Privacy Notice

LobbyPromo

Version 2.0

22-02-2024

1.    INTRODUCTION

 

LCKY Entertainment Limited, is a company incorporated in Ontario, Canada. This privacy notice describes the information collection, use, sharing, and related practices applicable to the Luckycasino.ca provided by LCKY, located at 100 Kings Street West, 1 First Canadian Place, Suite 6200, Toronto, Ontario, Canada, M5X1B8.  

At LCKY we highly value and respect the privacy of our customers and we are committed to maintain the confidence and security of our customers’ personal information.  

We endeavour to maintain strict security measures on the Website and its associated sites, so that no unauthorized use, loss and/or alteration of data can be made to you and your account.

This Policy governs the personal information collection, use, sharing, and related practices applicable to LCKY in Ontario only. “Personal information” means information about an identifiable individual and includes any information that constitutes personal information within the meaning of the Freedom of Information and Protection of Privacy Act (“FIPPA”) The Personal Information Protection and Electronic Documents Act (‘’PIPEDA’’) and other applicable privacy laws. This Policy is separate and distinct from the privacy policies that govern the online gaming services offered LCKY in other jurisdictions. This website and the Services operate under and pursuant to the Operating Agreement and are being offered by LCKY as part of the open and regulated iGaming market conducted and managed by iGaming Ontario (http://www.igamingontario.ca/en). In the course of providing the services (i) LCKY collects, uses and discloses personal information on behalf of and as agent to iGaming Ontario; (ii) LCKY collects personal information in accordance with FIPPA, PIPEDA and other applicable privacy laws, and under the authority of Ontario Regulation 722/21 made under the Alcohol and Gaming Commission, and the operating agreement entered into between LCKY and iGaming Ontario.

This Notice is governed the laws of Ontario and applicable federal laws of Canada. All collection and processing as part of your relationship with LCKY is governed by The Personal Information Protection and Electronic Documents Act S.C. 2000, c. 5 (PIPEDA) where applicable, and The Freedom of Information and Protection of Privacy Act, R.S.O. 1990, c. F.31 (FIPPA), and Ontario Regulation 722/21 under the Alcohol and Gaming Commission of Ontario Act where applicable.

 

2.    THE PURPOSE OF THE PRIVACY NOTICE

The purpose of this Privacy Notice is to inform you about the methods and purposes for which your personal information is processed whilst using Luckycasino.ca (the ‘’website’’) and to inform you the rights you have regarding the processing.

By accepting this Privacy Notice, you agree that you understand and consent to the processing of personal information as set out in this notice.

3.    GENERAL TERMS

If you do not agree with the terms of this Privacy Notice, please do not use the Website or otherwise provide us with your personal information. This Privacy Notice should be read in conjunction with our Terms and Conditions.

LCKY may periodically make changes to this Privacy Notice which will be posted on this website, and we may also inform you personally of any significant changes to this Privacy Notice. You are encouraged to regularly check this page and examine this Privacy Notice for up-to-date information on the processing of personal information.

4.    WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?

4.1 The information you provide us. We collect your personal information primarily from the registration form when you register as a customer on LuckyCasino.

The personal information we collect via the registration form includes:

a)    First name

b)    Middle name (optional)

c)    Surname

d)    Date of Birth

e)    Email address

f)     Telephone or mobile number

g)    Occupation

h)    Industry

i)      Job title

j)      Photographic identification and proof of address for due diligence checks

k)    If you attest that you are a Politically Exposed Person (“PEP”) the Head of an International Organization (“HIO”), or a family member or a close associate of a PEP or HIO, as those terms are defined in the Terms and Conditions, you will be required to provide additional information such as your source of funds, your source of wealth, the nature of your connection to the PEP or HIO if you are a family member or close associate of a PEP or HIO, the office or position of the PEP/HIO, the PEP or HIO organization/institution name and, if you are a family member or close associate of a PEP or HIO, the nature of the relationship between the family member and close associate of the PEP or HIO. Such information is collected on behalf of iGaming Ontario and may be shared with other Operators as part of enterprise level player monitoring.

