Privacy Policy
This Privacy Policy explains how Lucky Ones Casino, operating via the website luckyonesbet-ca.com, collects, uses, discloses, and protects personal information of Canadian players and website visitors (including unregistered visitors). It applies to all access to and use of our services, games, and related features provided through luckyonesbet-ca.com to users located in Canada (excluding Ontario). By using our website or services, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is effective as of 1 January 2025 and remains in force until replaced or updated, with key provisions aligned through at least 31 December 2026.
Who We Are
OBSERVE: Identify operator, group structure, and contact channel. EXPAND: Clarify roles of entities involved in operating and processing. REFLECT: Provide clear contact point for privacy-related issues.
The online gaming services offered at luckyonesbet-ca.com for Canadian users (excluding Ontario) (the "Site") are owned and operated by:
- Operator: Dama N.V., a company incorporated under the laws of Curaçao, registration number 152125, licensed to provide online gaming services under Master License 8048/JAZ2020-13 (Antillephone N.V.) and direct license OGL/2023/174/0082 issued by the Curaçao Gaming Control Board.
- Group payment agent: Friolion Limited, a company registered in Cyprus under number HE 419102, acting primarily as a payment processing and support entity, including for fiat card and e-wallet transactions.
For the purposes of data protection and privacy, Dama N.V. is the primary data controller in relation to personal information processed via luckyonesbet-ca.com for Canadian players, with Friolion Limited acting as a group processor and/or joint controller for certain payment-related activities.
Registered / legal addresses: The precise street addresses of Dama N.V. in Curaçao and Friolion Limited in Cyprus are not specified in this policy; they are available on request and may also be published on the relevant corporate or regulator registers. Until then, the principal place of gaming regulation and dispute jurisdiction is Curaçao.
Data Protection Contact / DPO-equivalent:
- Email: [email protected] (primary contact for privacy, data protection, and general support queries)
- Website contact: You may also contact us via any online forms or live chat tools made available on luckyonesbet-ca.com from time to time.
Please clearly mark all privacy-related communications with "Privacy" or "Personal Data Request" in the subject line so they can be directed to the responsible data protection personnel.
What Personal Data We Collect
OBSERVE: Identify data categories required to provide and secure gambling services. EXPAND: Consider AML/KYC, responsible gambling, and technical operation needs. REFLECT: Group data logically for transparency and risk awareness.
Account and Identity Data
- Identification and contact data: Full name, username, date of birth, country and province/territory of residence, address (where requested), email address, phone number(s), language and currency preferences.
- Verification / KYC data: Copies or details of government-issued identification (e.g., passport, driver's licence), proof of address (utility bills, bank statements), payment account ownership proofs, and any additional documents required under applicable KYC/AML rules or by our payment providers.
- Account profile data: Account registration date, status (active, self-excluded, closed), communication preferences, internal risk and verification flags, and notes relating to responsible gambling interactions.
Technical and Usage Data
- Technical identifiers: IP address, approximate location inferred from IP, device identifiers, browser type and version, operating system, screen resolution, language settings, and similar technical information.
- Log data: Dates and times of access, login attempts, session durations, clicked links, visited pages, error logs, and other system event logs.
- Cookies and similar technologies: Unique cookie identifiers, local storage data, and tracking pixels used for functional operation, analytics, and (where you consent) marketing and personalization. Details are provided in the "Cookies & Tracking Technologies" section.
Gaming and Behavioural Data
- Gameplay data: Game types played, stakes, wins and losses, betting history, bonus usage, tournament participation, and in-game behaviour metrics (where tracked).
- Responsible gambling data: Deposit limits, loss and session limits, reality checks, self-exclusion status and history, time-out requests, and records of responsible gambling interventions.
- Interaction data: Clickstream data, navigation paths, responses to on-site messages, and engagement with promotional offers.
Payment and Financial Data
- Transaction data: Deposits, withdrawals, bonus credits and redemptions, chargebacks, reversals, payment method used, transaction amounts, currencies, timestamps, and transaction identifiers.
- Payment method data: Partially masked card numbers, card type, expiry date, issuing country, e-wallet identifiers, bank account identifiers (where applicable), and verification data to confirm ownership and prevent fraud.
