Privacy Policy
This Privacy Policy explains how 21Tech (LuckyPem) collects, uses, stores, shares, and protects personal data.
Effective Date: April 1, 2026
•Data Controller: 21Tech
•Contact: notification@pem.gg
1. Introduction
This Privacy Policy explains how 21Tech (LuckyPem, we, us) collects, uses, stores, shares, and protects personal data when you use LuckyPem services, including web, app, Telegram integrations, wallet/payment features, and related support channels. By using the Platform, you acknowledge this Privacy Policy.
2. Data We Collect
2.1 Account and Identity Data
- Name, username, profile information
- Date of birth or age-verification indicators
- Platform and external account identifiers
- Verification information required for account integrity and legal compliance
2.2 Contact Data
- Email address
- Phone number
- Support communications and complaint records
2.3 Authentication and Security Data
- Login timestamps, access logs, session metadata
- Device/browser/app metadata, IP-related telemetry
- Fraud, abuse, and risk scoring signals
2.4 Transaction and Wallet Data
- Deposit and withdrawal records
- Entry payments, winnings, refunds, and balance events
- Payment references and reconciliation status
2.5 Participation and Product Data
- Pool entries, results, prize outcomes
- Creator pool and syndicate activity
- Achievement and streak indicators
2.6 Compliance and Responsible Gaming Data
- Spending limits and self-exclusion preferences
- Account restrictions, interventions, and enforcement events
- Lawful reporting or authority request records
3. Sources of Data
We collect data:
- Directly from you
- From your use of Platform services
- From payment/banking and authentication partners
- From anti-fraud, compliance, and service providers
- From lawful authority communications
4. Purpose of Processing
We process personal data to:
- Register and manage accounts
- Authenticate users and secure access
- Operate entries, draws, payouts, wallet functions, and support
- Detect, prevent, and investigate fraud or abuse
- Enforce responsible gaming and safety controls
- Maintain legal, tax, audit, AML/CFT, and sanctions compliance
- Improve platform quality, analytics, and operational resilience
- Communicate service and legal notices
5. Legal Bases
Depending on jurisdiction and processing activity, legal bases may include:
- Performance of contract
- Compliance with legal obligations
- Legitimate interests (security, fraud prevention, product integrity)
- Consent, where required by law
6. Sensitive Data and Minimization
Where processing includes sensitive or high-risk data categories, 21Tech applies purpose limitation, access controls, retention controls, and least-privilege handling. We process only data reasonably required for legitimate operational, compliance, and legal purposes.
7. Data Sharing and Disclosure
We may share personal data with:
- Banking/payment partners, including DK Bank-related channels where relevant
- Identity and authentication partners
- Cloud hosting, analytics, security, messaging, and support vendors
- Professional advisors, auditors, and insurers
- Law enforcement, regulators, courts, and competent authorities where legally required
We do not sell personal data for third-party monetary gain.
8. International Transfers
Where data is transferred across borders, 21Tech implements safeguards required by applicable law, which may include contractual protections and security controls.
9. Data Retention
We retain personal data for durations necessary to:
- Deliver services and maintain user accounts
- Fulfill legal, tax, audit, AML/CFT, and regulatory obligations
- Resolve disputes and enforce rights
- Support fraud prevention and security investigations
Retention duration may vary by data category and legal requirement. Data no longer required is deleted, anonymized, or securely archived.
10. Security Controls
21Tech applies administrative, technical, and organizational safeguards, including access controls, encryption where appropriate, audit logging, and incident-response practices. No system is absolutely secure. Users should also protect their credentials and devices.
11. User Rights
Subject to applicable law, you may request:
- Access to personal data
- Correction of inaccurate data
- Deletion where retention is no longer required
- Restriction or objection to certain processing
- Withdrawal of consent where consent is legal basis
- Data portability where legally applicable
Requests can be sent to notification@pem.gg. 21Tech may require identity verification before fulfilling requests and may lawfully decline requests where exemptions apply.
12. Automated Processing and Risk Decisions
21Tech may use rule-based and automated systems for fraud detection, transaction risk checks, and account protection. Where required by law, users may request review mechanisms for significant decisions.
13. Marketing and Service Communications
We may send:
- Mandatory service messages (security notices, transaction updates, legal/compliance notices)
- Optional marketing/promotional messages, subject to applicable consent and opt-out requirements
You may opt out of non-essential marketing communications via available controls or support request.
14. Cookies and Similar Technologies
The Platform may use cookies and similar technologies for authentication, security, session continuity, analytics, and service performance. You can manage certain controls through browser or device settings. Disabling essential technologies may impact service functionality.
15. Children and Age Restrictions
LuckyPem is not intended for persons under 18. If underage use is detected, 21Tech may suspend account access and take required compliance actions.
16. Tax and Regulatory Reporting
Where required by Bhutan law or competent authority, 21Tech may process and disclose transaction or payout-related data for tax, audit, and regulatory compliance. Users are responsible for maintaining accurate profile and tax-relevant information.
17. Dispute and Complaints
Privacy complaints should be submitted to notification@pem.gg with full details. 21Tech will investigate and respond within a reasonable period. Where unresolved, users may escalate to competent Bhutan authorities or courts as permitted by law.
18. Policy Updates
This Privacy Policy may be updated from time to time. Material changes will be notified via in-app notice, email, or official communication channels where required. Updated versions take effect on posted effective date unless stated otherwise.
19. Contact
For privacy requests, compliance inquiries, or complaints:
Email: notification@pem.gg
Operator: 21Tech