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At Lucky Play, transparency is very important to us, and we take your privacy extremely seriously. We appreciate that you are trusting us with your personal information (“PI”) and we want to be transparent about how we use it, in accordance with the laws of Ontario and Canada.
Rootz LTD is committed to protecting your PI and processing it in compliance with applicable laws – notably: the Freedom of Information and Protection of Privacy Act (‘FIPPA’), the Personal Information Protection and Electronic Documents Act (‘PIPEDA’), Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act, the Operating Agreement (may also be mentioned as ‘OA’) signed with iGaming Ontario (‘iGO’) and the iGO Privacy Directive, the Maltese Data Protection Act (Chapter 586 of the Laws of Malta) as well as the various subsidiary legislation issued under the same – the ‘DPA’; The 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 on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – the ‘GDPR’, as well as any other applicable laws.
In this Privacy Policy we describe the privacy practices for our applications, software, websites, APIs, products, and services (the “Services”). You will learn about the PI we collect, how we use it, the controls we give you over your PI and the measures we take to keep it safe.
If you have any questions, please contact us at dpo@luckyyplay.com .
Specifically, in this Privacy Policy we will cover:
Rootz Ltd, a Maltese company, is committed to protecting your PI and processing it in compliance with applicable laws. These applicable laws include the Freedom of Information and Protection of Privacy Act (‘FIPPA’), the Personal Information Protection and Electronic Documents Act (‘PIPEDA’), Ontario Regulation 722/21 made under the Alcohol and Gaming Commission of Ontario Act, the Operating Agreement (may also be mentioned as ‘OA’) signed with iGaming Ontario (‘iGO’) and the iGO Privacy Directive and any other applicable laws (collectively referred to hereinafter as the “Applicable Laws”).
Rootz Ltd has custody of your PI and provides you with the Services. Under the Applicable Laws, Rootz Ltd is operating on behalf of, and as an agent to iGO, and all such PI remains under the control of iGO, and Rootz Ltd collects, uses and discloses all such PI accordingly and in compliance with all Applicable Laws. Your PI will at all times be the property of Rootz Ltd, however the use and processing of your PI by Rootz Ltd will be subject to iGO’s control and the terms of the OA, which requires that Rootz Ltd’s collection, use, disclosure, retention and/or disposal of such PI must be in accordance with Part III of FIPPA.
We have an employee who is in charge of all data protection matters within the company, our data protection officer. If you are seeking to exercise any of your statutory rights or have any questions in relation to our policies and procedures, please contact our data protection officer at dpo@luckyyplay.com . You may also contact us at:
Rootz LTD
Ewropa Business Centre
Level 3 - 701, Dun Karm Street
Birkirkara BKR
9034
Malta
We need to process your PI in order to provide you with our Services. We will only ever ask you for the minimum amount of information that we need, and we only ever use it for lawful purposes.
When you register for an account with the Website, you enter into a contract with us, as set out in our Terms and Conditions. For us to be able to keep up our end of the contract and provide you with access to our Services, we need to process some PI about you. We will always make it clear which PI is mandatory, and which PI you can decide not to give us if you don’t want to. If there are pieces of PI that are mandatory, and you don’t want to provide to us, then you will not be able to hold an account on the Website and use our Services. We use your information to:
Some of the PI we process about you is also necessary for us to comply with the legal and regulatory obligations that we have as a gaming company, such as licensing requirements, responsible gaming and Anti Money Laundering (AML) Regulations. This information is processed in order to:
We will not knowingly solicit from, and our Website and Services are not intended for, persons under 19 years of age (‘Minors’). We will not collect PI from Minors, and if a parent or guardian becomes aware that his or her Minor child has provided us with PI, the parent or guardian may contact us to have such Minor’s PI deleted by sending an email to our Data Protection Officer (“DPO”) at dpo@luckyyplay.com requesting the deletion of the Minor child’s PI, including any documents provided by the Minor child. In case we cannot verify the relationship between the person making the request and the alleged Minor child from these documents, we have the discretion to request additional information and documentation verifying this information on a case-by-case basis.
We process a small amount of information about anyone who visits the Website. We do this so that we can better understand the individuals who visit the Website and to help us identify where there are problems, security issues or things going wrong for visitors to the site. We do this by using technical programs and functionality cookies. When we process information in this way, it is necessary for our legitimate interests to ensure that we provide an enjoyable, secure and smooth customer journey and that we protect the product from abuse that could compromise other users’ ability to use the service. Read more about our Cookie Policy.