- Anti-fraud and AML data: Internal risk scores, sanctions/matches screening results (where permitted), and audit trails created to comply with anti-money laundering and counter-terrorist financing obligations.
Communications and Support Data
- Support records: Emails, chat logs, support tickets, call notes (if calls are recorded or summarized), complaint records, and any documents or screenshots you submit to our support team.
- Marketing and survey data: Your opt-in/opt-out status, responses to surveys, feedback, ratings, and participation in promotions or loyalty programs.
Special Categories and Children's Data
- We do not intentionally collect sensitive personal data (e.g., health, political opinions) other than limited information potentially inferred from responsible gambling communications (e.g., references to gambling-related harm). Such information is processed only to support safer gambling and is protected with heightened care.
- Our services are strictly limited to adults. We do not knowingly collect data from individuals under the legal gambling age in their jurisdiction; any such data will be deleted once identified.
Legal Basis for Processing
OBSERVE: Align processing with applicable legal grounds. EXPAND: Include contractual necessity, legal duties (KYC/AML), consent, and legitimate interests. REFLECT: Clarify which basis applies to which main data uses.
Performance of a Contract
- We process personal data to enter into and perform the user agreement between you and Lucky Ones Casino, including:
- Creating and administering your Lucky Ones Casino account on luckyonesbet-ca.com;
- Verifying your eligibility to participate in real-money gaming (age, residence, permitted jurisdictions);
- Processing deposits, bets, winnings, bonuses, withdrawals, and loyalty rewards;
- Providing customer support and managing your account settings and limits.
Compliance with Legal and Regulatory Obligations
- As a licensed gambling operator, we are required by Curaçao regulatory frameworks, applicable anti-money laundering and counter-terrorist financing rules, and general record-keeping obligations to:
- Verify your identity and age and retain evidence of such verification;
- Monitor transactions and gameplay for suspicious patterns and report certain activities to competent authorities where required;
- Maintain proper accounting and tax records and comply with regulatory reporting duties;
- Respect responsible gambling obligations, including maintaining self-exclusion and limit records.
Legitimate Interests
- We rely on legitimate interests where these are not overridden by your rights and freedoms, including:
- Security and fraud prevention: Protecting our Site, systems, accounts, and users against unauthorized access, abusive behaviour, chargebacks, and financial crime;
- Service improvement and analytics: Analyzing aggregated usage and performance data to enhance our games, features, and user experience;
- Enforcing our terms: Investigating and responding to suspected breaches of our Terms and Conditions, Bonus Rules, or applicable laws;
- Internal administration: Managing internal reporting, audit trails, risk management, and corporate governance.
Consent
- We will rely on your explicit consent where required by applicable law, including:
- Sending electronic direct marketing (e.g., email, SMS, push notifications) that is not otherwise permitted on another legal basis;
- Using certain non-essential cookies or similar technologies for targeted advertising or advanced personalization;
- Processing any particularly sensitive information disclosed voluntarily in the context of responsible gambling support, to the extent necessary to assist you.
- You may withdraw consent at any time using the methods described in the "Your Rights" and "Cookies & Tracking Technologies" sections. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal.
Purpose of Processing
OBSERVE: Map data uses to functional needs. EXPAND: Include regulatory, commercial, and responsible gambling purposes. REFLECT: Present purposes clearly and link them to legal bases.
Provision and Management of Casino Services
- Creating, verifying, and managing your Lucky Ones Casino account;
- Operating casino games, bet placements, tournaments, and related gaming features;
- Processing deposits, withdrawals, and payment-related operations via Dama N.V., Friolion Limited, and other payment partners;
- Providing multi-language customer support and handling inquiries, complaints, and technical issues.
Legal, Regulatory, and Responsible Gambling Purposes
- Complying with Curaçao licensing conditions and other applicable legal requirements;
- Conducting KYC and AML/CTF checks, transaction monitoring, and record keeping;
- Implementing responsible gambling tools (limits, self-exclusion, reality checks) and documenting interactions to mitigate gambling-related harm;
- Responding to law enforcement or regulatory requests, court orders, or legal claims.
