Privacy Policy for pcluck

01 Data We Collect

pcluck collects personal data that you provide directly, data that is generated automatically as you interact with the platform, and — in limited circumstances — data obtained from trusted third-party sources for identity verification purposes. We collect only what is necessary to operate the platform safely, process transactions accurately, and meet our legal obligations.

Information You Provide Directly

When you register an account, complete identity verification, make a deposit or withdrawal, or contact our support team, you may provide some or all of the following:

• Identity data: Full legal name, date of birth, nationality, gender.
• Contact data: Email address, residential address (including district, city, and postal code in Bangladesh), and, where relevant, a mobile phone number.
• Document data: Copies of government-issued identification (National ID card, passport, or driving licence) and proof-of-address documents submitted during Know Your Customer (KYC) verification.
• Financial data: Mobile banking account numbers (bKash, Nagad, Rocket, Upay), bank account details (for Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank transfers), and card details (Visa, Mastercard) where applicable — stored only in tokenised or masked form.
• Support communications: The content of emails, chat transcripts, or any other messages you send to support@pcluck.net.

Data Generated Automatically

When you browse or use the pcluck platform, certain technical data is generated automatically by your device and our servers:

• Device & technical data: IP address, device type, operating system, browser type and version, screen resolution, and hardware identifiers.
• Usage data: Pages visited, game sessions initiated, bets placed, session duration, login timestamps, and feature interactions.
• Location data: General geographic location inferred from your IP address (country and city level). We do not collect precise GPS coordinates.
• Cookie and tracking data: See the Cookies & Tracking section below for full details.

Data from Third Parties

We may receive limited data about you from the following third-party sources where this is necessary to verify your identity or prevent fraud:

• Identity verification and anti-fraud service providers who cross-reference your submitted documents against public and proprietary databases.
• Payment processors and mobile financial service providers (bKash, Nagad, etc.) who confirm transaction status and account ownership.
• Responsible gaming databases maintained by industry bodies, used to check self-exclusion status before allowing account registration.

02 How We Use Your Data

pcluck uses the personal data described above for the following specific purposes. We do not use your data for any purpose incompatible with the original reason for collection without first obtaining your explicit consent.

Purpose	Data Categories Used	Legal Basis
Account registration and management	Identity, contact	Contract performance
Identity verification (KYC/AML)	Identity, document, financial	Legal obligation
Processing deposits and withdrawals	Financial, identity	Contract performance
Fraud detection and prevention	Technical, usage, financial	Legitimate interest
Customer support	Identity, contact, communications	Contract performance
Responsible gaming monitoring	Usage, financial	Legal obligation / legitimate interest
Platform analytics and improvement	Usage, technical, cookie	Legitimate interest
Promotional communications (opt-in)	Contact, usage	Consent
Legal and regulatory compliance	All categories as required	Legal obligation

Marketing Communications

pcluck will only send you promotional communications — including bonus offers, tournament announcements, seasonal promotions related to events such as BPL, IPL, Eid, or Pohela Boishakh — where you have given explicit opt-in consent at the time of registration or subsequently through your account settings. You may withdraw consent at any time by contacting support@pcluck.net. Withdrawal of marketing consent will not affect the lawfulness of processing that occurred before the withdrawal.

Automated Decision-Making

pcluck uses automated processes to detect fraud, flag unusual account activity, and identify potential problem gambling patterns. Where an automated process results in a decision that materially affects your account (such as a temporary suspension), you have the right to request a human review of that decision by contacting our support team. We will respond to such requests within 5 business days (BST, UTC+6).

03 Legal Basis for Processing

pcluck processes your personal data on the following legal grounds, each of which applies to specific processing activities as described in the table above:

Contract Performance

Processing is necessary to deliver the services you have signed up for under the pcluck Terms & Conditions. This includes account management, game access, and financial transaction processing. Without this data, we cannot provide you with a functional account.

Legal Obligation

Certain data processing activities are required by law — in particular, identity verification under anti-money laundering (AML) regulations, age verification to enforce the 18+ requirement, and record-keeping obligations. pcluck cannot waive these obligations, and refusal to provide the required data will result in account suspension.

