Luckee Privacy Notice

Overview

Luckee Gaming Platform Ltd. (“Luckee” “We” “Us”) is an innovative online gaming community that aims to revolutionize the gaming experience by fostering a sense of belonging and promoting responsible gaming practices.

We value your trust in us by sharing your information with us. We prioritize your privacy and are dedicated to protecting it. This Privacy Notice outlines and describes the Personal Information we collect about you, as well as your privacy rights regarding why, how, and when we collect, use, store, share, and protect your information across our website, payment platforms (“Platforms”), APIs, Software Applications, (“Apps”), email notifications and tools regardless of how you use or access them. This Privacy Notice is applicable to the Website, software applications and payment platforms offered by Luckee or its subsidiaries or affiliated companies collectively referred to as Luckee “Services”.

1. Definitions

“Luckee”, “we”, “us”, or “our” in this Privacy Notice means the Luckee Gaming Platform Ltd and subsidiaries or affiliates, the entity that is responsible for processing your personal information. Luckee and its affiliates are part of a group which comprises local operating entities in several markets across the globe. “Account” means a Luckee Account.

“Consent” means any freely given, specific, informed, and unambiguous indication of your wishes by which you, through a statement or a clear affirmative action, signify your agreement to the collection and processing of Personal Information relating to you.

“Cookie(s)” is a small data file that is transferred to your computer or mobile device. It enables us to remember your account log-in information, IP addresses, web traffic number of times you visit, browser type and version, device details, date, and time of visits.

“Data Protection Legislation” refers to the Nigeria Data Protection Act 2023 (NDPA) and all other applicable legislations, regulations and other regulatory requirements in force from time to time which apply to a party, all relating to the use of Personal Data.

“Data Subject” refers to any individual person who can be identified, directly or indirectly, through personal data collected about them. Essentially, as a user of our Platform and Services, you are a data subject for the purpose of this Privacy Notice .

“Personal Information” means information that can be used to identify a living person including name, contact address, email address, password; financial information such as a bank account number, payment card, and bank verification number, taxpayer identification; personal identification information including a government-issued identity card, company identity card, business card. It may also include anonymous information that is linked to you, for example, your internet protocol (IP), log-in information, address, location, device, or transaction data.

“Services” means the products listed on our website, https://www.luckee.ng/, and include any form of betting, gambling, or interactive entertainment offered on the Platform.

“Platform” means any platform including mobile applications, websites, and social media platforms.

“User,” “you” means an individual who uses the Services or accesses the Platform and has agreed to use the end services of Luckee.

“Special Categories of Personal Information” means details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

2. Our Privacy Principles

Luckee adheres to the following core principles:

• To empower you, our user, to be in charge of your personal information and to make your own voluntary choices about your personal data, subject to applicable law and regulations;
• To keep and secure your personal information by ensuring that appropriate security measures are put in place and your personal information is protected;
• To be transparent and to educate our users about their personal information, how we collect, for what purpose we collect it, and how we secure it;
• To abide by laws and regulations: Luckee is a company with local privacy expertise, and our privacy practices reflect local practices and legal requirements; and
• To collect and store personal information on a “need to collect” basis: Luckee collects personal information to perform its Services for you. We work to have measures in place to prevent collecting and storing personal data beyond what we need.

3. Information We Collect

3.1 Personal Information You Provide

You make certain Personal information available to us when you:

• visit our website;
• sign up for a Luckee Account;
• access any of our Services;
• fill in our online forms; or
• contact our customer support team.

We may collect, use, process, store, or transfer such personal information. Such personal information include:

• Identity data including your full name(s), identification documents such as your passport or any government-issued identity card, gender, a photograph (if applicable), date of birth, and any other registration information you may provide to prove you are eligible to use our services;
• Contact data which is needed to reach you, such as your contact address, email address, telephone number, details of the device you use and billing details;
• Financial data, includes your bank account number and your financial transaction history while on this platform;
• Profile Data includes your username, nickname and password, feedback;
• Marketing and communications information which includes a record of your decision to subscribe or to withdraw from receiving marketing materials from us or from our third parties;
• Usage Information which includes information about how you access and use our Services, such as your actions on the Services, including your interactions with others on the Services, your username, your nickname, and other content you provide. Please remember that Luckee may, but has no obligation to, monitor, record, and store Usage Information in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, to protect and defend our rights and property, or for other reasons relating to our provision of the Services. By using the Services, you consent to the recording, storage, and disclosure of such information you send or receive for these purposes; and
• Records of your discussions with us, if we contact you and if you contact us.