Where we have your consent, we will contact you about news, promotions and bonuses. We will only ever contact you for these reasons if we have your prior consent to do so. You have full control over whether and how we get in touch through the settings in your account. You can access and change these settings at any time.
Where you voluntarily disclose sensitive information to us which we feel may impact your rational decisions, such as when you are speaking with us in chats or emails, we may take the decision to block you from our Services for your own safety.
The majority of the PI that we collect about you is the PI you provide to us yourselves. However, sometimes we also get PI about you from other sources.
Under our AML obligations, we are required to carry out due diligence checks that confirm information about you. In some circumstances, we may also need to verify your source of income and/or source of wealth. We work with reputable external companies who work with the gaming industry to carry out these checks, and they provide a report which contains PI about you and your background.
In some circumstances, payment service providers may supply us with a small amount of PI when they carry out a transaction for you so that we can connect transactions to you as a player.
When you use our Services, we collect the following types of PI:
Some PI is required to create an account to allow you to use our Services, such as your name, physical address, physical location, personal numeric code (e.g. Social Insurance Number), email address, password, date of birth, age, gender, telephone number, ID number fiscal code (e.g. tax filing number) and documentary evidence confirming all such PI. This is important data for our compliance with applicable gambling and PI protection laws, regulations and guidelines, including Know Your Client (“KYC”) and Anti-Money Laundering (“AML”) regulatory requirements. This is the only PI you have to provide to create an account with us.
In view of the strict legal obligations imposed upon us, we also ask for occupation, source of wealth and source of income. There might be situations in which you are also asked to provide documentary evidence to prove that you are only using legitimate funds.
Copies of identification documents, usually photo ID, issued by a federal, provincial or territorial government or by a foreign government that is equivalent to a Canadian document.
To help improve your experience or enable certain features of the Services, you may choose to provide us with additional PI, such as your game play preferences and payment transaction history.
If you contact us or participate in a survey, contest, or promotion, we collect the PI you submit such as your name, contact information, and message.
If you choose to connect your account on our Services to your account on another service, we may receive PI from the other service.
In order to receive payments, you must provide certain PI for identification and verification, such as your name, credit, debit or other card number, card expiration date, and CVV code. This information is encrypted and sent to your card network, which upon approval sends back a token, which is a set of random digits for engaging in transactions without exposing your card number. For your convenience, we store the last four digits of your card number and your card issuer’s name and contact information.
We will derive your approximate location from your IP address, collecting connection details and information with regard to your device, software or hardware that may identify you, such as your device’s unique identifiers (e.g. UDID, IMEI and MAC address), browser fingerprinting, IP address and geolocation data.
When you access or use our Services, we receive usage data. This includes information about your interaction with the Services, for example, when you view or search content, create or log into your account, play a game, collect or use bonuses or loyalty points, as well as information with respect to your transactions, deposits, balances, bets, withdrawals and winnings.
We also collect data about the devices and computers you use to access the Services, including IP addresses, browser type, language, operating system, the referring web page, pages visited, location, and cookie information.
Our Websites use “cookies”. A “cookie” is a piece of software, which may be sent to your computer. Cookies enable us to collect information about how our Websites and services are being used and to manage them more efficiently.
Our up to date Cookie Policy.
We use the PI we collect for the following purposes:
Using the PI we collect, we are able to deliver the Services to you and honour our Terms of Service contract with you. For example, we need to use your PI to provide you with your player dashboard, provide you with game suggestions and (with your consent) any other relevant marketing promotions.
We use the PI we collect to improve and personalize the Services and to develop new ones. For example, we use the PI to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features. We also use segmentation to split our players into groups based on their gaming behaviour. We do this to help us understand how people use the Services and to help us develop our marketing approach, including bonuses and promotions.
When you allow us to collect location PI, we use that information to provide and improve features of the Services. For example, we may present to you your favourite games or games that you might be interested in at the top of our games content, based on the preferences you set, your place of residence and your game play data. We also use location information to determine your eligibility to use the Services.
We are required to take a number of steps to meet the rules around Anti-Money Laundering (AML) Counter-Terrorist Financing and fraud and other unlawful activities. In order to do this, we employ programs that monitor player behaviour and alert us to suspicious or fraudulent transactions. Where suspicious transactions are flagged, we escalate these to the responsible entities, including the iGO, which passes the information to the necessary regulators and enforcement bodies. As part of our licence, we also have obligations around responsible gaming. In order to do this, we employ a system which flags any gambling patterns or behaviours exhibited by a player that could indicate problem gambling. When the system flags a player, one of our responsible gaming team members reviews the account and where necessary will reach out to the player for a discussion on their game play and provide information and advice.
