Privacy Policy
LUCIANA NV is the owner and operator of the www.luckygames.be website dedicated to online games of chance and sports betting, hereinafter referred to as the "Website".
LUCIANA NV is a limited company under Belgian law with its head office at 2018 Anvers, Breydelstraat 9, registered under the business number CBE 0461.731.480. It holds an B+3825 license granted by the Belgian Gaming Commission, authorizing the Company’s online casino game activity, hereinafter the "Operator".
The Operator has also appointed a data protection officer within the meaning of Section 37 of European Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data. The Data Protection Officer is responsible for monitoring and ensuring the compliance of the personal data processing carried out by the Operator.
The Operator is concerned about personal data protection. We therefore do our utmost to protect the privacy of all users (hereinafter the “Users”) of our online game of chance and sports betting website (hereinafter the “Website”).
Users will find below all the provisions related to the processing of personal data, which are applicable to all uses of the Website by Users (hereinafter the “Privacy Policy”).
For any questions, please contact the Operator via the email address: [email protected].
1. General information
For the purposes and within the limits of the Privacy Policy, the Operator processes the personal data of the Website’s Users during all uses of the Website.
When processing said personal data, the Operator undertakes to comply with the laws and regulations in force, including, in particular, the Belgian Act of 30 July 2018 on the protection of privacy and European Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter the “Regulation”).
In this respect and in accordance with the Regulation, the Operator:
- is legally obliged to process the personal data of Users. This processing is outlined in Section 2.1 of the Privacy Policy;
- shall process personal data for the purposes of allowing Users to use the Website, as well as for the necessary and legitimate purposes outlined in Section 2.2 of the Privacy Policy;
- processes the personal data described in Section 3, in accordance with the purposes defined therein, subject to the User’s prior, explicit and freely given consent.
By accessing the Website, Users are deemed to have read and accepted the Privacy Policy.
Furthermore, they represent that the data and information communicated to the Operator is correct.
2. Personal data processing that does not require User consent
2.1. The Operator's legal obligations and processing required for use of the Website
In accordance with the statutory and regulatory obligations governing all online game of chance and sports betting operators and for the purposes of authenticating Users and granting them use of the Website, the Operator is legally required to process the following personal data for the purposes outlined below. This processing of personal data by the Operator does not require the consent of Users pursuant to Section 6.1.b) and c) of the Regulation; regarding the biometric data that the Operator is required to process pursuant to the Act of 7 May 2024 amending the Gambling Act of 7 May 1999, we shall ensure that we obtain your consent (Section 9.2.a) of the Regulation).
The personal data communicated by the User is saved on a register, as laid out in Section 7.1 below, which is controlled by the Operator and remains under its responsibility at all times.
Within the limits defined by the Regulation, the User shall also benefit from (certain) rights, as laid out in Section 4 below, which they can exercise in accordance with the provisions of Section 4.7.
a. What data is processed?
The following personal data is processed:
- first name(s) and surname, date of birth, language, sex, home/postal address, National Registration Number (or identity card or passport number), email address, home or mobile phone number;
- biometric data;
- bank details used to conduct deposit transactions on the Website and withdraw winnings;
- copies of personal documents for User authentication, such as a photo of an identity card, bank card or statement, proof of deposit or any other document proving the User’s home/postal address;
- the use, browsing and connection history of the Website (including browser data and IP address), notably by using cookies;
- any other personal data exchanged between the Operator and the User, in particular by email or live chat, in connection with the User’s registration or use of the online game of chance sports betting offer available on the Website.
b. What processing is carried out by the Operator?
Processing consists of collection, recording, storage, viewing, organization, use, reconciliation or any other necessary or useful action in accordance with the statutory and regulatory provisions referred to in Section 2.1.c) below. Processing may also involve the forwarding of personal data:
- to judiciary and administrative authorities, including the Gaming Commission and the Financial Intelligence Processing Unit (CTIF- CFI);
- to suppliers of the Operator whose services are inseparable from the use of the Website. A list of these suppliers may be obtained upon request by writing to one of the contact addresses provided in Section 7.5 below.