As a principle, we do not collect any Special Categories of Personal Information. If we do collect Special Categories of Personal Information, we will ensure compliance with applicable laws. We may also collect, store, use, and transfer non-personal information or anonymized data such as statistical or demographic data.

3.2 Automatically Collected Information

We and our third party partners may automatically collect certain information when you visit our Platform. This includes log/technical information which our servers automatically record when you access Luckee Services, information that your browser sends whenever you visit our website, links you have clicked on, length of visit on certain pages, unique device identifier, log-in information, location, and other device details.

3.3 Personal Information from Third Parties and Other Sources

We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from you. These may include:

• Data we collect from business partners, marketing, payments gateways, and vendor partners.
• Data we collect if you link, connect, or log in to your Luckee Account with a third-party service (e.g. Google, Apple). The third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
• Publicly available data we may obtain from publicly available sources that may include your contact information and other information. We may combine this information with the information we collect from you directly. We use this information to contact you, to send you advertising or promotional materials, to personalize our Services, and to better understand the demographics of our users.

This Privacy Notice applies to Luckee Services only. We do not exercise control over the sites displayed or linked from within our various services. These other sites may place their own cookies, plug-ins, or other files on your computer, collect data, or solicit personal information from you. Luckee does not control these third-party websites and we are not responsible for their privacy statements. Please consult such third parties’ privacy statements.

4. How We Use Your Personal Information

4.1 Permitted Use and Processing Purposes

We will use and process the information we collect for purposes described in this Privacy Notice or as otherwise described to you on our Services or in connection with our Services. These purposes may include:

• To create and process your account and deliver the Services to you, including to allow you to register for the Services and participate in gaming activities and for Luckee to authenticate your identity, handle billing and account management, fulfill our legal and regulatory obligations such as obligations that apply to being a licensed Nigerian Mobile Gaming platform, event market, and complete other administrative matters;
• Send you transactional information, including confirmations, invoices, technical notices, product and services information and announcements, software updates, security alerts, support and administrative messages, and information about your transactions with us;
• Communicate with you such as to respond to your comments and questions, deliver newsletters or other content we believe you will be interested in, provide customer service or feedback, contact you about amounts owed, conduct surveys, respond to employment opportunities for which you’ve applied, notify you about upcoming events, or for any other purposes in connection with the Services;
• Conduct research and analytics to understand our visitors and customers and tailor our product offerings;
• Provide you with updates about products and services offered by us and selected partners, as well as facilitate new promotions, and rewards;
• Make suggestions and recommendations to you about things that are similar to those about which you have inquired or that may otherwise be of interest to you, such as providing you with advertisements based on your interests and activity on the Services;
• Monitor, administer, and enhance our Services, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
• Enhance the safety and security of our Services, Platform, and users, and investigate or provide notice of fraud or unlawful or criminal activity;
• Perform audits and protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and
• Comply with applicable laws and legal obligations.
• For other purposes for which we provide specific notice at the time of collection.

4.2 Our Legal Basis for Collecting and Processing Your Personal Information

Please note that you are not obliged to share your Personal Information with us. But if you refuse to share the Personal Information we require from you for the purpose of providing our Services, we will not be able to provide our Services to you. To use your information as described above, we rely on the following legal bases:

• Your Consent: Where you agree to us collecting your personal data by using our Services.
• Our Contractual Obligation: Without your personal data, we cannot provide our Services to you.
• Our Legal Obligation: To ensure we are fully compliant with all applicable Financial legislations such as Anti-Money Laundering and Counter Terrorism Financing Laws, we must collect and store your personal data. We protect against fraud by checking your identity with your personal data.
• Our Legitimate Interest: In many cases, we handle information on the ground that it furthers our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, these include:
  • Customer service
  • Marketing, advertising, and fundraising
  • Protecting our users, personnel, and property
  • Managing user accounts
  • Organizing and running events and programs
  • Analyzing and improving our business
  • Managing legal issues

  We may also process information for the same legitimate interests of our users and business partners.