Our Website may from time to time contain links to both local and/or international third-party Websites after obtaining permission from them. Any such links are not an endorsement by us of any information in such websites or products and/or services offered through the same. We shall not accept any responsibility whatsoever for the content, use, availability, privacy practices or the content of any such websites. Please note that upon entering such other websites, you become subject to the Privacy Policy of these other sites.
No third party is permitted to link any other website to our Website without obtaining our prior written consent.
We use your information when needed, to send you notifications regarding the Services subject to having obtained your consent to send same, and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in. You can control marketing communications and most notifications regarding the Services by using your notification preferences in your account settings or via the “Unsubscribe” link in an email.
All e-mail messages are routinely scanned for viruses. In the case of e-mails, we may reject, delay or remove content from e-mails due to their nature, content or attachments, which may disrupt our systems or because they may pose security issues such as viruses. We may also filter out e-mails which contain certain content on the basis that the content is offensive, or the e-mail is unwanted or spam. In certain circumstances this may unfortunately result in “innocent” e-mails being affected, but we do try and reduce such occurrences.
Please be aware, however, that information sent through the Internet may technically be transmitted across international borders even where sender and receiver of information are located in the same country. Consequently, PI relating to you may be transmitted via a country having a lower level of data protection than that existing in your place of residence.
There are some circumstances where we need to share your PI with third party recipients in order to provide our Services. When we carry out any sharing with third parties, we always ensure that there is an appropriate contract in place, that the information being shared is transferred securely and that we only share the minimal amount of your information that we need to. We will never sell your information to any other third parties.
Third parties we work with include payment service and game providers, analytics services, identity verification, KYC and AML related services, social media platforms, website performance and security systems affiliates and other partners who process data for us, based on our instructions, and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, marketing, data analysis, research, and surveys.
You may direct us to disclose your PI to others, such as when you use our community features like the “Races”. For certain information, we provide you with privacy preferences in account settings and other tools to control how your information is visible to other users of the Services. Just remember that if you choose to participate in a “Race”, information like your first name will be visible to all other participants.
We work with partners who provide us with analytics and advertising services. This includes helping us understand how users interact with the Services, serving advertisements on our behalf across the internet, and measuring the performance of those advertisements. These companies may use cookies, pixels and similar technologies to collect PI about your interactions with the Services and other websites and applications.
We may share non-personal information that is aggregated or disidentified so that it cannot reasonably be used to identify an individual. We may prepare such information for research or statistical purposes.
We do not transfer your PI to any third parties for marketing purposes or for any other purposes other than listed above.
Without prejudice to anything contained in this Privacy Policy, we are obliged to disclose PI relating to you to any third party if such disclosures are necessary for the following purposes, among others:
Our policy is to notify you of a legal process seeking access to your PI, such as search warrants, court orders, or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period.
We may disclose your PI to potential purchasers, successors or investors in LuckyPlay or any entity or entities affiliated with LuckyPlay, or in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, reorganization, bankruptcy, consolidation or asset sale of an asset or transfer in the operation thereof) in relation to LuckyPlay or any entity or entities affiliated with LuckyPlay. In the event of an acquisition of LuckyPlay, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.
We provide you with account settings and tools to access and control your PI, as described below, regardless of where you live.
You have a number of rights that you can exercise when it comes to your PI. These rights include:
By logging into your account, you can access much of your PI, including your dashboard.
If you would like to exercise any of these rights, you should email us at dpo@luckyyplay.com from your registered email address and provide:
In some circumstances, we may request that you provide us with identity documents so that we can verify your identity. We will carry out your request, to the extent that it is possible to do so and in compliance with our legal obligations.
Your account settings let you change your PI. For instance, you can edit the profile data you provide or delete your account if you wish by contacting us at support@luckyyplay.com . However, certain PI that is necessary to check eligibility to access the Website and use the Services, such as date of birth or age, cannot be deleted.
You can obtain a copy of your PI through your account on the Website. For your protection, you will be required to provide proof of your identity to obtain such copies. You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. If you would like to close your account, you can also contact Customer Services. If you would like to close your account, this could be done through your personal account. We will comply with such requests unless we have a legitimate ground not to delete the data.
If you choose to terminate your account, we will retain your PI only for as long as necessary for the purposes set out in this policy and in compliance with the PI Retention section below.
We have a legal obligation due to AML and KYC regulations to retain all personal account data, obtained for customer due diligence purposes, such as your name and address and all documentation gathered during registration and payment processes for a period of 5 years after you close your account. You may also wish to note that this period may be extended by a further 5 years when such extension would be considered necessary for the purposes of the prevention, detection, analysis and investigation of money laundering or funding of terrorism activities by the Financial Intelligence Analysis Unit and/or the Financial Transactions and Reports Analysis Centre of Canada (“FINTRAC”), relevant supervisory authorities or law enforcement agencies.
