Privacy Policy

1. Introduction

Lucky Cement Limited ("Lucky Cement", "we", "us" or "our") respects the privacy of the people who use our digital properties. This Policy explains what information we collect when you use the Lucky Ustaad mobile application, the Lucky Ustaad web experience within the Homebuilders Hub, and the Lucky Cement corporate and marketing website, why we collect it, who we share it with, and the choices available to you. In this Policy, those properties are referred to collectively as the "Services".

This Policy should be read together with the Terms of Use. It does not apply to the practices of any third party whose site, application or platform you reach through the Services.

2. Who is responsible for your information

Lucky Cement Limited, of [insert registered address], is responsible for the personal information described in this Policy. Where we engage technology partners to operate parts of the Services on our behalf, they act on our instructions and under contractual obligations of confidentiality and security.

3. Information we collect

Information you give us. This includes the questions, descriptions and other text you enter into the assistant; photographs you upload or capture through the camera for interpretation; the details you enter into calculators and planners, such as area, number of rooms or intended construction stage; the contact details and preferences you provide when you make an enquiry, request a call back or contact a dealer; and the personal details, employment history, education history and documents you provide when you apply for a role with us. If you contact our support or feedback channels, we retain what you send us and our response to it.

Information collected automatically. When you use the Services we record technical and usage information, including device type, operating system and version, application version, browser type, language setting, IP address, general location inferred from it, referring pages, the pages and features you use, the actions you take within them, timestamps, session duration, crash and diagnostic data, and identifiers assigned to your device or browser for analytics and advertising purposes. Where you grant permission, we use your device's location services to centre the dealer map and show nearby stockists. Location permission can be withdrawn at any time through your device settings, though some features will then be less useful.

Information from others. We may receive information from advertising and analytics partners about how you arrived at the Services and how our campaigns perform, and from dealers or business partners where they pass on an enquiry relating to you. Where our sites carry social or video content from other platforms, those platforms may also set their own identifiers.

We do not seek sensitive categories of information through the Services, and you should avoid submitting identity documents, financial credentials or health information into the assistant.

4. How we use your information

We use the information described above to operate and deliver the Services, which includes generating responses to your questions, running calculations, showing relevant dealers and products, and keeping the platform stable and secure. We use it to respond to enquiries, feedback and support requests, and to route enquiries to the appropriate dealer or internal team.

Where you apply for a role, we use your information to assess your application, to communicate with you about it, and to maintain our recruitment records.

We use technical and usage information to understand how the Services are used, to diagnose faults, to measure the performance of features and campaigns, to prevent fraud and misuse, and to guide improvements to design and content. We use it, subject to the consent choices described below, to select and measure advertising, including advertising delivered through third-party networks, and to limit how often a given advertisement is shown to you.

We may also use information where it is necessary to comply with law, to respond to a lawful request from a competent authority, or to establish, exercise or defend legal claims.

5. Artificial intelligence and how conversations are handled

The assistant relies on artificial intelligence systems, some of which are provided by specialist third-party technology providers. When you submit a question or an image, the content of that submission, together with limited context needed to produce a useful answer, is transmitted to the relevant provider so that a response can be generated and returned to you. Providers may process this content outside Pakistan.

We contract with these providers on terms intended to restrict their use of your content to the delivery of the service to us. We do not permit your submissions to be used to train publicly available models where the provider offers a setting to prevent it, and we take reasonable steps to keep submissions free of direct identifiers before transmission where this is practicable.

Conversation history may be stored locally on your device so that you can revisit earlier guidance, and you can remove it through the application. We separately retain records of assistant usage, including message volume, feature usage and system performance measures, for operational monitoring, cost management and quality improvement.

6. Legal basis and your consent

We process personal information where doing so is necessary to provide a service you have asked for, where it is necessary to perform a contract with you, where we have a legitimate business interest that is not overridden by your interests, where we are required to do so by law, and otherwise where you have consented. Where consent is the basis, including for non-essential cookies, for advertising identifiers and for location access, you may withdraw it at any time, and withdrawal does not affect processing carried out before withdrawal.