Improvement, Analytics, and Personalization
- Monitoring performance, stability, and security of our services and infrastructure;
- Carrying out statistical and analytical research based on aggregated or pseudonymized data to improve game offerings, UX design, and marketing effectiveness;
- Personalizing certain aspects of your experience (such as language, recommended games, and promotions) based on your profile and preferences, subject to applicable consent requirements.
Marketing and Promotions
- Sending newsletters, bonus offers, tournament announcements, and promotional campaigns by email, SMS, push notifications, or on-site messages, where permitted by law and your consent or preferences;
- Measuring effectiveness of marketing activities and adjusting campaigns accordingly, including in cooperation with affiliates and advertising networks where you have consented to such marketing technologies.
Security, Fraud Prevention, and Dispute Management
- Detecting, investigating, and preventing fraudulent or abusive activities, bonus abuse, account takeovers, collusion, and other breaches of our Terms and Conditions;
- Maintaining logs and evidence necessary for internal investigations, dispute resolution with players, payment providers, affiliates, or third parties, and for defending legal claims;
- Cooperating with recognized third-party complaints or alternative dispute resolution (ADR) platforms, such as Casino.guru and AskGamblers, to address user grievances.
Disclosure & Sharing
OBSERVE: Identify typical recipients (processors, regulators, partners). EXPAND: Consider payment, hosting, analytics, ADR, and affiliate networks. REFLECT: Specify safeguards, purposes, and limits of sharing.
Group Companies and Service Providers
- Group entities: We share data within our corporate group, primarily with:
- Dama N.V. (Curaçao) as the main operator and controller;
- Friolion Limited (Cyprus) as a payment processing and support entity.
- Technical and infrastructure providers: Hosting providers, cloud and database services, email delivery services, customer support tools, security and anti-DDoS services, and analytics platforms that process data strictly under our instructions.
- Payment partners: Banks, card schemes, payment processors, e-wallet providers, and other financial intermediaries involved in deposits, withdrawals, and chargeback handling.
Regulators, Authorities, and Legal Counterparties
- Gaming regulators, especially in Curaçao, for licensing supervision, reporting obligations, compliance reviews, and dispute resolution where required;
- Law enforcement, courts, and governmental authorities where disclosure is required by law, necessary to establish, exercise, or defend legal claims, or to prevent or detect unlawful activities;
- Tax and accounting professionals, auditors, or legal advisors acting under confidentiality obligations to support our regulatory and governance duties.
Affiliates, Marketing, and Advertising Partners
- Affiliate networks: We may share limited information (such as tracking identifiers, registration and deposit confirmation, and anonymized performance data) with affiliates who referred you to luckyonesbet-ca.com for attribution and commission calculation.
- Advertising and analytics partners: Where you consent to marketing cookies or similar technologies, we may allow selected partners to collect or receive data (e.g., device and interaction data) via our Site for analytics and advertising purposes.
Alternative Dispute Resolution and Complaints Platforms
- In the event of a dispute or complaint that you raise via recognized ADR or complaints platforms (e.g., Casino.guru, AskGamblers), we may share relevant account, transaction, and communication records with such platforms to help resolve your complaint. This occurs only with appropriate safeguards and limited to data strictly necessary for the specific case.
Business Transfers
- If we undergo a corporate transaction such as a merger, acquisition, restructuring, or sale of all or part of our business, personal data may be transferred to the relevant third parties as part of the transaction, subject to confidentiality and data protection safeguards. In such cases, we will ensure that your rights are preserved and that you are informed of any material changes.
International Transfers
OBSERVE: Identify cross-border flows (Canada - Curaçao - EU etc.). EXPAND: Clarify safeguards for jurisdictions without equivalent protection. REFLECT: Emphasize contractual and technical protections.
- Your data may be processed in, or transferred to:
- Curaçao: Where Dama N.V. operates and where the primary gaming license and regulatory oversight are located;
- Cyprus and other EEA locations: Where Friolion Limited and some service providers may be established;
- Other countries: Where certain technical, payment, or analytics providers host or process data, which may include jurisdictions outside Canada and the European Economic Area.
