Privacy Policy

This Privacy Policy applies to all websites owned and operated by us, as well as all services we provide, including online and mobile services and products. In this policy, we will refer to them as our “Website” and “Services.”

When we mention “Personal Data,” we refer to identifiable information related to you, such as your name, email, address, phone number, payment account details, payment information, support requests, betting records, chat comments, etc. This policy does not apply if you cannot be identified (e.g., when Personal Data has been aggregated and anonymized).

We may need to update this policy from time to time. If there are significant changes, we will ensure to inform you, usually by posting a notice on the website or sending an email.

What Data We Collect and How We Collect It

When you visit our website or use our services, we collect and process your personal data. The ways we collect personal data can be broadly categorized as follows:

1. Explanation: This refers to personal information you voluntarily provide to us.
2. When you access or use certain parts of our website and/or services, we may ask you to provide personal data. For example, during registration, verification, anti-money laundering procedures, fraud checks, or when you contact us with questions or support requests, we may ask you for contact information or certain documents.

Automatically Collected Information

When you visit our website or use our services, we automatically collect some information about you, such as your IP address, operating system, device type and settings, browser type and settings, crash reports, system activities, and the date, time, and referring URL of your requests. This information is very useful for us as it helps us better understand how you use our website and services so that we can continue to provide the best experience. For example, by using information in your browser, we can determine the language you are using.Some of this information is collected using cookies, similar tracking technologies, and third-party tools like Google Analytics.We also collect details of your transactions with us and your account activities. We obtain information from third parties.Sometimes, we may collect personal data about you from other sources, such as publicly available materials or reliable third parties, like our payment providers. We use this information to supplement the personal data we hold about you to better provide information, personalize and improve our services, and verify the accuracy of the personal data you provide.

Legal Basis for Processing Personal Data

When collecting personal data, we will only process it when there is a legal basis for processing as defined by applicable data protection laws. These legal bases include:

1. Performance of a Contract:We may process your personal data when necessary for the performance of a contract. For example, when you register on the website, you enter into an agreement with us, or when we take steps related to the contract, particularly facilitating transactions conducted on the website.
2. Legal Obligation:Various laws and regulations impose certain obligations on us. To comply with these regulations, we must process your personal data, for example, to comply with anti-money laundering regulations, responsible gaming provisions, and the conditions of our gaming licenses.
3. Legitimate Interests:We may process your personal data when there are business or commercial reasons for us, other companies in our group, or third parties.
4. Your Consent:In certain limited circumstances, we will process your personal data based on your consent, such as when consent is required for direct marketing purposes.

How We Use Personal Data

Using your personal data (legal basis):

1. To operate our website, ensure that our website and services function as intended, and provide you with the requested services (performance of contract obligations, legitimate interests).
2. To determine whether you can use specific services, including checking your age, geographic location, identity, or self-exclusion status, and setting up and operating your account (performance of contract obligations, legitimate interests).
3. To fulfill legal duties and obligations, comply with all applicable laws and regulations, and prevent illegal activities, including money laundering and match-fixing (legal obligation).
4. To support you, including assisting with technical, payment, or other issues related to the website or services (performance of contract obligations).
5. To enhance our website and services, test and develop new features, and conduct technical analysis of our website and services to optimize your user experience and provide you with more efficient tools (legitimate interests).
6. To prevent, detect, and report criminal activities, protect your interests, those of other users, and our own interests, such as ensuring network and information security, mitigating security risks, detecting and preventing any fraud or malicious activities, and ensuring fair use of our website and services in accordance with agreements (legal obligation, legitimate interests, performance of contract obligations).
7. To analyze and aggregate data, create statistics, particularly generating aggregated and anonymized analyses and reports, which we may use internally or share publicly with third parties (legitimate interests).
8. To facilitate, manage, and confirm financial transactions (performance of contract obligations, legitimate interests).
9. To analyze your fraud risk and verify your credentials using third-party agencies, including financial institutions, identity verification agencies, and credit reference agencies (legal obligation, performance of contract obligations, legitimate interests).
10. To assess your gambling activities to promote responsible gambling (legal obligation, legitimate interests, performance of contract obligations).
11. To monitor betting activities and manage our risks and odds (legitimate interests, performance of contract obligations).
12. To exercise rights specified in agreements made with you or other agreements (performance of contract obligations).
13. To disclose information to other companies in our group for internal administrative purposes or corporate restructuring (legitimate interests).
14. To manage our relationship with you and communicate with you. This may include:1. Operational communications, such as notifications of changes to the website and services, information about new features, bonuses, and promotions, security updates, and assistance with using the website and services;2.Marketing communications, providing you with requested information or information we are obligated to send you (performance of contract obligations, legitimate interests, your consent).

