Privacy Policy

The present Privacy Policy has been approved by the Island Lukkly B.V. Executive Management and last updated on October 5th, 2025.

This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our websites, products, or services.

1. INTRODUCTION

At Lukkly Casino, we value your trust and are committed to protecting your privacy.

We act in full compliance with:

• the EU General Data Protection Regulation (GDPR),
• the Curaçao Gaming Authority (CGA) Data Protection and Responsible Gaming Guidelines (2024–2025), and
• other applicable AML, consumer protection, and e-privacy regulations.

If you do not agree with any part of this Policy, please do not use our websites or services. By continuing to play or interact with our platform, you confirm that you have read and accepted this Privacy Policy.

2. CONTACT INFORMATION

For general questions or account matters, privacy and data rights, please contact our Support Team at: support@lukkly.com. 

If your concern relates to regulatory compliance or data protection breaches, you may also contact the Curaçao Gaming Authority (CGA) via their official website.

3. INFORMATION WE COLLECT

We only collect information that is necessary to operate our gaming platform, comply with the law, and protect players.

When you register or verify your account:

• Full name, date of birth, gender, and contact details;
• Identity documents and proof of address (for KYC/AML verification);
• Payment information (bank or wallet details);
• Login credentials (username, encrypted password).

During gameplay, making deposits and/or withdrawals:

• Game activity, deposits, withdrawals, and bonuses;
• Device, IP address, browser information;
• Responsible gaming preferences, self-exclusion or session limits (if applied). 

Data from the third-party sources:

• Payment processors, identity verification partners, and AML screening providers; 
• Public or open databases for due diligence purposes. 

We do not collect unnecessary data and never request information unrelated to legitimate gaming or compliance activities.

4. HOW WE USE YOUR DATA

Your personal data is processed for the following purposes and legal bases:

A. Contractual necessity

• To register, operate, and maintain your player account;
• To process payments, withdrawals, and bonuses;
• To verify your identity and age. 

B. Legal obligation

• To comply with AML/CTF, tax, and licensing regulations;
• To cooperate with lawful investigations by CGA or financial authorities;
• To prevent fraud, underage gambling, and misuse of funds. 

C. Legitimate interests

• To improve platform security, usability, and performance;
• To detect and prevent multiple accounts or fraudulent behaviour;
• To maintain records for audit and dispute resolution; 

D. Consent

• To send marketing emails or promotions (only if you opted in);
• To use non-essential cookies and analytics tools;

You can withdraw consent at any time by changing your account settings or contacting us.

We do not use your personal data for automated decision-making that produces legal effects without human oversight.

5. DATA MINIMIZATION AND ACCURACY

We ensure that the information we hold is:

• adequate, relevant, and limited to what is necessary (“data minimization”);
• accurate and kept up to date;
• securely stored and deleted when no longer required.

Players are encouraged to update their information through their account settings or by contacting support.

6. SHARING YOUR INFORMATION

We may share your information only when necessary, and always securely:

With service providers:

• Payment processors, KYC verification partners, anti-fraud and cybersecurity vendors;
• Licensed game suppliers and software providers.

With regulators and authorities:

• The Curaçao Gaming Authority (CGA) and other competent authorities, when legally required;
• Law enforcement agencies for investigation of fraud, AML, or regulatory breaches

We do not sell, rent, or trade your personal data.

7. INTERNATIONAL DATA TRANSFERS

Your data may be securely stored or processed outside the EEA, including in Curaçao, the Netherlands, Kahnawake, or other jurisdictions where our technical infrastructure or partners are located.

Whenever data is transferred internationally, we apply Standard Contractual Clauses (SCCs) and equivalent safeguards to maintain the same level of protection.

8. SECURITY MEASURES

We employ advanced technical and organizational measures to safeguard your data:

• SSL 128-bit encryption for all transmitted data
• PCI DSS compliance for all payment handling
• 24/7 intrusion detection and fraud monitoring systems
• Restricted internal access on a need-to-know basis
• Independent security audits conducted annually

If you notice any unusual account activity, please contact us at support@lukkly.com  immediately.

9. DATA RETENTION

We retain your data only for as long as legally necessary, typically:

• 5 years after account closure, as per the Curaçao  Gaming Authority requirement, AML and financial recordkeeping;
• shorter if not required by law or regulator.

All deletion or retention actions are documented in our internal audit log in line with CGA record-keeping requirements.

10. COOKIES AND ANALYTICS

We use cookies to ensure our website functions properly and to enhance your experience.

Types of cookies:

• Essential: enable login and site security
• Functional: store your preferences
• Analytics: collect anonymous usage statistics
• Marketing: personalize offers (only subject to your consent)

You can manage or disable cookies in your browser settings. Please advise our Cookie Policy for more details.

11. YOUR RIGHTS

You have full control over your data under GDPR, including exercising of the following rights:

• Access – request a copy of your data;
• Rectification – correct inaccurate or outdated information;
• Erasure – request deletion (subject to legal retention limits);
• Restriction – limit how we use your data;
• Portability – receive your data in a structured format;
• Objection – oppose certain types of processing;
• Withdraw consent – opt out of marketing or cookies at any time; 

To exercise your rights, please contact us at: support@lukkly.com. We will respond to your inquiry within 30 days, as required by law.

12. DISPUTES AND COMPLAINTS

If you have a privacy concern or dispute, please contact us at: support@lukkly.com. 

If you are not satisfied with our response, you may escalate the matter to:

• Your local Data Protection Authority, or
• The Curaçao Gaming Authority for regulatory oversight.

We fully cooperate with regulators in resolving data-related complaints and Responsible Gaming investigations. 

13. POLICY UPDATES

The present Privacy Policy may be updated periodically to reflect legal, regulatory, or operational changes. If significant updates are made, we will notify you by email or site notice.

Continued use of our services after such notice means your acceptance of the present Privacy Policy latest version.

14. FINAL NOTE

Lukkly Casino operated by Island Lukkly B.V. is committed to transparency and responsible data use.

We process personal data solely to ensure fair, compliant, and secure gaming in line with Curaçao law and international privacy standards.

If you disagree with how your data is handled, please do not register or use our services.

Your continued use of the website confirms that you understand and agree with the present Privacy Policy.