Privacy Policy — How picluck Protects Your Data

picluck collects personal data through several channels, including the account registration form, the identity verification (KYC) process, payment transactions, platform usage, and direct communications between you and our support team. The categories of personal information we may collect are described below.

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, or biometric data for the purpose of uniquely identifying an individual. In the rare event that such data appears incidentally within submitted documents, it is not processed for any secondary purpose.

Where you provide personal data relating to a third party (for example, when reporting a dispute involving another player), you represent and warrant that you have the right to share that information and that the relevant individual is aware that their data will be processed by picluck for the stated purpose.

picluck processes your personal data only where a valid lawful basis exists. The primary legal bases we rely upon are: (a) the performance of our contract with you as a registered player; (b) compliance with our legal and regulatory obligations; (c) our legitimate interests in operating a secure, fair, and commercially viable platform; and (d) your explicit consent, where separately obtained.

The specific purposes for which we use your personal data include, but are not limited to, the following:

• Account creation and management: To register your account, verify your identity, maintain your player profile, and manage your session securely across devices.
• Service delivery: To provide access to the full picluck game library including cricket betting, live casino, slots, Pool Rummy, Ludo Quick, and all other platform features.
• Payment processing: To facilitate deposits via bKash, Nagad, Rocket, Upay, and DBBL, and to process withdrawal requests to your designated payment method.
• Identity verification and fraud prevention: To conduct KYC checks, verify your age, screen against self-exclusion registers, and detect and prevent fraudulent activity, money laundering, and multi-accounting.
• Responsible gaming: To monitor betting patterns that may indicate problematic gambling behaviour, to apply player-requested deposit limits or self-exclusion periods, and to provide timely responsible gaming interventions.
• Customer support: To respond to your enquiries, resolve disputes, manage complaints, and maintain a record of support interactions for quality assurance and training purposes.
• Promotions and VIP programme: To administer bonus offers, cashback credits, VIP tier progression, and exclusive Black Diamond programme benefits for eligible players — where you have opted in to receive such communications.
• Platform security and integrity: To monitor platform activity for unauthorised access attempts, unusual betting patterns, technical vulnerabilities, and other threats to the security of the platform and its player community.
• Analytics and improvement: To analyse aggregated usage data to improve platform performance, enhance game selection, and optimise the user experience for players across Bangladesh including Dhaka, Chittagong, Sylhet, and other regions.
• Legal compliance: To fulfil our obligations under applicable laws, to respond to lawful requests from competent authorities, and to establish, exercise, or defend legal claims.

picluck does not sell your personal data to third parties. However, to deliver our Services effectively and to comply with our legal obligations, we do share certain categories of personal data with carefully selected third-party organisations operating as data processors or independent data controllers, as described below.

• Identity verification providers: We share identity documents and personal details with accredited KYC and anti-money laundering (AML) screening services to verify your identity and age, and to screen against known fraud and sanctions databases. These providers process data strictly under contract and are prohibited from using it for any secondary purpose.
• Payment processors: Transaction data is shared with payment service providers including bKash, Nagad, Rocket, Upay, and Dutch-Bangla Bank Limited (DBBL) to facilitate deposits and withdrawals. Each payment provider operates under its own privacy policy and processes only the minimum data necessary to execute the transaction.
• Game software providers: When you access games supplied by third-party studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Ezugi, certain technical and session data (such as your player session token and bet history) is shared with those providers to operate the game engine. These providers do not receive your full identity data.
• IT infrastructure and cloud services: We use third-party cloud hosting and infrastructure services to store data securely. All such providers are bound by strict data processing agreements, and data at rest is encrypted in accordance with industry standards.
• Analytics platforms: Aggregated and anonymised usage data may be shared with analytics service providers to help us understand platform performance. This data does not identify you as an individual.
• Legal and regulatory authorities: We may disclose personal data to law enforcement, courts, regulators, or other competent public authorities where required to do so by applicable law, court order, or to protect the rights, property, or safety of picluck, its players, or the public.

All third-party data processors engaged by picluck are required to process personal data only on documented instructions from picluck, to maintain appropriate technical and organisational security measures, and to assist picluck in fulfilling its obligations in response to player privacy rights requests. picluck remains responsible for ensuring that all third-party processing meets the standard described in this Privacy Policy.

picluck uses cookies and similar tracking technologies — including pixel tags, local storage objects, and session identifiers — to operate the platform, maintain your logged-in session, remember your preferences, and gather analytics data about how players interact with our Services.

