Privacy Policy

This Privacy Policy ("Policy") is issued by lick33 ("lick33", "we", "us", "our", "the Platform", "the Operator") and governs the collection, processing, storage, transfer and protection of personal data relating to all individuals ("User", "you", "your") who access or use the lick33 website at https://lick33.cam and all associated services, features and content.

lick33 is committed to handling personal data with transparency, integrity and respect for user privacy. This Policy is designed to inform you clearly and accurately about what data we hold, why we hold it, how it is used, and what rights you have in relation to it. We do not use personal data for purposes beyond those described in this Policy without your consent or a legitimate legal basis.

By accessing the lick33 Platform, registering an account or submitting any personal information, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read together with our Terms & Conditions and our Responsible Gambling Policy.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person — including but not limited to name, email address, date of birth, financial data, device identifiers and location data.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, storage, use, disclosure, transfer or deletion.
• "Data Controller" means lick33, as the entity that determines the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means any third-party service provider engaged by lick33 to process Personal Data on its behalf, in accordance with written data processing agreements.
• "KYC" means Know Your Customer — the identity verification process through which lick33 verifies a User's identity, age and payment credentials.
• "AML" means Anti-Money Laundering — the legal framework and internal policies under which lick33 monitors transactions for suspicious activity and reports where required.
• "Cookie" means a small text file placed on your device by the Platform for the purposes of session management, analytics or user preference storage.
• "Sensitive Personal Data" means a sub-category of Personal Data warranting higher protection, including financial account details, identity document numbers and biometric data.

lick33 collects Personal Data across the following categories, depending on your interaction with the Platform:

lick33 collects Personal Data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC verification, submitting a support request or updating your account profile.
• Transaction processing: Data generated automatically when you make a deposit or withdrawal through the Cashier, including payment method identifiers and transaction amounts.
• Platform activity: Data generated as you use the Platform — placing bets, playing games, claiming bonuses and interacting with account settings.
• Technical collection: Data collected automatically from your device and browser, including IP address, session logs and cookie data, as described further in Section 10.
• Third-party sources: In limited cases, lick33 may receive data from authorised identity verification providers, fraud detection services or payment processors as part of the KYC/AML process.

lick33 processes your Personal Data for the following specific purposes:

To create, maintain and administer your lick33 account, including verifying your identity, managing your balance and processing your account settings and preferences.

To process deposits and withdrawals through your selected payment method, reconcile transaction records and manage any payment disputes. This includes reference to payment services familiar to Pakistani users, such as bank transfers via HBL, UBL, Meezan Bank and Bank Alfalah, and mobile wallet channels. Note that these providers operate independently and their use of your data is governed by their own privacy policies.

To verify your identity and age prior to processing withdrawals, to conduct transaction monitoring for suspicious activity in compliance with anti-money-laundering obligations, and to fulfil any regulatory reporting requirements imposed by the operator's licensing jurisdiction.

To monitor betting activity against responsible gambling parameters, to administer deposit limits, loss limits, cooling-off periods and self-exclusion tools you have set, and to identify patterns that may indicate gambling-related harm requiring intervention.

To detect and prevent unauthorised access to your account, to identify fraudulent transactions, to enforce single-account policies and to protect the integrity of the Platform against cheating, collusion or abuse.

To respond to your queries, resolve disputes, process responsible gambling requests, and improve the quality of our support service through interaction review and training.

To analyse aggregated and anonymised usage data for the purpose of improving Platform performance, user interface design, feature development and content personalisation — where such processing is based on your consent or on lick33's legitimate interests and does not involve sharing identifiable data.

