Privacy Policy

Published on 16th June 2020.

Last updated on 16th June 2020.

We ask that you read this website privacy policy (the “Policy”) carefully as it contains important information on who we are, how and why we collect, store, use and share personal information we collect, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This Policy also helps us in complying with our applicable global data privacy laws, including the EU General Data Protection Regulation (the “GDPR”) if you are located in the EEA.

Who we are

This website is operated by LuckyBit Entertainment N.V.; a company organised under the laws of Curaçao, and with the following registered address: Kaya Richard J. Beaujon Z/N, Willemstad, Curaçao (“We”, “we”, “our”, or “us”).

We collect, use and are responsible for certain personal information about you. If you are located in the EEA including the United Kingdom when we do so, then we are regulated under the GDPR which applies across the EEA (including in the United Kingdom), and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Our website

This privacy policy relates to your use of our website, accessible at affiliate.luckyb.it (the “Platform”).

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products available to you. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Our collection and use of your personal information

We collect personal information about you directly when you register on the Platform to create an account (“Register”); when we conduct regulatory checks on you including without limitation to protect against anti-money laundering and gambling regulation (each and collectively “Regulatory Checks”); when you contact us and you are located in the EEA to make a request relating to your personal information pursuant to a right of yours under the GDPR or a similar regulation under another jurisdiction (“GDPR Contact”); when you use the Platform to refer players and collect your affiliate comission (each and collectively “Referring”, as applicable); or indirectly when you use the Platform (see ‘Cookies’ below) (“Cookie Processing”).

The following details the only personal information we collect about you:

  • your email address and nick name when you Register (each and collectively “Registration Details”, as applicable);
  • your name, and any other information we obtain on you in support of Regulatory Checks (each and collectively “Regulatory Information”, as applicable);
  • your email address and name, and any other information you provide in a GDPR Contact (each and collectively “GDPR Compliance Details”, as applicable);
  • your transaction ID’s and receipient bitcoin address for comission payouts (each and collectively “Payment Details”, as applicable);
  • statistics of your referred players (each and collectively “Referral Stats”, as applicable);
  • your IP address, country of location, geo-location, TOR/VPN status; browser details (including without limitation agent and headers); log-in time; log-off time; and session duration in Cookie Processing (each and collectively “Cookie-derived Information”);

We use this personal information to:

  • Registration Details: to open your account and enable us to supply the services available on the Platform and customer administration (each and collectively as “Service Provision”, as applicable).
  • Regulatory Information: to comply with our anti-money laundering and anti-terrorist financing regulations, and to assist in the prevention of anti-money laundering and anti-terrorist financing; to protect problem gamblers and ensure under-age players do not use the Services (“Regulatory Compliance”);
  • GDPR Compliance Details: to comply with our regulations under the GDPR and to enable you to take advantage of your rights under the same (“GDPR Compliance”);
  • Payment Details: for Service Provision;
  • Referral Stats: for marketing (“Marketing”);
  • Referral Stats: to further develop and improve the Platform and Services (“Product Improvement”);
  • Cookie-derived Information: for Marketing;
  • Cookie-derived Information: to improve the safety and security of the Platform (“Security Improvement”); and Product Improvement; and
  • Cookie-derived Information: Regulatory Compliance.

This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

  • “Consent” where you have given us clear consent for us to process your personal information for a specific purpose, as is the case with Marketing; Product Improvement and Security improvement;
  • “Contract” where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract, as is the case for Service Provision; and
  • “Legal Obligation” where our use of your personal information is necessary for us to comply with the law (not including contractual obligations), such as with GDPR Compliance and Regulatory Compliance.

Overview

So, to summarize:

When you Register we process your Registration Details to enable our Service Provision on the legal basis of Contract;

During Regulatory Checks we process your Regulatory Information to enable our Regulatory Compliance on the basis of our Legal Obligation;

With each GDPR Contact we process your GDPR Compliance Details to enable our GDPR Compliance on the basis of our Legal Obligation;

When you receive comission Payouts we process your Payment Details to enable our Service Provision on the basis of Contract;

When you are Referring players we process your Referral Stats to enable our Marketing; and Product Improvement, on the legal basis of your Consent;

With some Cookie Processing we process your Cookie-derived Information to enable our: Marketing; Security Processing and Product Improvement, on the legal basis of your Consent;

With any other Cookie Processing we process your Cookie-derived Information to enable our Regulatory Compliance on the basis of our Legal Obligation.

Who we share your personal information with

Other than:

  • Registration Details, Payment Details, Referral Stats to software developers that are contracted with the following software development supply company that is contracted with us: Cryptosphere Systems AG, a company organized under the laws of Switzerland, with the following registered address: Zuger Strasse 32, ZG-6340 Baar, for the purpose of developing, improving and technically operating the Platform;
  • Registration Details and IP-addresses from Cookie Derived Information to the operational staff of the Platform for site operation and policy enforcement (each and collectively the “Operators”, as applicable);
  • E-mail adress and username to Mailchimp, an online marketing platform operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States. In order to send an email newsletters and updates.
  • Your geolocation from Cookie Derived Information, emails from Registration Details and balances from Deposit information, to Curaçao eGaming, a company located in Curaçao, with the following registered address: Pareraweg 45, Willemstad, which operates a compliance platform we use for geo-blocking and gamlbing compliance (“Curacao eGaming”); and
  • Law enforcement or other authorities if required by applicable law.

We do not share your information with any other third parties. Although we are a company organised under the laws of Curaçao, all of our agents, workers and employees that will or may process your personal information are located in the EEA.

Whether information has to be provided by you, and if so why

We require you to provide the following personal information: Registration Details to enable Service Provision; Regulatory Information for Regulatory Compliance; GDPR Compliance Details for GDPR Compliance; Deposit Details for Service Provision; and Cookie-derived Information for Regulatory Compliance.

Transfer of your information out of the EEA

We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows:

  • Curaçao, in order to use the geo-blocking and gambling compliance service of Curacao eGaming;

Such countries do not have the same data protection laws as the EEA. While the European Commission has not given a formal decision that Curaçao provides an adequate level of data protection similar to those which apply in the EEA, any transfer of your personal information will be subject to a European Commission approved contract (as permitted under the General Data Protection Regulation) that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. To obtain a copy of the European Commission approved contract, or if you would like further information please contact us at affiliate@luckyb.it

We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Cookies and similar technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies and other similar tracking technologies such as local storage on the Platform. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on our use of cookies, please see our affiliate.luckyb.it/cookie-policy

Your rights

Under the GDPR you have a number of important rights free of charge. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information;
  • access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address;
  • require us to correct any mistakes in your information which we hold;
  • require the erasure of personal information concerning you in certain situations;
  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
  • object at any time to processing of personal information concerning you for direct marketing;
  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
  • object in certain other situations to our continued processing of your personal information;
  • otherwise restrict our processing of your personal information in certain circumstances; and
  • claim compensation for damages caused by our breach of any data protection laws.

If you would like to exercise any of those rights, please:

  • email affiliate@luckyb.it;
  • let us have enough information to identify you;
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

Changes to this website privacy policy

We may change this website privacy policy from time to time, when we do we will inform you via an email and/or a notice on the Platform.

How to contact us

If you wish to contact us, please send an email to affiliate@luckyb.it