Table of Content
Objective of this Privacy Statement
This statement provides details on our collection and processing of your personal data during your use of the site. Our site is not designed for minors, and we do not intentionally gather data about children. Please review this statement alongside any additional privacy notices we might issue for specific data collection or processing scenarios, ensuring you're informed about our data usage practices.
Our Identity and Contact Information
The site and application (referred to collectively or individually as the “Site”) are managed by Igloo Ventures SRL, with registration number 3-102-880024 and address in San Jose, Cedula Juridica, Costa Rica. Lucky Pays holds a licence from the Government of the Autonomous Island of Anjouan, Union of Comoros, under Licence No. ALSI-1423 l 1005-FI2. Igloo Ventures SRL (known as "Lucky Pays", "we", "us", or "our" here) acts as the data controller, deciding the goals and methods for processing your data. We fulfill our controller responsibilities diligently. We've designated a data privacy officer to handle inquiries about this statement. For questions regarding this Privacy Statement or to exercise data-related rights, reach out to our data privacy officer via email at privacy@casinoluckypays.com You can lodge complaints with the appropriate data protection authority anytime, but we'd prefer to resolve issues directly, so please contact us first.
Updates to the Privacy Statement and Your Obligation to Notify Us of Changes
We routinely review this Privacy Statement. The latest update date appears at the end. It's essential that the data we hold on players remains accurate and up-to-date. Please notify us of any changes to your information while your account is active.
Links to External Sites
Our site might feature links to outside websites, plugins, or apps. Activating these could enable third parties to gather or exchange your data. We don't oversee those sites and aren't liable for their privacy practices. Upon exiting our site, we suggest checking the privacy policies of visited sites.
Information We Gather About You
Personal data refers to any details identifying an individual, excluding anonymized information. We obtain data you supply directly, like during account registration or customer support interactions. We also source it from public or third-party channels, such as social platforms and data collectors. We might collect, utilize, store, and share various types of your personal data, categorized as: Identity Details: first name, maiden name, last name, username or equivalent, marital status, title, birth date, and gender. Photographic Proof: passports or other ID photos for identity confirmation. Contact Details: billing address, residence address (if separate), email, and phone numbers. Financial Details: bank and payment card information. Transaction Details: records of deposits, withdrawals, and services used (e.g., games) on the Site. Technical Details: IP address, login info, browser details, time zone, location, plugins, OS, platform, and device tech. Profile Details: usernames, passwords, services used, interests, preferences, feedback, and surveys. Usage Details: how you engage with the Site, products, and services. Marketing and Communication Details: preferences for marketing from us or others, and communication choices. We also handle Aggregated Data like stats or demographics for various uses. Though derived from personal data, it's not personal if it doesn't identify you. For instance, we might aggregate usage to gauge feature popularity. If aggregated data links back to you, we treat it as personal data per this statement.
Consequences of Not Providing Personal Information
If law or contract terms require data collection (e.g., under Player Terms), and you don't provide it, we might be unable to fulfill the agreement (like enabling betting). We could then cancel access to products or services, notifying you accordingly.
Methods of Collecting Your Personal Information
We gather data via: Direct engagements: You provide Identity, Contact, and Financial Details through forms, mail, calls, emails, etc. Automated means: Site interactions yield Technical Details on equipment and browsing via cookies and similar tech. See cookie details below. Third-party or public sources: Data from:
● Analytics firms;
● Ad networks;
● Search providers;
● Tech and payment service vendors, like PSPs for transactions;
● Data brokers.
Our Use of Your Personal Information
We gather data to deliver superior service, ensure smooth and safe Site use, and personalize experiences. The following table details collection timing, data types, and purposes. Timing of Processing Data Requested Usage and Rationale Account Registration Contact Details Identity Details Financial Details Photographic Proof Processed to:
Establish and oversee your account
Discuss account matters Basis: Contract performance. Account Management Communications Contact Details Identity Details Financial Details Transaction Details Technical Details Profile Details Marketing & Communications Details Processed to:
Deliver tailored service
Address inquiries and issues Basis: Contract performance for management; legitimate interest for promotions. Customer Insights for Service Enhancement Contact Details Identity Details Transaction Details Technical Details Profile Details Usage Details Marketing & Communications Details Processed to:
Analyze customer patterns and demographics
Identify needs and interests Basis: Legitimate interest in business improvement. Marketing and Relevance Assessment Contact Details Identity Details Transaction Details Technical Details Profile Details Usage Details Marketing & Communications Details Basis: Legitimate interest in promoting offerings. Consent for electronic marketing doesn't alter this. Regulatory Compliance Contact Details Identity Details Financial Details Transaction Details Technical Details Profile Details Usage Details Basis: Legal obligations, including sharing with authorities for AML, KYC, fraud checks.
Promotional Activities
You'll get marketing from us if: (i) You hold an account and haven't opted out initially or later; or (ii) You're not an account holder but requested info or used services and consented. Stop marketing by contacting us or via Site settings. Opting out doesn't affect data provided for non-marketing reasons.
Sharing Your Personal Information
We may disclose data to listed parties for outlined purposes. Internal: Group affiliates as controllers/processors for IT, HR, support, admin, and reporting. External:
● IT and admin providers.
● Software licensors essential for services, e.g., game providers.
● Payment facilitators for transactions.
● Verification services for fraud prevention.
● Marketing dispatchers on our behalf.
● Advisors like lawyers, bankers, auditors, insurers for professional services.
● Authorities requiring reports.
● Potential buyers/transferees in business changes, who'll use data similarly. We mandate third parties to secure data legally, limiting use to specified instructions.
Protecting Your Data
We've implemented suitable safeguards against accidental loss, unauthorized access, alteration, or disclosure of data. Access is restricted to need-to-know personnel bound by confidentiality. Procedures address suspected breaches, with notifications to you and regulators as required.
How Long We Keep Your Data
Data is retained only as needed for collection purposes, including legal, regulatory, tax, accounting, or reporting needs. Longer retention applies for complaints or potential disputes. Retention considers data volume, sensitivity, risks, purposes, and requirements. You can request deletion in some cases; see section 14. We may anonymize data for research/stats, using it indefinitely without notice.
Your Legal Entitlements
In certain situations, data protection laws grant rights like:
● Access: Obtain a copy of held data.
● Correction: Fix incomplete/inaccurate data, with verification.
● Erasure: Delete where unnecessary, or if objected successfully, unlawful, or required by law. We might not comply for legal reasons, notifying you.
● Objection: Oppose processing impacting rights/freedoms; we may override if grounds compel.
● Restriction: Suspend in scenarios like accuracy checks, unlawful use (preferring restriction over deletion), legal needs, or verification post-objection.
● Transfer: Receive or send data in structured format for automated, consented, or contractual info. Contact us to exercise rights; we'll assess feasibility. No fee usually, but reasonable charges/refusals for baseless/repetitive requests. We may seek ID verification and more details to respond swiftly. Responses aim for one month; extensions possible for complexity, with updates.