Privacy Policy

This privacy policy was last updated on 1 February 2025.

1. PRIVACY

luckygem is committed to protecting your personal data. This privacy policy lets you know what information we collect when you use our services, why we collect this information and how we use the information collected.

Please note: this privacy policy is agreed between you and luckygem. ('We', 'Us' or 'Our', where applicable). This privacy policy is an integral part of the Terms and Conditions of luckygem.

The website luckygem ('Casino', 'Website', 'Company', 'We', 'Us', 'Our') is owned and operated by Virtual Connect Sociedad de Responsabilidad Limitada, a company registered under applicable legislation and located in Costa Rica, Jaco.

We may update this privacy policy from time to time and will notify you of these changes by posting the updated terms on our platforms. We recommend that you consult this privacy policy regularly.

2. INFORMATION COLLECTED

We consider information that can be used to identify an individual, including but not limited to first and last name, date of birth, home address or other physical address, email address, phone number or other relevant information as personal data ('Personal Data'). You may be asked to provide Personal Data when you use our website, create an account or make use of our services. The Personal Data we collect may include information such as: contact details (including phone number), shipping details, billing details, transaction history, website usage preferences and feedback about the Services. This information is stored by us on servers located in Costa Rica, Jaco and from time to time elsewhere. When you interact with the services, our servers maintain a unique activity log that collects certain administrative and traffic information, including the source IP address, time of access, date of access, web page(s) visited, language used, software crash reports and the type of browser used. This information is essential for the provision and quality of our services. We do not collect Personal Data about you without your knowledge.

3. MANNER OF COLLECTING AND PROCESSING DATA

We may automatically collect certain data as discussed above and receive Personal Data about you when you provide such information through the services or other communications and interactions on luckygemm.net. We may also receive Personal Data from online suppliers and service providers, and from customer lists lawfully obtained from third-party suppliers. In addition, we may engage the services of third-party service providers to provide technical support, process your online transactions and maintain your account. We have access to all information you provide to such suppliers, service providers and third-party e-commerce services, and we will use the Personal Data as set out in this Privacy Policy below. This information will only be provided to third parties outside the company in accordance with this Privacy Policy. We take steps to ensure that our arrangements with third-party service providers and online suppliers protect your privacy.

4. USE OF INFORMATION

We use the Personal Data we collect from you to provide our Services, offer customer service, carry out necessary security and identity checks, process your online transactions, support your participation in third-party promotions, meet certain business requirements and for all other purposes related to the operation of the Services. We may therefore share your Personal Data with our carefully selected partners (including other parties with whom they have data-sharing arrangements).

Your Personal Data may also be used by us to provide you with: (1) promotional offers and information about our products and services; and (2) promotional offers and information about the products and services of our partners, to expand the offering and improve our customer service. From time to time we may ask you for information via surveys or competitions. Participation in these surveys or competitions is entirely voluntary and you decide whether you wish to provide such information. Information requested may include contact details (such as name, correspondence address and phone number) and demographic data (such as postcode or age). By accepting a prize or winnings from one of our competitions, you agree that your name may be used for advertising and promotional purposes without additional compensation, except where prohibited by law. Unless you have chosen not to receive promotional information, we may also use your Personal Data (including your email address and phone number) to inform you about our products, services and promotions, including other gambling products (such as online poker, casino, betting, backgammon), and products and services of third parties carefully selected by us.

5. CERTAIN EXCLUDED DISCLOSURES

We may disclose your Personal Data if required by law, or if we believe in good faith that such action is necessary to: (1) comply with a legal process served on us, one of our sites or the services, or in situations where we are under a comparable legal obligation; (2) protect and defend our rights or property; or (3) act to protect the personal safety of users of the services or the public. If in our sole judgment it appears that you have cheated or attempted to defraud us, the company or any other user of the services in any way, including but not limited to game manipulation or payment fraud, or if we suspect you of fraudulent payments, including the use of stolen credit cards, or any other fraudulent activity (including a chargeback or other reversal of a payment) or prohibited transaction (including money laundering), we reserve the right to share this information (along with your identity) with other online gambling websites, banks, credit card companies, competent bodies and relevant authorities. (4) For research purposes related to the prevention of addiction, data may be anonymised and passed on to the relevant bodies.