The Operator also reserves the right to share the data defined in Section 2.1.a) with other legal entities in its group, in order to fulfill the legal and contractual obligations referred to in Section 2.1.c) and the consequences of the entry into force of the Law of 18 February 2024, amending the Law of 7 May 1999 on games of chance, betting, gaming establishments and the protection of players and the separation of licenses used for online game of chance and sports betting operations.
c. What are the purposes of this processing?
1) The Operator must process the personal data referred to in Sections 2.1.a) and b) in order to fulfill the legal and regulatory obligations incumbent upon it, including the following legal provisions in particular:
- the Belgian Act of 18 September 2017 on the prevention of money laundering and terrorist financing and on the restriction of the use of cash;
- the Belgian Act of 7 May 1999 on gambling as was modified by the Act of 7 May 2024, and its implementing decrees, including with regard to player protection and responsible gambling.
2) The Operator also processes the personal data referred to in Section 2.1.a) for the purposes of authenticating Users in order to allow them to access and use the Website. This processing is carried out for the following purposes:
- management of User registrations and accounts;
- management of User deposits and winnings and, more generally, the online game of chance and sports betting offer;
- forwarding of information to Users regarding the services offered by the Operator;
- management of customer service, including customer support and the Risk & Fraud service.
2.2. Other processing not requiring User consent
The Operator also processes personal data for the legitimate purposes outlined below. This processing of personal data carried out by the Operator does not require User consent, in accordance with Section 6.1.f) of the Regulation.
The personal data communicated by the User is saved on a register, as laid out in Section 7.1 below, which is controlled by the Operator and remains under its responsibility at all times.
a. What data is processed?
The following personal data is processed:
- first name(s) and surname, date of birth, language, sex, home/postal address, email address, home or mobile phone number;
- the use, browsing and connection history of the Website (including browser data and IP address), notably by using cookies;
- any other information exchanged between the Operator and the User, in particular by email or live chat, in connection with the User’s registration or use of the online game of chance and sports betting offer available on the Website.
b. What processing is carried out by the Operator?
Processing consists of the collection, recording, storage, viewing, organization, use and reconciliation of the personal data outlined in Section 2.2.a). It also consists of forwarding this personal data to third parties, a list of whom may be obtained upon request by writing to one of the contact addresses provided in Section 7.5 below.
c. What are the legitimate purposes of this processing?
The Operator processes the personal data referred to in Section 2.2.a) for the following legitimate purposes:
- promotion, advertising and marketing, in particular via SMS text messages, telephone calls, and printed and digital newsletters;
- the execution of satisfaction surveys, statistical studies, trend analyses and market studies for the purposes of improving the online game of chance and sports betting offer, informing or protecting Users and preventing gaming addiction.
3. Personal data processing subject to User consent
By using the Operator's Website for any purpose whatsoever, Users express their freely given, specific, informed and unequivocal consent to expressly authorize the Operator to process their personal data in accordance with the Regulation, within the limits and for the purposes defined below and without prejudice to the processing referred to in Section 2.
The personal data communicated by the User is saved on a register, as laid out in Section 7.1 below, which is controlled by the Operator and remains under its responsibility at all times.
Users also benefit from rights, including the right to withdraw their consent at any time, according to the terms and conditions defined in Section 4.7.
3.1. Nature of the personal data processed
The Operator processes the following data:
- first name(s) and surname, date of birth, language, sex, home/postal address, National Registration Number (or identity card or passport number), email address, home or mobile phone number; the biometric data are processed with consent for legal purposes, as defined above (art. 2).