Legitimate Interest

pcluck has a legitimate business interest in processing usage and technical data to maintain platform security, detect fraud, prevent bonus abuse, and improve the overall player experience. In each case, we have assessed that our legitimate interest is not overridden by your right to privacy, and we have taken proportionate steps to limit the scope of data processed.

Consent

For non-essential activities — primarily marketing communications and non-essential cookies — pcluck relies on your freely given, specific, and informed consent. Consent can be withdrawn at any time without detriment to your core account rights.

04 Cookies & Tracking Technologies

pcluck uses cookies and similar tracking technologies on its website to ensure the platform functions correctly, to understand how players navigate the site, and — where you have consented — to personalise your experience.

What Are Cookies?

Cookies are small text files stored on your device by your web browser when you visit a website. They allow the website to remember information about your visit — such as your preferred language, login session, or the contents of your game lobby preferences — making your next visit more efficient.

Types of Cookies Used by pcluck

• Strictly necessary cookies: These are essential for the platform to function. They manage your login session, maintain security tokens, prevent cross-site request forgery, and remember your cookie preferences. These cookies cannot be disabled without breaking core platform functionality.
• Performance and analytics cookies: These collect anonymised data about how players use the pcluck platform — which pages are visited most frequently, where users encounter errors, and how long sessions last. This data helps us optimise the platform. These cookies require your consent.
• Functional cookies: These remember your preferences — such as your preferred deposit method or notification settings — to provide a personalised experience. These cookies require your consent.
• Third-party game provider cookies: Some game providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) may set their own cookies within their game iframes. These cookies are governed by the respective provider's privacy policy. pcluck does not control these cookies but will list active third-party cookie providers in our Cookie Declaration, which is available on request.

Managing Cookies

You can control cookie permissions through your browser settings at any time. Most modern browsers allow you to block cookies, delete existing cookies, or receive a notification before a new cookie is stored. Please note that disabling strictly necessary cookies will impair core platform functionality, including the ability to maintain a logged-in session. For detailed instructions on managing cookies in your specific browser, refer to the browser's official help documentation.

Do Not Track

pcluck acknowledges Do Not Track (DNT) signals sent by your browser. Where a DNT signal is detected, we limit our analytics tracking to strictly necessary performance monitoring only and do not engage in cross-site tracking or third-party data sharing beyond what is required to process your transactions.

05 Data Sharing & Disclosure

pcluck shares your personal data with third parties only to the extent strictly necessary to operate the platform, meet legal obligations, or protect the safety and security of our players and the platform itself. We do not sell your data. The categories of recipients are as follows:

Service Providers

We engage trusted third-party service providers to perform specific functions on our behalf, including payment processing (bKash, Nagad, Rocket, Upay, Visa, Mastercard, and the listed bank partners), identity and document verification, fraud detection, customer support platform hosting, and cloud infrastructure services. These providers act as data processors under our instruction and are contractually bound to process your data solely for the purposes specified by pcluck, to implement appropriate security measures, and to delete or return your data upon termination of the service engagement.

Game Providers

Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive your anonymised Player ID and session data in order to operate their games correctly within the pcluck lobby. Full identity data is not shared with game providers. These studios are independent data controllers for the data they process in connection with their own platforms.

Legal & Regulatory Disclosure

pcluck may disclose personal data to government authorities, law enforcement agencies, financial intelligence units, or courts where required to do so by applicable law, by court order, or where disclosure is necessary to prevent, detect, or prosecute fraud, money laundering, or other criminal conduct. We will notify you of any such disclosure where we are legally permitted to do so.

Corporate Transactions

In the event of a merger, acquisition, or sale of all or a substantial portion of pcluck's assets, personal data held by pcluck may be transferred to the acquiring entity as part of that transaction. You will be notified by email and/or a prominent notice on the pcluck website prior to your data becoming subject to a different privacy policy as a result of any such transaction.

06 Data Retention

pcluck retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, subject to any longer retention period required by applicable law.

Active Accounts

For as long as your pcluck account remains active, we retain all data associated with your account — including identity documents, transaction history, and game session records — to provide our services and meet our ongoing legal obligations.