The following categories of cookies are used on the picluck platform:

Most web browsers allow you to manage your cookie preferences through the browser settings menu. You may choose to block or delete cookies at any time; however, disabling strictly necessary cookies will prevent you from logging in and using core platform features. Disabling functional or analytics cookies may affect personalisation and platform improvements but will not prevent you from placing wagers or making transactions.

picluck does not use cookies to deliver third-party advertising targeting on this platform. Analytics cookies used on our platform are processed in aggregated form and do not identify you personally in any analytical reporting.

picluck implements a layered approach to data security, combining technical controls, procedural safeguards, and staff training to protect personal data against unauthorised access, accidental loss, destruction, or disclosure.

Our primary technical security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• AES-256 encryption for sensitive personal and financial data stored on our databases.
• Multi-factor authentication (MFA) options for player accounts to reduce the risk of unauthorised access.
• Firewalls and intrusion detection systems continuously monitoring platform infrastructure for anomalous activity.
• Access controls restricting access to personal data to authorised staff members who require it to perform specific job functions, operating on a principle of least privilege.
• Regular penetration testing and security audits conducted by independent technical specialists to identify and remediate vulnerabilities before they can be exploited.
• Secure data centres with physical access controls, CCTV monitoring, and environmental protection measures.

Despite these measures, no system connected to the internet can guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, picluck will notify you without undue delay via your registered email address, and will take immediate steps to contain and investigate the breach.

Data Retention

picluck retains personal data for the periods set out below. Once a retention period expires and no overriding legal obligation requires continued retention, data is securely deleted or anonymised.

As a registered player on the picluck platform, you have the following rights in respect of your personal data. These rights may be subject to certain limitations where picluck has a legal obligation to retain or process the data, or where exercising the right would adversely affect the rights of a third party.

• Right of access: You have the right to request a copy of the personal data we hold about you, together with information about how and why it is being processed. We will respond to verified access requests within 30 days.
• 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. You may also update many data fields directly through your account profile settings.
• Right to erasure: You may request that we delete your personal data in certain circumstances — for example, if the data is no longer necessary for the purpose for which it was collected, or if you withdraw consent and no other legal basis applies. Note that we may be required to retain certain data for legal compliance purposes even following an erasure request.
• Right to restriction of processing: You may request that we restrict the processing of your personal data in certain circumstances, for example while the accuracy of the data is being contested, or while a legitimate interests objection is being assessed.
• Right to data portability: Where processing is based on consent or contract and carried out by automated means, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing based on legitimate interests, including profiling. You also have an absolute right to object to the processing of your data for direct marketing purposes, which we will action immediately upon receipt.
• Right to withdraw consent: Where processing is based on your consent (such as receiving marketing communications), you may withdraw that consent at any time through your account settings or by contacting support. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
• Right not to be subject to solely automated decisions: As noted in Section 2, you have the right to request human review of any automated decision that produces a significant effect on your account status, bonus eligibility, or withdrawal access.

picluck operates a strict 18+ only policy across all Services. Our platform is not intended for, directed at, or designed to attract individuals under the age of 18. We do not knowingly collect personal data from children or minors.

Age verification is a mandatory step in the account registration and KYC process. Every player is required to provide a valid government-issued photo identification document confirming that they are at least 18 years of age before deposits, withdrawals, or bonus claims are approved. Players who cannot demonstrate they meet the minimum age requirement will have their accounts suspended and any deposits returned in accordance with our responsible gaming procedures.

We strongly encourage parents and guardians to make use of parental control software and browser-level filtering tools to restrict minors' access to online gambling platforms. A range of free parental control tools are available for most devices and operating systems. picluck is not liable for access by minors that occurs as a result of misuse of a parent's or guardian's registered account.

If any personal data relating to a minor is found to have been collected inadvertently, it will be deleted immediately upon discovery, and the associated account will be closed. Any funds deposited by a minor will be handled in accordance with our responsible gaming and account closure procedures.

picluck reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, to comply with new legal or regulatory requirements, or to account for new platform features and services. All revisions will be published on this page with an updated "Last Updated" date at the top of the document.

Where a change to this Privacy Policy is material — meaning it significantly affects how we collect, use, or share your personal data — we will provide advance notice via the email address registered to your account and/or via a prominent notice displayed on the picluck platform homepage. We will give you a minimum of 14 days' notice before any material change takes effect.

Your continued use of the picluck platform after any published Privacy Policy update constitutes your acknowledgement of the revised terms. If you do not agree with any change to this Privacy Policy, you should cease using the Services and contact support at support@picluck to request account closure.

This Privacy Policy is written in English and the English version is the authoritative version for all interpretive purposes. If any translation is provided for reference, the English text shall prevail in the event of any inconsistency.