- bank details used to conduct deposit transactions on the Website and withdraw winnings;
- copies of personal documents for User authentication, such as a photo of an identity card, bank card or statement, proof of deposit or any other document proving the User’s home/postal address;
- the use, browsing and connection history of the Website (including browser data and IP address), notably by using cookies;
- any other information exchanged between the Operator and the User, in particular by email or live chat, in connection with the User’s registration or use of the online game of chance and sports betting offer available on the Website.
The personal data communicated by the User is saved on a register, as laid out in Section 7.1 below, which is controlled by the Operator and remains under its responsibility at all times.
3.2. Data processing
Processing consists of the collection, recording, storage, viewing, organization, use and reconciliation of the personal data referred to in Section 3.1. It also consists of forwarding this personal data to the Operator's entities.
3.3. Purposes of personal data processing
Personal data is collected and processed by the Operator for the following purposes:
- Promotion, advertising and marketing, including affiliation and loyalty program management, relating to the offer of online game of chance and sports betting services, including via SMS text messages, telephone calls, and printed and digital newsletters, that does not fall under Section 2.2.c), such as the Operator’s offline casino and gambling business, including any advertising and marketing within the limits provided for by law;
- Participation in competitions and promotional offers, including communications about winners;
- The development of the online game of chance and sports betting offer;
- The execution of satisfaction surveys, statistical studies, trend analyses and market studies for the purposes of management, marketing and reporting, including profiling, which do not fall under the purposes set out in Section 2.2.c).
4. Users’ rights
Without prejudice to Sections 2 and 5 herein, Users may exercise a right of rectification, opposition and restriction, in accordance with the following terms and restrictions.
4.1. Right of access
a. The Operator makes the following information available to Users:
- The identity and contact details of the data controller;
- The contact details of the Data Protection Officer (DPO);
- The personal data processed;
- The purposes of the personal data processing and the legal basis for such processing;
- The recipients or categories of recipients of personal data, if applicable;
- Where applicable, the data controller’s intention to transfer the personal data to a country located outside the European Union and either (i) the existence (or absence) of an adequacy decision adopted by the European Commission or, (ii) in the absence of such a decision, the guarantees offered by the third country in question and the measures implemented to obtain a copy of the personal data;
- The possibility to oppose the automated processing of their data, such as profiling, unless valid reasons exist rendering said processing by the Operator necessary, as well as the possibility to oppose all processing of their personal data for direct marketing purposes.
b. Users may request access to all the information mentioned in this section and in Section 3.1 at any time by writing to one of the contact addresses provided in Section 7.5 below. The Operator shall respond to such information requests within one month.
c. Users have the right to obtain a copy of their personal data which is processed. The Operator reserves the right to demand payment for the potential costs incurred due to this request; these costs will be calculated on the basis of administrative costs incurred due to the request and will not exceed €20.
d. Users shall have the right to be granted said access or obtain said copy of the personal data, in a structured format and in such a way that the personal data is provided in a format that complies with technical standards in force when the request for access is submitted; this format must allow the data to be machine-readable.
4.2. Right to rectification
The Operator guarantees Users the right and places them under an obligation to update and rectify any of their personal data that is incomplete or incorrect.
This right to rectification may be exercised by sending a request to one of the contact addresses provided in Section 7.5 below.
4.3. Right to opposition
The Operator hereby authorizes Users to oppose the processing of all or part of their personal data, for the following reasons:
- the data is inaccurate;
- the processing is no longer required for the purposes for which the data was collected;
- the User has withdrawn their consent;
- the data has been subject to illegal processing.
The Operator also authorizes Users to oppose:
- the automated processing of their data, such as profiling, unless valid reasons exist rendering said processing by the Operator necessary;
- any processing of their personal data for direct marketing purposes, including profiling, if it is linked to such direct marketing.
This right to opposition may be exercised by sending a request to one of the contact addresses provided in Section 7.5 below.