l)      Banking and Financial details and any supplementary documents required by law to establish the source of funds. Your financial information is collected through a secure server (SSL) for your registration as a real money player and then it will also be verified via third party service providers.

m)   Residential address

4.2 Through the use of our services, we may collect the following personal information:

a)    Records of correspondence (this can be via email, telephone, mobile or other means of communication).

b)    Documents you provide.

c)    Any information you provide via the Website or email.

d)    Information about the transactions you carry out on the Website.

e)    Information about your visits to the Website traffic data, location data.

f)     Information about any devices you may have used to access our Services (define this)

g)    Information about how you, interact with our website.

h)    To prevent fraudulent or criminal activity, we may also collect the player’s financial information from other online gaming sites, banks, credit card companies and other fraud prevention agencies.

i)      From which location you are accessing the service.

 

LCKY uses electronic location and identity verification software provided by third party suppliers. 

 4.3 The Information we receive from third parties.

a)    The information that is collected from you may be combined with other information we receive from third party sources such as public data bases.

b)    We may use third party data about you, from

Facebook feeds to provide more effective personalization.

Google used by Google Analytics to collect data on the number of times you have visited the website as well as the date of the first and last visit. It is used to understand how you, the visitor navigates around the website.

Microsoft is used for internal analysis. It collects behavioral data from multiple websites, in order to present more relevant advertising. This allows the website to limit the number of times the same advertisement is shown, it collects track FTDs and registrations for campaigns, ads and keywords in Microsoft Ads interface.

c)    Data received from our business partners.

 

5.0  HOW WE USE THE INFORMATION WE COLLECT AND OPT-OUT OPTIONS

 

A.  Use by LCKY

 Verification Purposes

 During this process you will be verified at registration through a third party. For you to be verified through electronic verification you will need to  have valid and current information from a Canadian credit file that has been existence for at least three years.  In circumstances  where you cannot be verified through the Canadian credit file, your personal information will be checked against the Dual-Process Method and verified against two reliable and independent sources. 

 

When using the credit file process to verify the identity of a player, we will maintain a record of the following information for seven years and make information available to iGO upon request: 

  1.  Player’s full name 
  2.  Source of the credit file (i.e., name of the Canadian Credit Bureau)  
  3.  Player’s credit file number  
  4. Date of verification. 

 

Dual Process 

 When using the dual process to verify your identity, we will maintain a record of the following information for seven years and make information available to iGO upon request: 

  1. Player’s full name  
  2. Date of identity verification  
  3. The name of the two different sources used to verify identity.  
  4. Type of information referred to (e.g., financial (bank) account, marriage certificate, utility statement)  

 

 

Marketing Purposes

When you register for an account with us, you will have the option to sign-up to receive marketing information, including notifying you of special promotions, offers, and events via push notifications, e-mail, and other means. We may also link personal information (including your name, mobile phone number, and e-mail address) with non-personal information (including information collected through Tracking Technologies and Wi-Fi services) and use such information for our own marketing purposes. If you no longer wish to receive these types of marketing communications, you may opt-out in accordance with the “How to Opt-Out” section below.

 

Non-Marketing Purposes. 

We may use the information we collect for non-marketing purposes including:

(1)  validating your identity.

(2)  sending you push notifications or e-mails to provide you with alerts and updates about your Account and the Services.

(3)  monitoring, accessing, and recording gaming-related activity, such as using automated software to report on any processes or programs running on your computer that have been identified as prohibited software to prevent the abuses caused by BOTS.

(4)  conducting statistical or demographic analysis.

(5)  processing and tracking gaming and non-gaming transactions.

(6)  complying with legal and regulatory requirements.

(7)  customizing your experience with the Services.

(8)  protecting and defending our companies against legal actions or claims.

(9)  preventing fraud. debt collection.