- Whenever we transfer personal data internationally, we take appropriate measures to ensure an adequate level of protection, which may include:
- Using standard contractual clauses or equivalent data transfer agreements approved under applicable data protection frameworks;
- Implementing technical safeguards such as strong encryption in transit and at rest, strict access controls, and minimization of stored data;
- Limiting transfers to what is strictly necessary for the relevant processing purpose (e.g., payment execution, hosting, support).
- By using luckyonesbet-ca.com, you acknowledge that your data may be processed outside your province or country of residence, including in Curaçao and the EU, under the safeguards described above.
Data Retention
OBSERVE: Retention needs arise from gaming, AML, tax, and dispute requirements. EXPAND: Differentiate by data category and purpose. REFLECT: Provide typical timeframes and deletion criteria extended through 2026.
General Principles
- We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including:
- Operating your Lucky Ones Casino account on luckyonesbet-ca.com;
- Complying with legal, regulatory, and reporting obligations;
- Resolving disputes and enforcing our agreements;
- Maintaining appropriate records for audit and security purposes.
- Where applicable laws require minimum retention periods (for example, for AML or accounting records), we will retain data for at least those periods, typically up to 5 - 10 years from the relevant event depending on the category and jurisdiction.
Typical Retention Periods
- Account and identification data: Generally retained for the duration of your active account and for up to 5 years after account closure or last meaningful interaction, unless a longer period is required by AML, regulatory, or legal obligations.
- KYC and AML documentation: Copies of identification documents, address proofs, and AML investigation records are typically retained for up to 5 - 10 years from the date of collection or from the end of the business relationship, in line with applicable AML/CTF rules.
- Transaction and financial data: Deposits, withdrawals, and related accounting records are retained for at least 5 years following the relevant transaction, or longer where required for tax or financial reporting.
- Gameplay and behavioural data: Retained for as long as needed to provide services, support responsible gambling, and address disputes, typically up to 5 years after account closure, after which it may be anonymized or aggregated.
- Marketing data: Data used solely for marketing is retained until you withdraw your consent or object to such processing, or until it becomes obsolete due to inactivity, after which it may be anonymized or deleted.
- Logs and security data: Technical logs and security-related records are generally retained for shorter periods (often 6 - 24 months), unless extended retention is necessary for security investigations or legal purposes.
Deletion and Anonymization
- When data is no longer needed and no legal obligation requires its retention, we will:
- Securely delete or irreversibly anonymize the data so that it can no longer be associated with an identifiable individual; or
- Archive it with restricted access where limited retention is still required.
- Where you request deletion of your data and no overriding legal ground exists to keep it, we will delete or anonymize it in line with our internal procedures and applicable laws.
Your Rights
OBSERVE: Align with strong privacy standards similar to GDPR. EXPAND: Provide clear procedures, timeframes, and fee rules. REFLECT: Enable users to exercise control over their data across jurisdictions, even where specific statutes differ.
Regardless of your province of residence in Canada (excluding Ontario, which we do not actively target), we aim to align our privacy practices with robust international standards such as those reflected in the EU's GDPR. The references below are for clarity and do not themselves create EU or Mexican jurisdiction over our operations.
Right of Access
- You may request confirmation as to whether we process your personal data and, if so, obtain a copy of such data, together with information about the purposes of processing, categories of data, and recipients.
Right to Rectification
- You may request that we correct or complete inaccurate or incomplete personal data relating to you, for example if your contact details, address, or payment information changes.
Right to Erasure ("Right to be Forgotten")
- You may request deletion of your personal data where:
- The data is no longer necessary for the purposes for which it was collected;
- You have withdrawn consent (where consent was the basis) and no other legal ground applies;
- You have successfully objected to the processing (see below); or
- The data has been unlawfully processed.
- We may not be able to delete data where retention is required by law or where necessary to establish, exercise, or defend legal claims, particularly in AML, gaming, and accounting contexts.
Right to Restriction of Processing
- You may request that we restrict processing of your data (other than storage) where:
- You contest the accuracy of the data (for the duration of our verification);
- Processing is unlawful, and you prefer restriction to deletion;
- We no longer need the data, but you require it for legal claims; or
- You have objected to processing and we are considering our legitimate grounds.
Right to Object
- You may object at any time to processing of your personal data based on our legitimate interests (including profiling), on grounds relating to your particular situation. We will assess your request and cease processing unless we have compelling legitimate grounds that override your interests or where processing is needed for legal claims.
