Terms & Conditions
Welcome to LuckyPem. By accessing the website (luckypem.bt) and participating in any lottery draw, you agree to be bound by these Terms and Conditions. Please read them carefully.
Effective Date: April 1, 2026
Privacy & Data Protection
LuckyPem is committed to protecting your privacy and data. We collect only essential information required for platform operations, security, and compliance.
Authentication is handled exclusively through Digital Kidu (DK Bank) using your Citizen ID (CID). All identity verification and financial transactions are processed securely through the DK Bank gateway.
We collect and process: account and identity data, contact information (email, phone) for OTP verification and service communications, transaction and wallet data, participation records, and security/fraud prevention data. All data is processed with strict security controls and retained only as required by law.
For complete details on data collection, use, retention, and your rights, please read our Privacy Policy.
1. The Service & Platform
1.1 The Platform
LuckyPem is a digital lottery platform offering fair and transparent draws through Time-Based Pools (recurring daily, weekly and monthly cycles) and Size-Based Pools (fill-and-draw power pools with multipliers). All operations are conducted through wallet-based transactions for enhanced security and transparency.
1.2 Authentication & Payment Gateway
All authentication, identity verification, and financial transactions are processed exclusively through Digital Kidu (DK Bank), Bhutan's national payment gateway. Users authenticate using their Citizen ID (CID) through the DK Bank system - no passwords or email addresses are required or stored by LuckyPem.
1.3 Wallet System
All pool entries and prize payouts are processed through a secure wallet system. Users deposit funds from their DK Bank account into their LuckyPem wallet, use wallet balance for pool entries, and can withdraw winnings back to their linked bank account at any time.
1.4 Nature of Service
LuckyPem is a chance-based lottery platform designed to provide fair entertainment and winning opportunities to participants in Bhutan. All draws use cryptographically secure random number generation with complete audit trails.
2. Eligibility
To participate, you must meet the following criteria:
2.1 Age & Citizenship
You must be 15 years or older and possess a valid Bhutanese Citizen ID (CID) to participate in LuckyPem lottery draws.
2.2 DK Bank Account
You must have an active, verified Digital Kidu (DK Bank) account linked to your CID. All authentication and transactions are processed through the DK Bank gateway - no separate registration or account creation is required on LuckyPem.
2.3 Identity Verification
Identity verification is automatic through DK Bank using your CID. You do not need to provide any personal information (email, phone, password) to LuckyPem - your identity is verified securely through the DK Bank system.
3. Pool Types & Draw Mechanics
3.1 Time-Based Pools
Time-Based Pools are recurring lottery draws that execute at scheduled intervals (Daily, Weekly, Monthly). Each pool has a predetermined capacity and prize structure. Once the time expires, the draw executes automatically regardless of capacity, provided minimum participation requirements are met.
3.2 Size-Based Pools (Power Pools)
Size-Based Pools (Power Pools) are high-stakes lottery draws with capacity tiers of 100, 500, and 1000 participants. These pools close and draw immediately once the maximum capacity is reached, regardless of the scheduled time. First-come, first-served basis.
3.3 Wallet-Based Entry
All pool entries are purchased using your LuckyPem wallet balance. You must first deposit funds from your DK Bank account into your wallet. Entry fees are instantly deducted from your wallet balance when you join a pool. No direct bank debits occur during pool entry.
3.4 Multiple Entries
You may purchase multiple entries in the same pool to increase your winning chances. Each entry is treated as an independent participant in the draw. Entry limits may apply for responsible gaming purposes.
3.5 Pool Capacity
Each pool displays its current capacity status in real-time. For Size-Based Pools, the pool closes instantly when capacity is reached. For Time-Based Pools, the system accepts entries until either capacity is reached or the scheduled draw time arrives.
4. Refund Policy
4.1 Automatic Refunds to Wallet
If a Time-Based Pool fails to reach its minimum required participants by the scheduled draw time, all entry fees will be automatically refunded to participants' wallet balances within 24 hours. The pool is declared VOID and no draw takes place.
4.2 Size-Based Pool Refunds
Size-Based Pools close and draw immediately upon reaching capacity, so refunds do not apply. However, if technical issues prevent a draw after the pool closes, all entries are refunded to wallet balances.
4.3 Refund Timeline
100% of your entry fee is automatically refunded to your LuckyPem wallet balance in the event of a voided draw. Refunds are processed immediately and appear in your wallet within 1-24 hours.
You may withdraw refunded amounts to your DK Bank account at any time through the wallet withdrawal feature.
4.4 No Cash Refunds
All refunds are credited to your LuckyPem wallet. Direct bank refunds are not processed. You may withdraw your wallet balance to your DK Bank account at your convenience.
5. Draw Execution & Winner Selection
5.1 Cryptographically Secure Randomness
Winners are selected using a cryptographically secure random number generator (CSPRNG) with a commit-reveal scheme. The platform uses drand public randomness beacon integration and HKDF-SHA256 for verifiable, unbiased selection. Each entry has an exactly equal chance of winning.
5.2 Automatic Draw Execution
Draws execute automatically when trigger conditions are met: Time-Based Pools draw at scheduled times (if minimum capacity is met); Size-Based Pools draw immediately upon reaching maximum capacity. No manual intervention is possible.
