Privacy Policy

This Privacy Policy explains how lukki-casino, operating exclusively via lukki-ca.com, collects, uses, discloses, and protects your personal data. It applies to all players and visitors of our website and platform. The policy is effective as of November 6, 2025, and reflects our commitment to your privacy and compliance with Canadian (CA) laws, applicable international standards, and industry best practices.

Who We Are

OBSERVE: lukki-casino is operated by Just Entertainment B.V. (Registration No. 160603), with its registered address at Scharlooweg 39, Willemstad, Curaçao. Payment processing is facilitated by Friolion Ltd. (Reg No. 419102) and Strukin Ltd. (Reg No. HE 407624), both based in Cyprus. Dama N.V. (Reg No. 152125) is identified as the ultimate beneficial owner. The casino holds Curaçao GCB license OGL/2025/164/0246, valid until December 31, 2025.
EXPAND: For privacy concerns, the Data Protection Officer (DPO) or designated data protection contact can be reached as follows:
REFLECT: All privacy-related inquiries are handled professionally and in accordance with CA and industry standards.

• Legal Operator: Just Entertainment B.V., Scharlooweg 39, Willemstad, Curaçao. Registration Number: 160603.
• Payment Processing: Friolion Ltd. (Reg No. 419102) and Strukin Ltd. (Reg No. HE 407624), Cyprus.
• Data Protection Contact: Email: [email protected]
• Additional Contacts: General inquiries: [email protected]
• Websites: lukki-ca.com, lukki.com

What Personal Data We Collect

OBSERVE: lukki-casino collects a range of data to ensure regulatory compliance and service provision.
EXPAND: Data categories include personal, technical, payment, behavioral, and cookies.
REFLECT: Collection is limited to what is necessary for lawful and operational purposes.

• Personal Data: Full name, date of birth, email address, phone number, postal address, identification documents (for KYC/AML).
• Technical Data: IP address, device identifiers, browser type, access logs, geolocation data, activity timestamps.
• Payment Data: Credit/debit card details, bank account information, cryptocurrency wallet data, transaction records.
• Behavioral Data: Betting and gaming history, transaction and win/loss records, account preferences, clickstream data.
• Cookies & Tracking: Session cookies, persistent cookies, third-party analytics and advertising cookies, device fingerprinting technologies.

Legal Basis for Processing

OBSERVE: Processing of personal data is grounded in legal and regulatory obligations, user consent, and legitimate business interests.
EXPAND: We ensure all data processing aligns with CA law and relevant international standards.
REFLECT: Each processing activity is justified by one or more lawful bases as detailed below.

• User Consent: Explicit consent obtained for account registration, marketing communications, and cookies where required.
• Contract Performance: Processing necessary for fulfilling user agreements, providing casino services, verifying identity, processing payments, and delivering support.
• Legal Obligations: Compliance with anti-money laundering (AML), know-your-customer (KYC), tax reporting, and responsible gambling regulations.
• Legitimate Interests: Prevention of fraud and abuse, system security, service improvement, analytics, and internal reporting (provided such interests do not override user rights).

Purpose of Processing

OBSERVE: Data is processed only for clearly defined and lawful purposes.
EXPAND: This ensures user rights are respected and regulatory requirements are met.
REFLECT: Each processing activity supports our service, compliance, and user experience goals.

• Service Provision: Creating and managing accounts, enabling gameplay, processing payments and withdrawals, providing customer support.
• System Improvement: Monitoring performance, troubleshooting, and developing new features.
• Marketing & Communication: Sending newsletters, promotional offers, and updates (where consented).
• Analytics & Research: Analyzing user behavior, game performance, and business trends to optimize services.
• Fraud Prevention & Security: Detecting and mitigating fraudulent or unauthorized activity, ensuring platform integrity.
• Regulatory Compliance: Meeting legal obligations under CA law and international gambling regulations.