4.4. Right to be forgotten
The Operator also undertakes to respond as soon as possible to any request for the deletion of personal data (“right to be forgotten”), when:
- the processing is no longer required for the purposes for which the data was collected;
- the User has withdrawn their consent;
- the data has been subject to illegal processing, or must be deleted due to a legal obligation;
- the User opposes the automated processing of their data, such as through profiling, and there are no valid reasons rendering said processing by the Operator necessary;
- the User opposes the processing of their personal data for direct marketing purposes, including profiling, if it is linked to said direct marketing.
4.5. Right to restriction
Users shall also have the right to obtain from the Operator the restriction of the processing of their personal data, when:
the User considers their personal data to be incorrect, for the time required for the Operator to verify the accuracy of the data in question;
the processing is illegal but the User does not wish for their data to be deleted but requests a restriction of the data processing;
the User opposes automated processing, including profiling or the processing of their personal data for direct marketing purposes, and it is necessary to verify the legitimacy of the reasons for which the Operator intends to carry out this processing;
the Operator no longer needs the personal data processed but the person concerned wants them to be saved for the observation, exercise or defense of rights in court.
This right to restriction may be exercised by sending a request to one of the contact addresses provided in Section 7.5 below.
4.6. Transfer of data to a data controller
Users are authorized to transfer the personal data processed automatically by the Operator under Sections 2.2 and 3 to another data controller without the Operator being able to prevent said transfer.
Users are authorized to request from the Operator that the transfer be carried out directly by its data controller, insofar as such a transfer is technically possible.
4.7. Terms and conditions
The rights granted to Users by the Operator shall be exercised in accordance with the terms and conditions defined in Section 7.5 below.
4.8. Notification
The Operator shall send a notification to the User of any deletion or rectification of data carried out by it in accordance with Sections 4.2 and 4.4, unless such notification proves to be impossible or requires a disproportionate effort on the part of the Operator.
This notification will be sent by email or by post, using the details communicated by the User.
5. Personal data location, storage and retention period
5.1. The Operator uses appropriate and secure methods to store Users’ personal data in a format that ensures the identification and availability of the data.
The data is stored and hosted in Belgium by Data Center, which offers all the necessary and useful security guarantees in accordance with applicable technical standards.
5.2. Users’ personal data is stored by the Operator for the purposes defined in Sections 2 and 3. The data is stored for a period of ten (10) years for all the purposes mentioned under Section 2.1.c); the Operator therefore reserves the right to retain Users’ personal data for all purposes required by law in view of its online game of chance and sports betting activity. Users therefore represent that they have been informed and accept that, in order to comply with its legal obligations, the Operator shall retain their personal data as referred to under Section 2.1.a) for a period of at least ten (10) years as from the player’s last activity on the Website.
The personal data shall be stored for a period not exceeding the period required to fulfill any and all of the purposes of processing defined in Sections 2.2 and 3. The data shall then be deleted from the Operator’s files at the User’s request, by writing to one of the contact addresses provided in Section 7.5 below.
5.3. Some of the Users’ personal data may be transferred to service providers located outside of the European Economic Area. This concerns data for which:
- the European Commission has adopted an adequacy decision recognizing that the service providers in question offer an adequate level of protection for the data transferred to them by a European entity;
- the Operator has provided appropriate guarantees, mainly due to the use of standard contractual clauses (SCCs) drawn up by the European Commission.
The personal data is therefore transferred on one of these two bases.
6. Responsibility of the Operator – Data processor
6.1. The Operator undertakes to process Users’ personal data lawfully, fairly and transparently with respect to the User concerned. All data processing performed by the Operator shall comply with the requirements of the Belgian law of 30 July 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and this Privacy Policy.
The Operator implements all reasonable and appropriate methods to ensure the confidentiality, integrity and availability of the personal data it processes.
The technical measures include notably anonymization and encryption of personal data, depending on the required purpose.
Organizational measures mainly include the performance of internal audits, in addition to the audits that may be conducted on the Operator by the Gaming Commission, for example.
If necessary and with the help of the Data Protection Officer, the Operator shall carry out an impact analysis when the processing of data is liable to cause a heightened risk for Users.