- You may always object to direct marketing, including profiling related to such marketing, in which case we will stop using your data for that purpose.
Right to Data Portability
- Where processing is based on consent or contract and carried out by automated means, you may request to receive your personal data in a structured, commonly used, machine-readable format and, where technically feasible, to have it transmitted directly to another controller.
Right to Withdraw Consent
- Where we rely on your consent (e.g., for marketing communications or certain cookies), you may withdraw that consent at any time by:
- Using the unsubscribe or settings links in our emails or messages;
- Adjusting your notification or marketing preferences in your Lucky Ones Casino account, where available;
- Contacting us at [email protected].
- Withdrawal will not affect the lawfulness of processing carried out before withdrawal, but we will stop further processing based on that consent.
Procedure, Timeframes, and Cost
- How to exercise your rights: Please contact us by email at [email protected], clearly indicating:
- Your full name and registered account details (if applicable);
- The specific right(s) you wish to exercise; and
- Any relevant context or supporting information.
- Verification: To protect your privacy, we may request additional information or documentation to verify your identity before acting on your request.
- Timeframes: We aim to respond to all valid requests without undue delay and, in principle, within 30 days of receipt. If your request is particularly complex or we receive numerous requests, we may extend this period, in which case we will inform you of the extension and reasons.
- Fees: Requests are handled free of charge. However, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded or excessive, in particular because of their repetitive character.
Cookies & Tracking Technologies
OBSERVE: Cookies support core operations, analytics, and marketing. EXPAND: Distinguish types and control mechanisms. REFLECT: Provide clear, actionable guidance on managing preferences.
Types of Cookies We Use
- Strictly necessary (functional) cookies: Essential for the operation of luckyonesbet-ca.com, enabling basic functions such as secure login, session management, navigation, and account-related features. These cookies are generally set in response to your actions and cannot be switched off in our systems, though you may block them through your browser (which may impair functionality).
- Preference cookies: Remember your choices (such as language, currency, and display preferences) to provide a more personalized experience on subsequent visits.
- Analytics and performance cookies: Collect aggregated data about how visitors use our Site (e.g., most visited pages, error occurrences, device statistics) to help us improve performance, usability, and content. These may be provided by internal tools or third-party analytics services.
- Advertising and targeting cookies: Used, where you consent, to deliver more relevant advertising, to measure campaign effectiveness, and to limit how often you see a particular ad. These cookies may be set by us or by our advertising partners via our Site.
Similar Technologies
- We may use technologies functionally similar to cookies, such as:
- Local storage and session storage in your browser;
- Tracking pixels (web beacons) in emails or on pages to measure engagement;
- Device identifiers used by mobile or desktop applications, if applicable.
Cookie Management
- Browser settings: Most web browsers allow you to:
- View which cookies are stored on your device;
- Delete cookies individually or all at once;
- Block cookies from specific websites or all websites;
- Block third-party cookies.
- Internal controls: Where available, we may provide an on-site cookie banner or preference centre that allows you to accept or reject non-essential cookies (e.g., analytics, advertising) while keeping essential cookies active.
- Advertising choices: Depending on your jurisdiction and device, you may have additional tools (such as device settings or industry opt-out pages) to control interest-based advertising.
Data Security
OBSERVE: Gaming platforms hold high-value financial and behavioural data. EXPAND: Address technical, organizational, and procedural safeguards. REFLECT: Emphasize continuous risk management rather than absolute guarantees.
Technical and Organizational Measures
- Encryption: We use TLS 1.2 or higher to encrypt data in transit between your browser and our servers. Sensitive data at rest (such as hashed passwords and certain financial data) is stored using industry-standard encryption and hashing algorithms.
- Access controls: Personal data is accessible only to authorized personnel with a legitimate "need to know" for their role. Access is managed via role-based permissions, strong authentication, and logging.
- Authentication and account security: We require strong, unique passwords and may offer or mandate multi-factor authentication (MFA) for certain administrative or high-risk access points. We encourage players to enable any additional security features available.
- Network and system security: Firewalls, intrusion detection and prevention systems, anti-malware tools, and other security technologies are used to protect our infrastructure. Regular backups and redundancy strategies help minimize data loss risks.