Disclosure & Sharing

OBSERVE: User data may be disclosed to third parties only when necessary and lawful.
EXPAND: Disclosures are limited to entities involved in service delivery and regulatory oversight.
REFLECT: All sharing is governed by strict confidentiality, data processing agreements, and regulatory requirements.

• Payment Partners: Banks, payment processors, and financial institutions for transaction processing.
• Service Providers: IT support, cloud hosting, analytics, and marketing service vendors bound by confidentiality and data protection agreements.
• Regulators & Law Enforcement: Disclosure is made to regulatory authorities, including the Curaçao Gaming Control Board and CA authorities, when legally required.
• Affiliates: Marketing affiliates and business partners, only with explicit user consent and subject to data protection controls.
• Advertising Networks: Third-party advertising partners, solely with user consent and in compliance with applicable laws.

Legal Obligation: lukki-casino will never sell, lease, or trade your personal information for unrelated commercial purposes.

International Transfers

OBSERVE: Some data processing occurs outside of Canada, notably in Curaçao (operator headquarters) and Cyprus (payment processing).
EXPAND: Cross-border transfers are governed by recognized data protection safeguards.
REFLECT: lukki-casino applies international best practices to protect your data regardless of processing location.

• Transfer Destinations: Curaçao (operations), Cyprus (payment processors), and other jurisdictions where service providers are located.
• Protection Measures: Standard contractual clauses (SCCs), data processing agreements, and technical safeguards are implemented to ensure adequate protection.
• Compliance Statement: All transfers comply with CA privacy laws and, where applicable, international frameworks such as GDPR adequacy decisions and recognized cross-border transfer mechanisms.

Data Retention

OBSERVE: Data is retained only as long as necessary for the specified purposes.
EXPAND: Retention aligns with legal, regulatory, and operational requirements.
REFLECT: Upon expiration of retention periods or upon user request (unless prohibited by law), data is securely deleted or anonymized.

• Personal Data: Retained for up to 5 years after account closure, or as required for regulatory compliance (e.g., AML/KYC).
• Technical & Behavioral Data: Typically retained for 2 years for analytics and security purposes, unless a longer period is mandated by law.
• Payment Data: Retained for 5 years to comply with financial regulations and audit requirements.
• Cookies & Tracking Data: Retention varies by type (see Cookies section), generally from session duration up to 2 years.
• Deletion Criteria: Data is deleted upon user request (subject to legal exceptions), expiration of retention period, or when processing is no longer necessary.

Legal Clause: Data may be retained for longer periods if required for legal proceedings, dispute resolution, or regulatory investigations.

Your Rights

OBSERVE: lukki-casino upholds all user rights in accordance with GDPR-equivalent standards and CA privacy laws.
EXPAND: These rights include access, correction, deletion, restriction, objection, portability, and withdrawal of consent.
REFLECT: Practical procedures are in place to facilitate the exercise of these rights, free of charge, within 30 days of verified request.

1. Access: Request a copy of personal data we hold about you.
2. Rectification: Correct inaccurate or incomplete personal information.
3. Erasure ("Right to be Forgotten"): Request deletion of your data unless processing is necessary for legal compliance.
4. Restriction: Request limitation of processing in certain circumstances (e.g., contesting accuracy).
5. Objection: Object to processing based on legitimate interests or direct marketing.
6. Portability: Obtain your data in a structured, machine-readable format and transmit it to another provider if technically feasible.
7. Withdraw Consent: Revoke consent for marketing communications or non-essential processing at any time.

• How to Exercise: Email [email protected] with your request. We may require identity verification to protect your privacy.
• Response Time: We will respond within 30 days of receipt of a valid request.
• Fees: All requests are processed free of charge unless manifestly unfounded or excessive, in which case a reasonable fee may be charged.
• Complaint: If you believe your rights are not respected, you may contact the Canadian privacy authority or relevant supervisory body (see Complaints section).