How We Share Your Personal Data

In certain circumstances, we need to share your personal data with third parties. We will disclose your personal data to:

1. Other companies in our group;
2. Third-party service providers and partners that assist us in providing the requested website and services, such as those supporting the delivery of the website or services or marketing our website and services;
3. Regulatory authorities, law enforcement agencies, government bodies, courts, anti-fraud agencies, licensing bodies, esports self-regulatory bodies, or other third parties when we believe it is necessary to comply with applicable laws or regulations, or to exercise, establish, or defend our legal rights (where possible and appropriate, we will notify you of such disclosures);
4. Affiliates and other parties who introduce you to us;
5. Other parties with your consent.

Cross-Border Data Transfers

When we process and share data, it may be transferred to countries outside of your country and processed in those countries. The laws in those countries may differ from those you are accustomed to. When personal data is processed in other countries, we will take safeguards to ensure your personal data is protected.

For individuals in the European Economic Area (EEA), this means your data may be transferred outside the EEA. If your personal data is transferred to countries outside the EEA, we will implement transfer mechanisms that meet the requirements to protect your personal data, particularly by entering into contracts with data recipients that include standard contractual clauses approved by the European Commission.

Security

We are committed to protecting your personal data and have taken appropriate technical and organizational measures, including:

1. Data Encryption. We use industry-standard Transport Layer Security (TLS) protocols to encrypt all data transmitted between you and us to protect your personal and financial data. Your data is also encrypted while stored on our servers and when backed up and replicated between our data centers.
2. Limited Access. We restrict access to personal information to authorized employees, contractors, and agents who need to access and process this information.
3. Network Protection. We employ multiple layers of security controls in our environment to protect access and internal security, including firewalls, intrusion protection systems, and network isolation. Our security services are configured, monitored, and maintained according to industry best practices. We collaborate with leading security vendors to leverage their expertise and global threat intelligence to protect our systems.
4. Secure Data Centers. Our servers are located in enterprise-grade hosting facilities that employ robust physical security controls to prevent unauthorized physical access to the servers they host. These controls include 24/7/365 monitoring and surveillance, on-site security personnel, and regular security audits. We maintain geographically separated data copies to minimize the risk of data loss or downtime.
5. Security Monitoring. Our security team continuously monitors security systems, event logs, notifications, and alerts from various systems to identify and manage security threats.

Data Retention

Certain data can be deleted by you at any time, some data will be automatically deleted, and some data we will retain for longer periods when necessary. When deleting data, we ensure that your data is securely and completely removed from our servers or retained only in an anonymized form. Information will be retained until you delete it.

We provide a range of services that allow you to correct or delete data related to your account or stored data. For example, you can:

1. Edit information about yourself,
2. Delete a chat record, or
3. Completely delete your account.

We will retain this data until your account is closed, and we will keep it for five years after the account is closed or after your last contact with us to meet our regulatory and legal obligations and to defend ourselves against any claims, where applicable.

Long-Term Retention of Information for Specific Purposes

Sometimes, based on business and legal requirements, we need to retain certain information for specific purposes for a longer period. For example, when an individual self-excludes from using our services, we will retain that person's personal data for longer for responsible gaming purposes.