7. Cookies, analytics and advertising technologies

The Services use cookies, software development kits, pixels and similar technologies. Some are necessary for the Services to function, to keep sessions secure and to remember your settings. Others help us understand usage through analytics tools, and others support the selection and measurement of advertising through third-party advertising platforms.

Where required, we present a consent notice on first visit that allows you to accept or decline non-essential categories, and your choice can be changed at any time through the preferences link provided. You can also manage cookies through your browser settings and manage advertising identifiers through your device settings, though declining certain categories may affect how parts of the Services behave.

8. When we share information

We do not sell your personal information. We share it in the following circumstances.

We share it with service providers who support the Services on our behalf, including hosting and infrastructure providers, content management and database services, artificial intelligence and language technology providers, mapping and location services, analytics and measurement providers, advertising platforms, communication and email delivery services, and customer support tooling. Each is engaged under terms requiring appropriate confidentiality and security.

We share enquiry details with the dealer or distributor you have asked to be connected with, so that they can respond to you.

We share information within the Lucky Cement group of companies where necessary for administration, reporting and the delivery of the Services. We disclose information where we are required to do so by law, by a court, or by a regulator, and where disclosure is necessary to protect our rights, our people, our customers or the security of our systems. If our business or any part of it is reorganised, transferred or acquired, information may be transferred as part of that transaction, subject to the protections in this Policy.

9. Transfers outside Pakistan

Some of the providers we rely on, particularly for cloud hosting, artificial intelligence processing, analytics and advertising, operate outside Pakistan. Where information is transferred internationally, we take reasonable steps to ensure that it remains subject to appropriate contractual and technical safeguards and that it is handled consistently with this Policy.

10. How long we keep information

We keep personal information only for as long as it is needed for the purposes described in this Policy, and thereafter only where retention is required by law or is necessary for the establishment or defence of legal claims.

In practice, enquiry and support records are retained for the period needed to handle the matter and to maintain a reasonable service history. Recruitment records are retained for the duration of the hiring process and for a limited further period so that we may consider you for other suitable roles, unless you ask us to remove them sooner. Technical and analytics data is retained in aggregated or reduced form after the initial retention period. When information is no longer required, we delete it or render it no longer attributable to you.

11. Security

We maintain administrative, technical and physical measures designed to protect personal information against unauthorised access, alteration, disclosure and loss. These include encryption of data in transit, access controls and role-based permissions on administrative systems, network and application monitoring, and periodic review of our practices and those of our providers.

No system can be guaranteed to be completely secure. You are responsible for keeping any credentials associated with the Services confidential and for taking reasonable care with the information you choose to submit.

12. Your choices and rights

You may ask us for a copy of the personal information we hold about you, ask us to correct information that is inaccurate or incomplete, ask us to delete information where there is no continuing basis for us to retain it, object to or ask us to restrict certain processing, and withdraw a consent you have previously given. Where applicable law provides these rights, we will honour them within the timeframes it prescribes.

You can control location access and advertising identifiers through your device settings, manage cookie categories through the consent notice, clear the assistant's conversation history from within the application, and unsubscribe from marketing communications using the link included in them. Service messages relating to an enquiry or an application will continue to be sent where necessary.

Requests may be sent to the contact address in section 15. We may need to verify your identity before acting, and we may decline a request where the law permits or requires us to do so, in which case we will explain why.

13. Children

The Services are not intended for children, and we do not knowingly collect personal information from them. If you believe a child has provided information to us, please contact us and we will take appropriate steps to remove it.

14. Changes to this Policy

We may update this Policy to reflect changes in the Services, in our practices, or in applicable law. The revised version takes effect when published, and the effective date above will be updated. Where changes are material, we will take reasonable steps to bring them to your attention before they take effect.

15. Contact and complaints

Questions about this Policy, or requests relating to your personal information, may be sent to [insert privacy contact email] or by post to Lucky Cement Limited, [insert registered address], marked for the attention of [insert data protection contact or department]. We aim to acknowledge enquiries promptly and to resolve them fairly. If you remain dissatisfied, you may raise the matter with the competent authority in your jurisdiction.