6. ACCESS

You can unsubscribe from receiving promotional communications by selecting this option via your account settings on our sites or services, or in the emails you receive from us, or at any time by sending an email or writing to us via Customer Service.

In addition, you can contact us if you: 1) wish to confirm the accuracy of the Personal Data we have collected about you; 2) wish to update your Personal Data; and/or 3) have a complaint about our use of your Personal Data. If requested, we will (1) update any information you have provided to us, provided you demonstrate the necessity of these changes, or (2) flag information to prohibit future use for marketing purposes. For the avoidance of doubt, nothing in this Privacy Policy prevents us from retaining your Personal Data when we are legally required to do so.

7. COOKIES

Information placed on your device

When you visit our services, we may store information on your device. These pieces of information are called cookies, small text files that are stored on your device when you visit online pages and that record your preferences. We also use Local Shared Objects or 'flash cookies'. 'Flash cookies' are similar to browser cookies. They enable us to remember things about your visits to our sites. Neither cookies nor flash cookies can be used to access or make use of other information on your computer. We use these methods only to track your use of our services. Cookies help us monitor traffic to the site, improve our services and make use easier and/or more relevant for you. We use flash cookies and third-party cookies to show you more relevant and attractive advertisements.

Strictly necessary cookies

Strictly necessary cookies are essential to enable a user to navigate a website and use its features, such as accessing secure areas of the website or carrying out financial transactions. Without these cookies we would not be able to operate our websites efficiently.

During the registration process

These cookies contain information collected during your registration and enable us to recognise you as a customer and provide you with the services you need. We may also use this data to better understand your interests while you are online and to improve your visits to our platforms.

On our website

For visitors to our website, we use cookies to collect information. Our servers use three different types of cookies:

A 'session-based' cookie: This type of cookie is assigned to your computer only for the duration of your visit to our website. A session-based cookie helps you navigate our website more quickly and, if you are a registered customer, we can provide you with information that is more relevant to you. This cookie expires automatically when you close your browser.

A 'permanent' cookie: This type of cookie remains on your computer for a period set for each cookie. Flash cookies are also permanent.

'Analytical' cookies: This type of cookie enables us to recognise and count the number of visitors to our site and to see how visitors use our services. These help us to improve the functioning of our sites, for example by ensuring that you can easily find what you are looking for.

You can accept or refuse cookies. Most web browsers accept cookies automatically, but if you wish, you can usually adjust your browser settings to refuse cookies. The Help menu on the menu bar of most browsers tells you how to prevent your browser from accepting new cookies, how to receive a notification when you receive a new cookie and how to disable cookies entirely.

Flash cookies

You can adjust your Flash Player settings to prevent the use of flash cookies. The Settings Manager of your Flash Player allows you to manage your preferences. To refuse flash cookies from all third-party content, go to the 'Global Storage Settings' panel of the Settings Manager and uncheck the box labelled 'Allow third-party flash content to store information on your computer' and close the Settings Manager. You can also adjust your settings for specific websites you visit via the 'Website Storage Settings' panel, also found in the Settings Manager.

If you use an older version of Flash Player or an older web browser, the Settings Manager may not be available to you. We recommend that you update your Flash Player and browser to the latest available versions.

If you choose to refuse cookies, you may not be able to use all the interactive features on our sites.

8. CONSENT TO USE OF ELECTRONIC SERVICE PROVIDERS

In order to play for real money on our services, you must transfer money to us and receive money from us. We may use third-party electronic payment systems to process such financial transactions. By accepting this Privacy Policy, you expressly consent to the use of the Personal Data necessary for processing transactions, including, where necessary, the transfer of information outside your country. We take steps to ensure that our arrangements with payment systems protect your privacy.