5.3 Instant Prize Distribution
Prizes are automatically credited to winners' wallet balances immediately after the draw completes. No waiting period or manual claim process is required. Winners can withdraw their winnings to their DK Bank account instantly.
5.4 Transparency & Verification
All draws use Merkle Tree integrity verification and maintain a complete audit trail. Every participant can verify the fairness of the draw through the platform. Winner announcements are published on the Winners Feed with masked identifiers for privacy.
5.5 Prize Structures
Each pool clearly displays its prize structure before entry. Time-Based Pools have fixed prize amounts; Size-Based Pools (Power Pools) have capacity tiers of 100, 500, and 1000 participants. Prize distributions are predetermined and cannot be altered after the pool opens.
6. Wallet Operations & Prize Payouts
6.1 Wallet Deposits
You authorize DK Bank to transfer funds from your bank account to your LuckyPem wallet when you initiate a wallet deposit. All deposits are processed through the secure DK Bank gateway with OTP verification. Deposits are credited to your wallet immediately upon successful verification.
6.2 Pool Entry Payments
Entry fees are deducted from your wallet balance when you join a pool. Insufficient wallet balance will prevent pool entry - you must deposit sufficient funds into your wallet before participating. No direct bank debits occur during pool entry.
6.3 Instant Prize Payouts
All winnings are automatically credited to your LuckyPem wallet balance immediately after the draw completes. No manual claim process is required. Prizes appear in your wallet within seconds of the draw execution.
6.4 Wallet Withdrawals
You may withdraw your wallet balance (including winnings) to your linked DK Bank account at any time. Withdrawals are processed through the secure DK Bank gateway and typically complete within 1-24 hours. Withdrawal limits may apply as per DK Bank policies.
6.5 Transaction Transparency
All wallet transactions (deposits, entries, winnings, withdrawals) are recorded in your transaction history with complete details, timestamps, and reference numbers for full transparency and reconciliation.
7. Winner Privacy & Transparency
7.1 Automatic Identity Verification
Winner identity is automatically verified through DK Bank using your CID. No manual verification process is required for standard prizes. High-value wins may be subject to additional compliance checks by DK Bank as per banking regulations.
7.2 Privacy-First Winner Announcements
To ensure transparency while protecting privacy, winner announcements on the Winners Feed display only a masked identifier (e.g., "User ***123"), prize amount, and timestamp. No personal information, names, or CID numbers are publicly disclosed without explicit consent.
7.3 Optional Publicity
Winners of major prizes may be invited to voluntarily participate in promotional activities (photos, testimonials). All publicity is entirely optional and requires explicit consent. You may decline without affecting your prize.
7.4 Data Minimization
LuckyPem publishes only the minimum information necessary for transparency. Your CID, bank details, and personal information remain private and are never shared publicly or with third parties.
8. Disclaimers & Liability
8.1 Platform Availability
LuckyPem strives for maximum uptime and reliability. However, we are not liable for missed entries due to user internet connectivity issues, device failures, DK Bank gateway outages, or scheduled maintenance. Users are responsible for ensuring their own connectivity and submitting entries with adequate time before pool closure.
8.2 Verifiable Fairness
All draws use cryptographically secure random number generation with commit-reveal scheme, drand public randomness integration, HKDF-SHA256, and Merkle Tree verification. The system is designed to be tamper-proof and independently verifiable. The draw results are final and binding. No correspondence regarding draw outcomes will be entered into.
8.3 Third-Party Services
LuckyPem relies on DK Bank for authentication and payment processing. While we implement robust error handling and retry mechanisms, we are not liable for issues arising from DK Bank service disruptions, delays, or errors. Banking-related issues should be directed to DK Bank support.
8.4 Responsible Gaming
LuckyPem implements spending limits, entry restrictions, and self-exclusion features for responsible gaming. However, participants are ultimately responsible for their own gaming behavior. Play responsibly and within your means.
8.5 Limitation of Liability
LuckyPem's liability is limited to the return of entry fees in the event of technical failures or voided draws. We are not liable for indirect, incidental, or consequential damages arising from platform use.
9. Responsible Gaming Features
9.1 Spending Limits
LuckyPem implements daily, weekly, and monthly spending caps to promote responsible gaming. You can view and manage your spending limits through your account settings. These limits help prevent excessive participation.
9.2 Entry Restrictions
Maximum entries per day and per pool are enforced to prevent compulsive behavior. The platform displays realistic winning odds for each pool to ensure informed participation.
9.3 Self-Exclusion & Cool-Off Periods
Users may voluntarily self-exclude for 24 hours, 7 days, 30 days, or permanently. During self-exclusion, wallet deposits and pool entries are disabled. Cool-off periods may be automatically triggered for at-risk users based on behavioral monitoring.
9.4 Reality Checks
The platform provides periodic reminders showing session duration and total spending to help users maintain awareness of their gaming activity.
9.5 Support Resources
If you or someone you know is experiencing gambling-related issues, support resources and helplines are available through the platform. Seek help if gaming becomes problematic.
10. Governing Law
These Terms are governed by the laws of the Kingdom of Bhutan. Any disputes arising from the platform shall be subject to the exclusive jurisdiction of the courts of Thimphu.