(10)  satisfying contractual obligations; and

(11)   safety and security purposes including cooperating with law enforcement or other government agencies for purposes of national security, public safety, or matters of public importance when we believe that disclosure of information is necessary or appropriate to protect the public interest (collectively “Non-Marketing Purposes”). 

 

B. Sharing with Affiliates 

 We do not sell or disclose your personal information to third parties without your consent, except as set forth below or as required or permitted by law.

 

We may share the information we collect with Affiliates for Non-Marketing Purposes and, with your consent, for marking purposes. If you do not want us to share your personal information with Affiliates for marketing purposes, you may withdraw your consent at any time in accordance with the “How to Opt-Out” section below.   

 

 

C. Sharing with Business Partners and Other Third Parties

We may share the information we collect with our business partners and other third parties for joint marketing purposes and/or our business partners’ (or our own) marketing purposes. Even if you opt-out of permitting us to share your personal information with our business partners and other third parties for marketing purposes, we may still share the information we collect with them for non-Marketing purposes such as processing transactions, fulfilling your requests, responding to your inquiries, etc.

 

 

D. Service Providers

We may engage service providers to provide certain services to us or to perform certain services on our behalf including analytics, marketing, fulfillment, know-your-client identity verification, etc. In some cases, service providers may collect or be provided with access to your information as reasonably necessary to perform such services on the condition that they not use or disclose your personal information for other purposes.

 

Our service providers may be located at locations other than Canada including foreign jurisdictions. In the event personal information is transferred to other foreign jurisdiction, the storage and other processing maybe be subject to the laws of that jurisdiction and may be disclosed to or accessed by the courts, law enforcement and governmental authorities in accordance with those laws.

 

E. Certain Business Transactions

We may share all of the information we collect with any successor to all or part of our business in connection with a transaction involving a sale, purchase, reorganization, merger, or transfer of any our assets or the assets of Affiliates.

 

 

 

6.0  WHY DO WE PROCESS YOUR PERSONAL DATA?

a)       It allows us to identify you.

b)      It is essential for providing you with the services and products that you want.

c)       It is used to personalize and improve your experience when you are using our services.

d)      To comply with the law.

e)      To contact you with important information.

 

 

7.0  MARKETING AND MARKET RESEARCH

 

Under Canadian Anti-Spam Legislation[1] (“CASL”) it is prohibited to send or cause to permit to be sent to an electronic address a commercial electronic message unless you have consented to receiving it. When you register with us, we will ask if you would like to receive marketing communications, and you can change your marketing choices online, at any time.

 

If you have consented, we may use information which we hold about you to show you relevant advertising on third party sites.

 

If you want to revoke your consent for the marketing purposes, contact our Customer Service or our Data Protection Officer ([email protected]). We inform you that when revoking your consent, we may not be able to provide you the service or parts of the service.  Although you may opt-out of the use and sharing of personal information for marketing purposes, we may still use and share information we collect for Non-Marketing Purposes.

We are required under a legal obligation to determine:

a)    Our services are only available to you in Ontario.  Where you are accessing the services, we use the third party ‘Geolocation’ which identifies the geographic location of your device when accessing our website.  This is needed in order to ensure that you are not playing in a restricted province or country.

b)    To assess any risk associated with betting including identification of potential problem gambling.

c)    To prevent Money Laundering activities by identifying and establishing the source of wealth.

d)    Crime detection, prevention and prosecution.

e)    To carry out anti-fraud checks including the prevention of fraudulent or criminal activity.  We may also collect your financial information from other online gaming sites, banks, credit card companies and other fraud prevention agencies in order to fulfill this obligation.

f)     To make sure we are offering the services to eligible persons by determining that you are not under the age of 19.

g)    To ensure the personal information we have about you, is accurate and remains accurate and up to date.

 

8.0  COOKIES

 Cookies are small text files stored on your computer by your browser. They are used for many things, such as remembering whether you’ve visited the site before, for ease of access to your account – or to help us work out how many new website visitors we get each month. They contain information about the use of your computer, but don’t include personal information about you. Cookies cannot harm your computer and do not contain any viruses.