Closed Accounts

Following account closure (whether voluntary or by pcluck), we retain your personal data for a minimum period of five (5) years from the date of closure. This retention period reflects standard AML record-keeping requirements and the limitation period for potential legal claims. After this period, your data will be securely deleted or anonymised beyond re-identification.

Support & Communication Records

Customer support communications are retained for a period of three (3) years from the date of the last interaction, to allow continuity of service and to resolve any subsequent disputes arising from previous interactions.

Marketing Data

Where you have consented to marketing communications, your contact data and marketing preferences are retained until you withdraw consent. Upon withdrawal, your details are removed from marketing lists within 10 business days. A suppression record (noting that you opted out) is retained indefinitely to ensure we do not re-add you to marketing lists inadvertently.

07 Your Privacy Rights

As a user of the pcluck platform, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at support@pcluck.net with the subject line "Privacy Rights Request". We will acknowledge your request within 2 business days and respond substantively within 30 calendar days.

Right of Access

You have the right to request a copy of all personal data that pcluck holds about you, along with information about the purposes for which it is processed, the categories of data involved, and the recipients to whom it has been disclosed. This is commonly referred to as a Subject Access Request (SAR).

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 without undue delay. For changes to registered name or date of birth, documentary evidence will be required to prevent fraud.

Right to Erasure

You may request that pcluck delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent and no other legal basis applies, or where you object to processing and pcluck has no overriding legitimate interest. This right is subject to our legal obligation to retain records for AML and regulatory compliance purposes — data subject to a mandatory retention period cannot be deleted until that period expires.

Right to Restriction of Processing

You may request that pcluck restrict the processing of your data (i.e., store it but not actively use it) in circumstances including: while the accuracy of the data is being contested; where processing is unlawful but you prefer restriction to erasure; or where pcluck no longer needs the data but you require it for the establishment, exercise, or defence of legal claims.

Right to Data Portability

Where pcluck processes your data on the basis of contract or consent using automated means, you have the right to receive a copy of that data in a structured, commonly used, and machine-readable format (such as CSV or JSON), and to request that it be transmitted directly to another data controller where technically feasible.

Right to Object

You have the right to object to pcluck processing your data for direct marketing purposes at any time. You also have the right to object to processing carried out on the basis of legitimate interest, in which case pcluck will cease processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

08 Data Security

pcluck implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include but are not limited to:

• 256-bit SSL/TLS encryption applied to all data in transit between your device and pcluck's servers.
• Encryption at rest for sensitive stored data including identity documents and financial details.
• Access controls: Personal data is accessible only to pcluck staff who have a specific operational need for it, governed by role-based access policies and individual authentication requirements.
• Tokenisation of payment card numbers and mobile wallet identifiers so that full account numbers are never stored in plain text within pcluck's systems.
• Regular security assessments including penetration testing and vulnerability scanning conducted by qualified security professionals.
• Incident response procedures that enable rapid detection, containment, and notification in the event of a data breach.

Data Breach Notification

In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, pcluck will notify affected players without undue delay — and in any event within 72 hours of becoming aware of the breach — by email to your registered address. The notification will describe the nature of the breach, the categories of data affected, the likely consequences, and the steps pcluck has taken or proposes to take to address the breach and mitigate its effects.

Your Own Security Responsibilities

While pcluck takes every reasonable step to protect your data on our end, the security of your account also depends on actions you take. You are responsible for keeping your password confidential, logging out of your session on shared devices, and notifying pcluck immediately if you suspect any unauthorised access to your account. pcluck will never ask you for your password via email or chat.

Changes to This Privacy Policy

pcluck reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the structure of the platform. Material changes — those that substantially affect your rights or the way we use your data — will be communicated by email to your registered address and by a prominent notice on this page at least 14 days before they take effect. The effective date at the top of this page will be updated with each revision. Your continued use of the platform after the effective date of a revised policy constitutes your acknowledgement of the changes.

For any questions about this Privacy Policy or about the way pcluck handles your personal data, please contact us at support@pcluck.net. Our support team is available 24/7 in English and will respond within 4 hours (BST, UTC+6).