• Public Interest and Mandate: Processing is necessary for the performance of a task carried out in the public interest or in exercise of official public mandate vested in Luckee.

For the purpose of this Privacy Notice, consent means any freely given, specific, informed and unambiguous indication of the Data Subject's wishes by which they, through a statement or a clear affirmative action, signify their agreement to the processing of Personal Information relating to them.

5. How We Secure Your Personal Information

The security of your Personal Information is important to Luckee. We are committed to protecting the information we collect about you. We maintain administrative, technical and physical controls designed to protect the Personal Information you provide, or we collect against loss or theft, as well as against any unauthorized access, risk of loss, disclosure, copying, misuse, or modification.

Other security measures include but not limited to, secure servers, firewall, data encryption and granting access only to employees in order to fulfill their job responsibilities.

Where you use a password for your Account, please ensure you do not share this with anyone, and the password is kept confidential at all times.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of your Personal Information is protected and maintained. Transmitting information online is not entirely secure. Whilst we take all reasonable steps to ensure that your Personal Information is secured and well protected we do not guarantee that all information provided online is secure.

6. When We May Retain Your Personal Information

We will only retain personal information on our servers for as long as is reasonably necessary as long as we are providing Services to you. When you close your Account, your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection, and prevention. Where we retain your Personal Data, we do so in compliance with limitation periods under the applicable law.

7. When We Disclose Your Personal Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the personal information we collect. We may share your personal information in the instances described below:

• Service Providers

  We may disclose your information with certain authorized and vetted contractors, subcontractors, third-party vendors, and service providers who help us run and protect our business. This includes sending emails, conducting business analytics, marketing, and data processing. For example, we may share personal data with service providers that identify and serve targeted advertisements or provide mailing services, tax and accounting services, contest fulfillment, web hosting, or analytics services.

• Legal Compliance and Protection

  We may disclose your information if we are required to do so by law or believe good faith that such disclosure is permitted by this Privacy Notice or reasonably necessary or appropriate for any of the following reasons:
  • to comply with legal process;
  • to enforce or apply our Terms of Use and this Privacy Notice, or other contracts with you, including investigation of potential violations thereof;
  • enforce our Code of Conduct and policies contained and incorporated therein,
  • to respond to your requests for customer service; and
  • to protect the rights, property, or personal safety of Luckee, our agents and affiliates, our users, and the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.

• Business Transfers

  As we continue to develop our business, we may engage in certain business transactions, such as the transfer or sale of our assets. In such transactions, (including in contemplation of such transactions, e.g., due diligence) your information may be disclosed. If any of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.

• Affiliated Companies

  We may disclose your information with current or future affiliated companies.

• Consent

  We may disclose your information to any third parties based on your consent to do so. Where required by law, and in some other cases where legally permissible, we handle information on the basis of consent. Where we handle your information on the basis of consent, you have the right to withdraw your consent; in accordance with applicable law.

• Aggregate/De-identified Information

  We may disclose de-identified and/or aggregated data for any purpose to third parties, including advertisers, promotional partners, and/or others.

8. How We Transfer Your Personal Information

Luckee may transfer Personal Information that we maintain about you to recipients outside the country in which the Personal Information was originally collected. The data protection regulations of these countries may be different from those of your country. Where Personal Information is to be transferred to a country outside Nigeria, Luckee shall put adequate measures in place to ensure the security of such Personal Information. Transfer of Personal Information out of Nigeria would be in accordance with the provisions of Data Protection Legislations. Luckee will therefore only transfer Personal Information out of Nigeria on one of the following conditions:

• The transfer is necessary for the performance of a contract between Luckee and the Data Subject or implementation of pre-contractual measures taken at the Data Subject’s request.
• The transfer is necessary to conclude a contract between Luckee and a third party in the interest of the Data Subject.
• The consent of the Data Subject has been obtained.
• The transfer is necessary for reasons of public interest.
• The transfer is for the establishment, exercise, or defense of legal claims.
• The transfer is necessary in order to protect the vital interests of the Data Subjects or other persons, where the Data Subject is physically or legally incapable of giving consent.
• Luckee will take all necessary steps to ensure that Personal Information is transmitted in a safe and secure manner. Details of the protection given when your Personal Information is transferred outside Nigeria shall be provided to you upon request.