 

You can find more information about cookies at computer.howstuffworks.com.

 

We may use cookies as a means of collecting information from a web server for the above purposes following a customer's use of the Website. If you register with us or if you continue to use the Website, you agree to our use of cookies.

 

The use of cookies on our website can be categorized as follows:

-          Cookies used for Functionality - this enables us to remember your preferences and they improve your user experience.

-          Essential Cookies - these cookies manage the session information, and they enable you to navigate through our website. These are considered essential cookies to make use of our website.

-          Fraud Prevention Cookies – they store information which helps us stop fraudulent use of the Website.

-          Tracking Cookies – these are stored and used to help us analysis how users landed on our website. If you used an Affiliate to come to our website this is recorded and so we will be able to pay that Affiliate accordingly.

-          Analysis Cookies – these cookies help use improve the way our website works; it allows us to recognize and count the number of users and see how these users navigate on our website.

 

Cookies are used to allow users to log-in, to allow users to change their log in preferences, to monitor and collect information about transactions placed on the website, for fraud prevention purposes and to improve and enhance the user experience.

 

We may from time to time use third party tracking and/or analytical cookies to assist in improving our services and our website.

 

If you want to stop the cookies that are being used to track your browsing patterns on our website or you want to delete any cookies stored on your computer, you can do so by altering your browser’s privacy settings.

 

Here’s a link which can guide you on how to enable and disable Cookies on different Web Browsers; https://allaboutcookies.org/how-to-manage-cookies

 

9.0  WHERE DO WE STORE YOUR DATA?

Non-gaming information data collected by us through the Services is stored on secure servers located in Ontario, Canada.  

Data collected by us is stored on servers and are protected by firewalls and other industry standard security measures. These security measures are intended to protect our servers from unauthorized access. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach. We have controls in place that are designed to detect potential data breaches, contain and minimize the loss of data, and conduct forensic investigations of a breach. We will provide you notice in the event of an incident that materially impacts your personal information (a “Data Incident”). We will notify you, iGaming Ontario, and any other applicable regulatory authority about the Data Incident, and we will aid iGaming Ontario and any applicable authorities in the management and handling of the Data Incident.

 

10.0       WHEN DO WE SHARE YOUR PERSONAL INFORMATION?

When we share your personal information with third parties, we have contracts in place to ensure that the third parties only process your personal information to provide the service in line with the purposes that we have specified herein.

We share your personal information with third parties in the following circumstances:

a)    With service providers that provide services on our behalf. This includes companies the provide the following services. 

-          Process payments

-          Advertising

-          Detection of location

-          Technology

-          Data storing

-          Security

 

b)    With external auditors to carry out the required independent checks.  

c)    When we are ordered to do so by any legal provision or regulatory authority.

d)    To establish, exercise or defend our legal rights.

e)    To prevent fraudulent activity. We may share Personal Data with other online gaming sites, banks, credit card companies and other fraud prevention agencies.

f)     Whenever we have a legal obligation to do so, we may also share your personal data with authorities.

g)    To any entity we sell or transfer our business to.

We share your data with other companies within the Group.

a)    Testing new systems and general upgrades.

b)    Complying with regulatory requirements.

c)    Facilitating the secure access to online platforms.

d)    Market research.

e)    We may also share your personal data with other third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our shares and/or assets or other corporate change.

f)     Some of the companies within the group are used to provide services to other companies within the same group. In which case, your data will be shared with the other company so it can provide the required services. Whenever we share personal data within the group, we use data protection agreements and security measures to ensure that your personal data is safe and secure and in line with the relevant data protection laws.

 

11.0       DO WE TRANSFER YOUR DATA OUTSIDE OF CANADA?

Information collected by LCKY, or our affiliates may be stored and processed in any country in which we or our affiliates, suppliers, third-party electronic payment processors and/or financial institutions or agents maintain facilities. By using our site, you expressly consent to any transfer of information outside of your country (including to third countries that may not have been assessed as having adequate privacy laws). Nevertheless, we take steps to ensure that our agents, affiliates and suppliers comply with our standards of privacy regardless of their location.