Regional Compliance Note: While this policy is designed for CA users, lukki-casino voluntarily aligns with international standards such as the GDPR and, where applicable, references best practices from Mexican data protection law for multi-jurisdictional consistency.

Cookies & Tracking Technologies

OBSERVE: lukki-casino uses cookies and similar technologies for core functionality, analytics, and advertising.
EXPAND: Users are informed of types, purposes, and control options.
REFLECT: Consent mechanisms and management tools are provided in accordance with CA and international standards.

• Session Cookies: Essential for login, navigation, and secure transactions; deleted when you close your browser.
• Persistent Cookies: Store preferences and enhance user experience; remain on your device up to 2 years unless deleted.
• Third-Party Cookies: Used by analytics providers (e.g., Google Analytics) and advertising networks with your consent.
• Device Fingerprinting & Tracking: Technologies may be used for fraud prevention and regulatory compliance.
• Cookie Management: You can manage or disable cookies via your browser settings or, where available, through our internal privacy dashboard.

Legal Clause: Essential cookies are required for site operation. Non-essential cookies are subject to user consent and can be withdrawn at any time.

Data Security

OBSERVE: lukki-casino employs advanced technical and organizational measures to protect your data.
EXPAND: Security covers data in transit, at rest, and during processing.
REFLECT: All measures are regularly reviewed and updated to meet or exceed international security standards.

• Encryption: All data transmitted via lukki-ca.com is protected by TLS 1.2+ protocols; sensitive data is encrypted at rest.
• Access Controls: Strict role-based access, multi-factor authentication, and monitoring of privileged access.
• Security Audits: Regular internal and external audits, vulnerability assessments, and penetration testing.
• Staff Training: Ongoing security awareness and data protection training for all employees and contractors.
• Incident Response: Formal procedures for prompt detection, reporting, and mitigation of data breaches, including user notification where required by law.
• Compliance: Alignment with ISO 27001 and SOC 2 standards where applicable, with continuous review of controls and certifications.

Legal Commitment: While we implement robust security, no system is impenetrable; users are encouraged to follow safe practices and report any suspected incidents immediately.

Complaints & Contacts

OBSERVE: lukki-casino provides clear channels for privacy-related complaints and inquiries.
EXPAND: Step-by-step complaint procedures and escalation paths are outlined for user protection.
REFLECT: lukki-casino is committed to fair, timely, and transparent resolution of all concerns.

1. Primary Contact: Send complaints or requests regarding personal data to our DPO via [email protected].
2. Procedure:
   • Submit your complaint with relevant details and supporting documents.
   • lukki-casino will acknowledge receipt within 5 business days.
   • We will investigate and provide a substantive response within 30 days.
   • If additional time is required, you will be notified of the delay and reason.
3. Escalation: If dissatisfied, you may escalate your complaint to the relevant supervisory authority in Canada:
   • Office of the Privacy Commissioner of Canada (OPC): Website: www.priv.gc.ca, Tel: +1 800-282-1376
4. International Users: Users in other jurisdictions may contact their respective data protection authorities as appropriate.

Commitment: lukki-casino will cooperate fully with all supervisory authorities and regulatory bodies in investigating and resolving privacy complaints.

Updates

OBSERVE: This policy is reviewed and updated regularly to reflect changes in law, business practices, or technology.
EXPAND: Users are promptly notified of material changes and provided options.
REFLECT: Version control and advance notice ensure transparency and user rights.

• Notification Methods: Significant updates are communicated via email, website banners, and account dashboard alerts.
• Advance Notice: For material changes, a minimum 30-day notice is provided before changes take effect.
• User Options: Users may object to changes or close their accounts before new terms become effective.
• Version Control: Last updated: November 6, 2025
• Changelog: Material changes, such as updates to data sharing practices or user rights, will be summarized at the top of the policy and archived for reference.

Legal Clause: Continued use of lukki-ca.com after updates constitutes acceptance of the revised policy. Users are encouraged to review this page periodically for the latest information.