Where you have explicitly consented to receive promotional communications from lick33, we may use your email address to send relevant offers, promotions and platform news. You may withdraw marketing consent at any time by following the unsubscribe instructions in any marketing email or by contacting support.

lick33 processes Personal Data on one or more of the following legal bases, as applicable to each processing activity:

• Contractual Necessity: Processing required to perform the contract between you and lick33 — including account creation, transaction processing and service delivery.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC verification, AML monitoring and mandatory record-keeping.
• Legitimate Interests: Processing carried out in pursuit of lick33's legitimate business interests, such as fraud prevention, security monitoring, platform improvement and responsible gambling intervention — provided these interests are not overridden by your privacy rights.
• Consent: Processing carried out on the basis of your explicit, informed and freely given consent — specifically in relation to marketing communications and non-essential cookies. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

lick33 does not sell, rent or commercially trade your Personal Data to any third party. We share Personal Data only in the following limited and necessary circumstances:

lick33 engages authorised third-party processors to assist with platform operations — including payment processing, identity verification, fraud detection, cloud hosting and customer support tooling. These processors are bound by written data processing agreements and may only process your data on lick33's instructions and for the purposes specified in those agreements.

KYC identity checks may be conducted through authorised third-party verification services. These services receive the minimum personal data necessary for verification purposes and are governed by their own privacy and data retention policies.

Financial transaction data is shared with the relevant payment processor in order to execute your deposit or withdrawal request. This may include processors facilitating bank transfers or other payment methods available in the Cashier. Each processor operates under its own privacy and data handling framework, which is independent of lick33's control.

lick33 may disclose Personal Data to competent legal or regulatory authorities where required to do so by law, court order or binding regulatory request — including in the context of AML reporting obligations. We will notify you of any such disclosure where permitted by applicable law to do so.

In the event of a merger, acquisition or sale of assets involving lick33, Personal Data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and your data will continue to be processed in accordance with this Privacy Policy or a materially equivalent policy.

The lick33 Platform and its supporting infrastructure may be hosted in and processed from jurisdictions outside Pakistan. By registering and using the Platform, you acknowledge and consent to the transfer of your Personal Data to countries outside Pakistan for the purposes described in this Policy.

Where such transfers occur, lick33 takes reasonable steps to ensure that appropriate safeguards are in place — including contractual protections with service providers — to maintain an equivalent level of data protection to that described in this Policy.

lick33 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal obligations. The following general retention principles apply:

• Account Data: Retained for the duration of your active account relationship with lick33 and for a defined period thereafter (typically a minimum of five years following account closure, or longer where legally required) in order to fulfil AML, fraud prevention and dispute resolution obligations.
• KYC Documents: Retained for the period required by applicable AML and regulatory obligations, which may extend beyond account closure. These documents are stored securely and access is restricted to authorised compliance personnel.
• Transaction Records: Financial transaction records are retained for a minimum period as required by applicable legal and tax obligations in the operator's jurisdiction.
• Support & Communications Data: Retained for a period sufficient for quality assurance, dispute resolution and potential legal proceedings — typically a minimum of two years from the date of the last communication.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications, at which point your data is removed from active marketing lists promptly.
• Cookie & Analytics Data: Session cookies expire at the end of your browser session. Persistent analytics data is retained in accordance with the applicable cookie policy of the analytics service used.

lick33 uses cookies and similar technologies to ensure the Platform functions correctly, to improve your user experience, and — where you have consented — to analyse usage patterns and support relevant promotional communications. A cookie is a small text file stored on your device by your browser when you visit the Platform.

• Essential Cookies: Required for the Platform to function — including session management (keeping you logged in), load balancing and security tokens. These cookies cannot be disabled without affecting the operation of the Platform.
• Analytical Cookies: Used to understand how Users interact with the Platform in aggregate — including which pages are visited most frequently, where users navigate from and how long sessions last. This data is anonymised and used to improve Platform design and performance.
• Preference Cookies: Store user preferences such as language settings, display options and responsible gambling tool configurations to provide a personalised experience across sessions.
• Marketing & Attribution Cookies: Used only where you have provided explicit consent. These cookies may track your journey from an advertising source to lick33 registration and are used to measure the effectiveness of promotional campaigns. They do not collect sensitive personal or financial data.