We provide you with account settings and tools to control your data use. For example, through your privacy settings, you can limit how your information is visible to other users of the Services; using your notification settings, you can limit the notifications you receive from us.
You have a right to object to the use of your PI for direct marketing purposes. Please see your notification settings to control our marketing communications to you about new games and products. Please also review our Cookie Policy for your options to control how we and our partners use cookies and similar technologies for advertising.
If you need further assistance regarding your rights, please contact us at dpo@luckyyplay.com , and we will consider your request in accordance with applicable laws. You also have a right to lodge a complaint with IGO.
We keep your account information, like your name, email address and password, for as long as your account is in existence because we need it to operate your account.
If you require more information about our Data Retention Policy, please email us at dpo@luckyyplay.com .
We use the PI we collect to promote the safety and security of the Services, our users, and other parties. For example, we may use the PI to authenticate users, facilitate secure payments, protect against fraud and abuse, respond to a legal request or claim, conduct audits, and enforce our terms and policies.
For PI, we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time using your account settings and other tools; when the processing is necessary to perform a contract with you, like the Terms & Conditions; and our legitimate business interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described above.
We work hard to keep your PI safe and make all reasonable efforts to safeguard the confidentiality of PI that we process. We regularly review and enhance our technical, physical and managerial procedures to ensure that your PI is protected. These cover areas such as access control, authentication, audit, monitoring, alarms, data storage and backup and transmission standards. This is to ensure there is no unauthorized access or modifications to PI, no improper use or disclosure, or unlawful destruction or accidental loss.
Our security policies, rules and technical measures are dedicated to the protection of the PI that we have under our control. All our employees and third-party data processors, who have access to and are associated with the processing of PI, are further obliged to respect the confidentiality of this PI and are subject to a code of conduct which requires them to adhere to privacy principles.
By its very nature, however, the Internet is not a secure medium and data sent via this medium can potentially be subject to unauthorized acts by third parties. By playing on our site and agreeing to this Privacy Policy, you acknowledge that you understand and agree that although we will take reasonable steps and employ appropriate security measures to safeguard your PI, no method of transmitting or storing data is completely secure. We will promptly notify you if your PI is impacted by a privacy breach that could reasonably result in a real risk of significant harm to you. We will also report any such privacy breach to the authorities as required by Applicable Laws (including, without limitation, the Information and Privacy Commissioner of Ontario and the Office of the Privacy Commissioner of Canada), and keep a record of any such privacy breach to the extent required by Applicable Laws. If you have a security-related concern, please contact Customer Support.
Your PI will be processed outside of Ontario and, wherever possible, we keep your PI within the European Economic Area (EEA). However, in some circumstances your information may have to leave the EEA, such as when we work with third parties. We are obliged to ensure that our subcontractors that hold and process PI outside of Ontario are held to the equivalent privacy and security standards as those applicable in Ontario. In the event that such transfers occur, we will take all reasonable steps to ensure your PI is treated as securely as it would be within Ontario and the EEA and in accordance with this Privacy Policy and the applicable legislation and that such transfers are made securely.
Our Privacy Policy is compliant with the Applicable Laws, as well as any future data protection legislation as may be enacted from time to time.
If you are unhappy with how your PI has been handled, please email dpo@luckyyplay.com , detailing:
We will then look into your complaint and investigate whether your PI has been handled appropriately and in line with this privacy notice, our legal obligations and our internal policies and procedures. We will then contact you regarding the outcome of the investigation and any steps that have been taken as a result.
If you are unhappy with our resolution of your complaint, you may request a copy of your case file, which we shall provide, in order to escalate the complaint to iGO. We will aid iGO in the investigation and handling of your complaint, all in accordance with the iGO’s Customer Care and Dispute Resolution Policy pursuant to section 24.02 of the OA.
We have translated our privacy notice from English into the official languages of the countries that we provide our services to. We have done this to ensure that all of our customers are clear about how we use PI.
If there are any conflicts or inconsistencies between the translated versions of this Privacy Policy, the English version will prevail.
This Privacy Policy may be modified at any given time, particularly where statutory obligations so require, or the interest of our users’ security so requires. Any such changes will be posted here so that you are always kept informed of how and why we process your PI.
We will notify you before we make material changes to this policy and give you an opportunity to review the revised policy before deciding if you would like to continue to use the Services.