6.2. Users’ personal data will not be transferred to third parties other than the Operator’s providers and partners, except for the purposes set out in Sections 2.1, 2.2 and 3, i.e., if:
- the transfer is made compulsory by a law, regulation or injunction issued by an administrative or judicial authority;
- the transfer is required for the provision of the online game of chance and sports betting offer or maintenance services;
- the User has given their consent to such transfer.
The partner will not be considered as a data processor unless such partner processes Users’ personal data on behalf of the Operator. The Operator accepts no liability regarding the processing of User’s personal data by a partner providing its own services in its own name and on its own behalf, or if the Operator can prove that it is in no way responsible for any damage caused.
Where the Operator is acting as the partner’s data processor, it is agreed that the Operator shall only be held liable for damage caused by the processing of personal data in breach of the Regulation or this Privacy Policy (i) if it has breached the obligations specifically incumbent on data processors pursuant to the Regulation, or (ii) if it has acted outside of or contrary to the partner’s lawful instructions. Similarly, the Operator’s liability i) cannot be incurred in any way whatsoever if it can prove that it is in no way responsible for the event that caused the damage and ii) remains subject to the limitation of liability provisions of Section 11 of the Website Terms of Use.
6.3. The Operator shall ensure that, when processing is carried out by a data processor on behalf of the Operator said data processor shall provide sufficient guarantees as to the implementation of appropriate technical and organizational measures and, more generally, its compliance with the requirements of the Regulation. In particular, the Operator shall require the data processor to comply with the Regulation and, consequently, to keep a register.
6.4. The Operator undertakes to notify the data protection authority referred to in Section 7.4 below as soon as possible in the event of a security issue that could affect the confidentiality of the data processed.
The Operator shall also inform the Users concerned, insofar as the violation of personal data presents a heightened risk for Users’ rights and freedoms. Such notification shall be sent by email or by post using the contact details provided by the User.
7. Other provisions
7.1. Personal data register
As the data controller for the processing of personal data, the Operator keeps a register of all its processing activities. This register contains all information relating to the type of data processed, data subjects, the potential recipients to whom the data is communicated (where applicable), the purposes for which the data is processed, the data retention period and a general description of the technical and organizational security measures implemented.
The personal data communicated by the User is recorded, along with the processing operations carried out and the purposes thereof, in a register that is controlled by the Operator and remains under its responsibility at all times. This register includes, in addition to the aforementioned information:
- a description of the purposes of the processing;
- a description of the categories of data subjects and personal data;
- the categories of recipients to whom the personal data has been or will be communicated, including any recipients in third countries or international organizations;
- the expected deadlines for the deletion of various categories of data;
- a general description of the organizational and technical measures implemented with regard to data confidentiality and security.
7.2. Completeness – Amendments to the Privacy Policy
This Privacy Policy contains all the contractual provisions enforceable against Users, without prejudice to the general provisions contained in the Website Terms of Use, of which they form an integral part. The Website Terms of Use therefore remain applicable for any matter not related to personal data protection.
The Operator also reserves the right to amend the Privacy Policy. All changes shall be enforceable against Users as soon as they are published on the Website. The Operator undertakes to mention the date of publication of the Privacy Policy in force on the Website.
7.3. Probative value
Users acknowledge that the electronic documents exchanged and electronic data collected in connection with their registration or use of the Website shall have the same probative value as if such documents and data had been communicated or collected via printed media. Users therefore agree not to contest the documents’ validity or probative value on grounds of their digital format.
7.4. Data protection authority
Conforming to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the law of 30 July 2018, Users have the right to request extra information or make a complaint to the Data protection authority. The Data Protection Authority shall fulfil the role of supervisory authority. Its contact details are as follows:
Address: Rue de la Presse, 35, 1000 Brussels, Belgium
Telephone: +32 (0)2 274 48 00
Email: [email protected]
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