You may manage your cookie preferences through your browser settings at any time. Most modern browsers allow you to block, delete or restrict cookies. Note that disabling essential cookies may prevent the Platform from functioning correctly. Withdrawing consent from non-essential cookies will not affect any previously collected data.

Subject to applicable law and any overriding legal obligations, you have the following rights in relation to your Personal Data held by lick33. To exercise any of these rights, contact us using the details provided in Section 16.

lick33 will respond to rights requests within a reasonable period and no later than thirty (30) days from receipt. We may request verification of your identity before processing a rights request.

lick33 implements appropriate technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

• Transport Encryption: All data transmissions between your device and lick33 servers are encrypted using TLS/SSL protocols, preventing interception of data in transit.
• Access Controls: Internal access to Personal Data is restricted to authorised personnel on a need-to-know basis. All internal access is subject to authentication and logging.
• Two-Factor Authentication (2FA): Available to all Users as an additional layer of account security. We strongly recommend enabling 2FA on your lick33 account.
• Data Storage Security: Personal Data is stored in secure environments with appropriate physical and logical access controls. KYC documents and financial records receive heightened security classification.
• Fraud Detection Systems: Automated monitoring tools operate continuously to detect anomalous account activity, unusual transaction patterns and unauthorised login attempts.
• Incident Response: lick33 maintains a data breach response procedure. In the event of a security incident affecting your Personal Data, we will notify affected Users and relevant authorities as required by applicable law.

lick33 is strictly an adults-only platform. Access and registration are prohibited for any individual under the age of 18, or the higher minimum age required by the applicable operator/license jurisdiction. lick33 does not knowingly collect Personal Data from minors.

Where lick33 becomes aware that Personal Data has been submitted by a minor — whether through a false declaration of age during registration or any other means — the relevant account will be suspended immediately, the data will be deleted from active systems and any funds in the account will be handled in accordance with our Terms & Conditions and applicable legal obligations.

If you are a parent or guardian and believe that a minor in your care has registered on lick33, please contact us immediately using the contact details in Section 16 so that we can take appropriate action without delay.

lick33 acknowledges that a significant portion of its users are located in Pakistan, including cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. The following additional notes are relevant to Pakistani users in respect of data privacy and applicable law:

lick33 does not operate under the oversight of the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, or any other Pakistani governmental or quasi-governmental regulatory body. This Privacy Policy is not governed by Pakistani data protection legislation. Pakistani users acknowledge this when registering an account.

Where Pakistani users initiate transactions through locally familiar payment services such as Easypaisa, JazzCash, Raast, or bank transfers via HBL, UBL, Meezan Bank or Bank Alfalah, any data shared with those providers in the course of the transaction is subject to the relevant provider's own privacy policies. lick33 does not control how payment providers use transaction data on their own systems. Payment provider names referenced on this Platform are for user reference only and do not imply endorsement, partnership or affiliation with lick33.

Pakistani users are solely responsible for understanding and complying with all applicable laws governing online gambling and data privacy in Pakistan. This Policy does not constitute legal advice. Users with concerns about the application of local privacy laws to their use of lick33 are encouraged to seek independent legal counsel.

lick33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. When material changes are made, we will notify registered Users by posting a notice on the Platform and/or by sending an email to the address registered to your account.

The date on which this Policy was last updated is displayed at the top of this document. We encourage you to review this Policy periodically to stay informed about how we handle your Personal Data. Continued use of the lick33 Platform following publication of a revised Privacy Policy constitutes your acceptance of those changes.

For all privacy-related enquiries, data subject rights requests, or complaints regarding the handling of your Personal Data, please contact the lick33 Data & Privacy team using the details below. Our support team is available 24/7 and provides assistance in both English and Urdu.

Email Support (plain text — not a clickable link):

[email protected]

Live Chat Support: Available 24/7 directly within the lick33 Platform. This is the fastest channel for urgent account or privacy concerns.

Languages Available: English and Urdu.

Response Time Target: We aim to acknowledge all privacy requests within 5 business days and to resolve them fully within 30 days. Complex requests may take longer, in which case we will communicate an updated timeline.