9. Your Rights as a Data Subject

Individuals who have their Personal Information held by Luckee are entitled to exercise the rights below and may contact us accordingly:

• Right to request for and access their Personal Information collected and stored. Where data is held electronically in a structured form, such as in a Database, the Data Subject has a right to receive that data in a common electronic format.
• Right to information on their personal information collected and stored.
• Right to objection or request for restriction.
• Right to object to automated decision-making.
• Right to request rectification and modification of Personal Information which Luckee keeps.
• Right to request for deletion of their data.
• Right to request the movement of data from Luckee to a third party; this is the right to the portability of data.
• Right to object to, and to request Luckee to restrict the processing of their information.

Your request will be reviewed by Luckee’s Data Protection Officer (DPO) and carried out except as restricted by law or Luckee’s statutory obligations. You may decline to provide your Personal Information when it is requested by Luckee, however, certain services or all the services may be unavailable to you. You may review your account settings and update your Personal Information directly or by contacting us. You have various rights with respect to the collection and use of your information through the Services. Those choices are as follows:

10. Third-Party Links and Services

The Services may contain links to third-party websites which may include (e.g., social media sites like Facebook and Twitter), third-party plug-ins (e.g., the Facebook “like” button and Twitter “follow” button), and other services. If you choose to use these sites or features, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or privacy practices of such third-party websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Notice. We encourage you to read the privacy statements of each and every site you visit.

11. Third Party Tracking and Online Advertising

We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third-party online advertising networks, social media companies, and other third-party services to collect information about your use of our Services over time so that they may play or display ads on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. For advertising, we may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online on other platforms more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Notice. Some of these companies are members of the Network Advertising Initiative (NAI), which offers a single location to opt out of ad targeting from member companies. To learn more, please visit http://www.networkadvertising.org/choices or the Digital Advertising Alliance (DAA) resources, available at http://www.aboutads.info/choices. You may also be able to set your browser to delete or notify you of cookies by actively managing the settings on your browser or mobile device. Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again. You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt out of interest based ads” (Android).

Google Analytics and Advertising – We use Google Analytics to recognize you and link your devices and when you use our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the Services. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, see “How Google uses data when you use our partners’ sites or apps” linked here: http://www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On, here: https://tools.google.com/dlpage/gaoptout/. We may also use certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics

Demographics and Interest Reporting – These features let us use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your use of our Services. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

12. Cookies

Like many other websites, we use cookies to distinguish you from other users and to customize and improve our services. Some browsers may automatically accept cookies while some can be modified to decline cookies or alert you when a website wants to place a cookie on your computer. If you do choose to disable cookies, it may limit your ability to use our website.

13. Children

The Services are intended for users over the age of 18 and are not directed at children as contemplated under the NDPA. If we become aware that we have collected personal information from children or personal data (as defined by the NDPA), we will take reasonable steps to delete it as soon as practicable. You can contact us here regarding this matter on legal@Luckee.com.

14. Updates to our Privacy Notice

We may change, amend, or review this Privacy Notice from time to time to reflect new services or changes in our Privacy Notice and place any updates on this page. All changes made will be posted on this page and where changes will materially affect you, we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Notice.

15. Contact Us

Luckee has appointed a Data Protection Officer (DPO) to oversee data protection and privacy compliance. All communications with us will be treated accordingly, based on our Privacy Notice as well as the applicable data protection laws and regulations. If we require additional details, we may contact you. All access requests, questions, comments, complaints, and other requests regarding our privacy practices should be sent to legal@Luckee.com.