Reasons we may retain certain data for the long term include:

1. To protect you, others, and ourselves from fraud, abuse, illegal activities, and unauthorized access, we may take measures such as when we suspect someone is engaging in fraudulent activities, match-fixing, or money laundering.
2. To comply with tax, anti-money laundering, and other financial regulatory requirements, conduct accounting, or facilitate dispute resolution, for example, when we are a party to a financial transaction, including receiving your deposits and making payments to you.
3. To comply with applicable laws, regulations, legal processes, or enforceable government requests, or when necessary to enforce agreements, including investigating potential violations.
4. To ensure we provide ongoing services to you and other users.
5. If you communicate directly with us, such as through customer support channels, providing feedback, or reporting errors.

We are committed to protecting your personal information or the confidentiality of data we collect, use, and/or hold, in accordance with applicable data protection laws and regulations, particularly national data protection laws and other applicable international data protection regulations, such as the General Data Protection Regulation (GDPR) 2016/679.

Your Rights

You have specific rights regarding your personal data:

1. You have the right to know what personal data we hold about you.
2. You have the right to rectify or request the correction of inaccurate personal data related to you.
3. You have the right to access your personal data and request a copy in a machine-readable format, for example, if you wish to back up your data.
4. When we process personal data based on legitimate interests, you have the right to object to this. Please note that even if there are other relevant legal bases or compelling reasons for us to continue processing in a manner that aligns with our interests, we may still proceed with processing your personal data if your rights, interests, or freedoms do not outweigh those reasons.
5. In certain circumstances, you have the right to request that we delete your personal data, including deleting your account: (1) when we no longer need to process that data, (2) you have withdrawn your consent, and your consent was the legal basis for processing the data, (3) you have exercised your right to object, and there are no overriding legitimate grounds for processing, (4) your personal data has been processed unlawfully, (5) deletion of your personal data is required by law. Please note that we will not delete and will still retain data in cases such as when personal data needs to be retained based on our legitimate interests that outweigh your request; to comply with legal obligations; or in cases where it is necessary to establish, exercise, or defend legal claims.
6. In specific circumstances, you have the right to request that we restrict the processing of your personal data.
7. If we require your consent to process personal data, in that case, you have the right to withdraw your previously given consent. Please note that even if other relevant legal bases exist, we may still continue to process your personal data.
8. You have the right to object to direct marketing and related profiling (limited to data related to direct marketing). When it comes to marketing communications, you can request us to stop sending you such information at any time—just follow the unsubscribe instructions included in the marketing communication or send your request to luckybearpublic@gmail.com.
9. You have the right to lodge a complaint with your local data protection authority.

Please note that not all of the rights described above are absolute.You can exercise your rights at any time by adjusting your account or sending an email to luckybearpublic@gmail.com.Before we fulfill your request, we may need to provide evidence and confirm your identity.If you are not satisfied with how we process your personal data, please let us know by sending an email to luckybearpublic@gmail.com. We will review and investigate your complaint and aim to respond to you within a reasonable time.

Use of Google Analytics

We use Google Analytics to collect information about the usage of this website. Google Analytics collects information such as how often you visit the website, what pages you visit, and what other sites you used before visiting the website. Google Analytics only collects the IP address assigned to you when you visit the site, without collecting your name or other identifying information. We do not merge the information collected through the use of Google Analytics with your personal data. Although Google Analytics places a permanent cookie in your web browser to identify you as a unique user the next time you visit the website, that cookie can only be used by Google, and no one else can use it. According to Google Analytics' terms of use and Google's privacy policy, Google has limitations on the use and sharing of information collected about your visits to the website. You can prevent Google Analytics from recognizing you on your return visit to the website by disabling cookies in your browser.

If you wish, you can choose to opt out by disabling cookies in your web browser's preference settings. For more information about Google Analytics, please visit http://www.google.com/analytics/. To learn more about how Google uses cookies, please visit https://policies.google.com/technologies/cookies.

SSL Encryption

All important communications between users and the website are encrypted using Secure Socket Layer technology (SSL) with a 256-bit key.