33 will respond to subject access requests within 30 days of receipt.
2. Right to rectification: You may request that lock33 correct any inaccurate or incomplete personal data held in your Account or elsewhere in our records.
3. Right to erasure: In certain circumstances, you may request that lock33 delete your personal data. This right is subject to limitations where lock33 is required to retain data for legal, regulatory, or licensing reasons — including the retention periods set out in Section 8.
4. Right to restrict processing: You may request that lock33 suspend certain processing activities — for example, while the accuracy of data is contested — without requiring full deletion.
5. Right to data portability: Where processing is carried out on the basis of your consent or on the basis of contractual necessity, you may request that lock33 provide your personal data to you in a structured, commonly used, machine-readable format.
6. Right to object: You may object to processing carried out on the basis of lock33's legitimate interests, and to the use of your personal data for direct marketing purposes at any time.
7. Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

11 Children and Minors

lock33 is strictly an adult platform. Access to and use of lock33 services is prohibited for any person under the age of 21. lock33 does not knowingly collect personal data from individuals under 21 years of age.

Where lock33 discovers or is notified that personal data belonging to a person under 21 has been collected — whether as a result of age falsification during registration or any other reason — that Account will be immediately suspended, all Funds will be withheld pending investigation, and the personal data in question will be deleted in accordance with our data minimisation obligations, subject to any overriding regulatory requirements.

Parents or guardians who believe that a minor has registered or used a lock33 Account should contact our support team immediately. lock33 takes underage gambling extremely seriously and cooperates fully with any investigation in this regard.

12 Security Measures

lock33 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption: All data transmitted between your device and lock33 servers is encrypted using 256-bit SSL/TLS protocols, including during every lock33 Login session.
• Password hashing: Account passwords are stored using industry-standard one-way cryptographic hashing algorithms. lock33 staff cannot view your password in plain text under any circumstances.
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis. lock33 staff members are granted access only to the data necessary for the performance of their specific role.
• Intrusion detection and monitoring: lock33's infrastructure is monitored continuously for suspicious activity, unauthorised access attempts, and anomalous behaviour patterns.
• Regular security audits: lock33 conducts periodic security assessments and penetration testing to identify and address potential vulnerabilities before they can be exploited.
• Data processor vetting: All third-party data processors are assessed for security competence before engagement and are subject to ongoing review.

While lock33 takes all reasonable steps to protect your data, no online platform can guarantee absolute security against all possible threats. You are responsible for maintaining the confidentiality of your lock33 Login credentials and for ensuring the security of the device from which you access the platform. lock33 will never ask you to provide your password via email or customer support channels.

13 Changes to This Policy

lock33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or licensing requirements. When material changes are made, lock33 will notify active Account holders — typically by displaying a prominent notice on the platform or by sending an email to the address registered on your Account — prior to the updated Policy taking effect.

The date on which this Privacy Policy was last updated is displayed prominently at the top of this page. We encourage you to review this Policy periodically to remain informed about how lock33 protects your personal data. Your continued use of the lock33 platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes.

Previous versions of this Privacy Policy are available upon request from the lock33 support team.

14 Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or lock33's data processing practices, please contact our support team. Our 24/7 customer support service is available in both English and Urdu.

Support Email: [email protected]

When submitting a privacy-related request or complaint, please include your Account username, a clear description of your concern or the right you wish to exercise, and any relevant supporting information. lock33 will acknowledge receipt of your request within 5 business days and aims to resolve all privacy-related matters within 30 calendar days.

If you are not satisfied with lock33's response to your privacy complaint, you may have the right to lodge a complaint with the data protection supervisory authority applicable in your jurisdiction. Details of the relevant authority are available upon request from our support team.