Governance, Training, and Audits
- Internal policies: We maintain internal information security and data protection policies defining how staff must handle personal data and respond to incidents.
- Staff training: Employees and contractors with access to personal data receive periodic training on security, confidentiality, and responsible gambling-related privacy considerations.
- Vendor oversight: Third-party service providers processing personal data on our behalf are selected based on their security posture and are bound by contractual data protection obligations.
- Audits and reviews: We regularly review and update our technical and organizational measures, and we seek to align them, where feasible, with recognized international security practices (such as ISO 27001 or SOC 2-inspired controls), while not asserting formal certification unless explicitly stated on our Site.
Incident Response
- We maintain procedures to detect, respond to, and remediate personal data breaches or other security incidents, including:
- Investigation and containment of the incident;
- Assessment of potential risks to affected individuals;
- Implementation of corrective and preventive actions;
- Notification to relevant authorities and, where required by law, to affected individuals, in a timely manner.
- While we take robust measures to protect your data, no system can be guaranteed as completely secure. You also play an important role by keeping your login credentials secret, using strong passwords, and promptly notifying us of any suspected unauthorized account activity.
Complaints & Contacts
OBSERVE: Users need clear routes to raise concerns. EXPAND: Provide internal escalation steps and external oversight options. REFLECT: Encourage resolution with the operator while recognizing the user's right to escalate.
Contacting Us
- Primary contact for privacy and support: [email protected]
- Website: https://luckyonesbet-ca.com
Please include sufficient information to identify your account (if you have one) and clearly describe your concern or request.
Internal Complaint Procedure
- Submission: Send your complaint or question to [email protected], indicating that it relates to "Privacy" or "Data Protection".
- Acknowledgement: We will aim to acknowledge receipt of your complaint within 5 business days.
- Investigation: Your complaint will be reviewed by the appropriate internal team, which may request additional information or clarification.
- Response: We will provide a substantive reply without undue delay and, in principle, within 30 days from receipt of your complete complaint. If more time is needed due to complexity, we will inform you of the delay and expected timeframe.
- Escalation within the company: If you are not satisfied with the initial response, you may request that your complaint be escalated to a senior manager or designated data protection contact.
External Recourse and Supervisory Authorities
- Depending on your province in Canada, you may have the right to lodge a complaint with your local privacy or information commissioner or equivalent authority. Contact details differ by province; please consult your provincial government resources.
- As our primary gaming regulation and dispute jurisdiction is Curaçao, you may also contact:
- Curaçao Gaming Control Board (GCB) - for issues related to gaming regulation and licensing.
- For gambling-related disputes that include privacy elements, you may also raise a complaint through recognized third-party platforms such as:
- https://casino.guru
- https://askgamblers.com
Updates
OBSERVE: Policies evolve with legal and operational changes. EXPAND: Ensure users know when and how changes occur. REFLECT: Provide transparency, advance notice for significant changes, and user options.
Changes to This Privacy Policy
- We may update this Privacy Policy from time to time to reflect changes in our services, legal or regulatory developments, or our internal practices.
- Each version of the Privacy Policy will be identified by the "Last updated" date indicated below. Material changes will be summarized in a change note or short changelog accessible on or from the Privacy Policy page.
Notification of Material Changes
- For significant changes that materially affect your rights or how we process your data, we will:
- Provide notice at least 30 days in advance, where reasonably practicable;
- Use one or more of the following channels:
- Email to the address registered on your Lucky Ones Casino account;
- Prominent banner or pop-up notification on luckyonesbet-ca.com;
- In-account dashboard alerts upon login.
- During this notice period, you may review the updated policy and decide whether to continue using our services.
Your Options Following Updates
- If you do not agree with the updated Privacy Policy, you may:
- Adjust your privacy, marketing, or cookie preferences where such settings are available; and/or
- Request closure of your account and, where applicable, exercise your data protection rights as described in the "Your Rights" section.
- Continued use of luckyonesbet-ca.com after the effective date of an updated Privacy Policy will signify your acceptance of the changes.
Last updated: January 2025 (with key provisions intended to remain aligned through at least December 31, 2026).