12.0       HOW LONG DO WE KEEP YOUR DATA?

We retain the personal data for of the amount of time as specified under applicable legislation so that you can have reasonable opportunity to obtain access to it and for the period necessary for us to fulfil the purposes outlined in this Privacy Notice, unless a longer retention period is required or permitted by law. We may also retain necessary personal data to resolve disputes, enforce our Terms and Conditions, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Website and our service.

We will retain the information we collect about you as long as your Account is active. When your Account is terminated, we will retain your personal information for as long as necessary to comply with our legal and regulatory obligations, resolve disputes, reasonably manage our business, and enforce contractual agreements. 

 

13.0       WHAT ARE YOUR RIGHTS?

a)    You have the right to obtain information of the personal data collected for processing. You are also entitled to have any such personal data that is inaccurate, outdated, unnecessary or contrary to the purposes of data processing corrected.

b)    You have the right to have your personal information be accurate, complete and up-to-date (as is necessary for the purposes for which it is to be used).

c)    You have the right to amend your personal information provided that you can successfully demonstrate the inaccuracy or incompleteness of your personal information.

d)    You have the right to withdraw your marketing consent at any time, subject to legal or contractual restrictions and reasonable notice.

e)    If you suspect that we do not follow the applicable data protection regulations, you have the right to lodge a complaint with iGaming Ontario.

If you have a complaint, you can contact Customer Services via Email, Live Chat or Telephone. We will respond to your request as quickly as possible, and we shall keep you informed at regular intervals.

If you do not agree with the decision made by Customer Services you will be entitled to ask that the complaint is reviewed, by the Customer Support Manager. The Customer Support Manager may contact you for further information in relation to the original complaint and revert within 5 days.

If you are not satisfied, you can contact iGaming Ontario (iGo) customer care and dispute resolution (“CCDR”) at   https://www.agco.ca/igaming-complaints-and-inquiries-q1a.

In the event you want to exercise your rights or have any further questions regarding our data processing practices please contact our Privacy Office by emailing us at [email protected]

14.0     INCIDENT BREACH MANAGEMENT PLAN.

The company is committed to protecting the personal information entrusted to it by our customers. While this protection is paramount to our company, we do recognize that no service can be completely secure. In case there is a privacy breach, the company has put in place an incident management plan to help our staff identify, respond, and contain the issue. This plan also outlines requirements to notify relevant authorities and assist them in the handling of any incidents, as well as those affected, and includes steps to investigate and implement changes to prevent future re-occurrences.

15.0       WHAT ARE YOUR OBLIGATIONS?

When providing your personal information, you acknowledge and warrant that you are providing accurate, actual and complete personal data as is being requested by us. If there are any changes to your personal information you must inform us so we can keep your personal information up to date.

If your actions or inactions are in anyway contrary to the data protection laws and this Notice, we retain the right to reject your registration or to suspend or to terminate your account without notice and immediately, in which case you have no right to compensation due to the rejection, suspension or termination of your account.

To protect your Personal Information, we recommend that our customers leverage Two-Factor Authentication wherever possible in combination with a strong password. A strong password should be at least 8 characters long, using a combination of Large and Small Caps, Numbers and Symbols or Characters. LCKY will never ask you to provide your password. Never give out your password to anyone over the phone, SMS, email or social media.

 

[1] An Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, and to amend the Canadian Radio-television and Telecommunications Commission Act, the Competition Act, the Personal Information Protection and Electronic Documents Act and the Telecommunications Act.


[1] An Act to promote the efficiency and adaptability of the Canadian economy by regulating certain activities that discourage reliance on electronic means of carrying out commercial activities, and to amend the Canadian Radio-television and Telecommunications Commission Act, the Competition Act, the Personal Information Protection and Electronic Documents Act and the Telecommunications Act.