9. CONSENT TO SECURITY CHECK

We reserve the right to carry out a security check at any time to validate the registration details you have provided and to check your use of the services and your financial transactions for possible violations of our Terms and Conditions and of applicable legislation. By using our services and thereby agreeing to our Terms and Conditions, you give us permission to use your Personal Data and to provide your Personal Data to third parties for validating the information you provide during use of our services, including, where necessary, the transfer of information outside your country. Security checks may include, but are not limited to, requesting a credit report and/or otherwise verifying the details you have provided via third-party databases. In addition, you agree to provide, in order to facilitate these security checks, the information or documentation that we may request from you.

10. SECURITY

We understand how important security is and what techniques are needed to secure data. All Personal Data we receive directly from you is stored in an encrypted and password-protected database within our secure network, behind advanced firewall software. (Our Services support SSL Version 3 with 128-bit encryption). We also take steps to ensure that our subsidiaries, agents, affiliates and suppliers maintain adequate security measures.

11. PROTECTION OF MINORS

Our Services are not intended for or directed at persons under the age of eighteen (18) years (or the legal age in their respective jurisdiction). Anyone who provides data to us through any part of the services thereby indicates that they are eighteen (18) years of age or older (or the legal age in the respective jurisdiction). It is our policy to detect attempts by minors to access our services, which may include initiating a security check. If we discover that a minor has attempted or actually provided personal data through our services, we will not accept this information and will take steps to remove it from our records.

12. INTERNATIONAL DATA TRANSFERS

Personal Data collected through the services may be stored and processed in any country where we or our affiliates, suppliers or agents have facilities. By using our services you expressly consent to any transfer of information outside your country (including to countries that may be considered to lack adequate privacy legislation). Nevertheless, we take steps to ensure that our employees, affiliates and suppliers adhere to our privacy standards, regardless of their location.

13. THIRD-PARTY PRACTICES

We cannot guarantee that data you provide to a third-party online site that links to or from the services, or data collected by a third party that administers our affiliate programme (if applicable) or any other programme, will be protected, as these third-party online sites are not owned by us and are operated entirely independently of us. All information collected by these third parties is subject to the privacy policy, if any, of that third party.

14. LEGAL DISCLAIMER

The Services operate 'AS IS' and 'AS AVAILABLE', without any liability. We are not responsible for events outside our direct control. Due to the complex and constantly changing nature of our technology and business operations, we cannot guarantee, nor do we claim, that the privacy of your Personal Data will be error-free, and we are not liable for any indirect, incidental, consequential or punitive damages relating to the use or disclosure of said Personal Data.

15. CONSENT TO PRIVACY POLICY

Your use of our services signifies your agreement to our Privacy Policy.

This is our complete and exclusive Privacy Policy and supersedes all previous versions. This Privacy Policy should be read in conjunction with our Terms and Conditions and any additional applicable terms posted on our platforms. We may amend this Privacy Policy periodically and will notify you of these changes by posting the updated terms on our Platforms. Your continued use of our services following changes to this Privacy Policy signifies your acceptance of those changes. We recommend that you consult this Privacy Policy regularly.

In addition, under Article 77 of the GDPR, you have the right to lodge a complaint regarding the processing of your data with a supervisory authority, in particular in the member state of your habitual residence, place of work or place of the alleged infringement.

16. OTHER WEBSITES

Our website may contain links to other websites that are outside our control and are not covered by this Privacy Policy. If you visit other sites via the links provided, the operators of those sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours. We are not responsible. Only the operators of those websites are responsible for their functionality or any errors on the linked sites.

17. OTHER CONDITIONS

All versions of the Privacy Policy, except the English-language version, are provided for information purposes only. The English-language version is authoritative in the event of discrepancies or conflicts between different versions.