Privacy Policy

This Privacy Policy sets forth how luckydreams, operating exclusively through luckydreamsclub.com ("the Website"), collects, processes, stores, and protects personal information. This document is intended for all players and visitors accessing the Website from Australia (AU) and is effective as of 16 June 2025.

Who We Are

OBSERVE: Reviewing operator identity, jurisdiction, and contact requirements.

EXPAND: Clarifying company structure, licensure, and data protection responsibility in context of AU and Curaçao regulation.

REFLECT: Providing transparent legal entity details and direct contact mechanisms for users.

• Operator: The Website is owned and operated by Dama N.V., a company registered and established under the laws of Curaçao, with a principal business address at Scharlooweg 39, Willemstad, Curaçao.
• Registration & Licensing: Dama N.V. operates under gaming license number 8048/JAZ2020-13 issued by Antillephone N.V., valid through 2025. Parent and subsidiary information includes Friolion Ltd. (Cyprus, ΗΕ 419102).
• Contact for Privacy Queries: For inquiries regarding your personal data, contact our Data Protection Office at [email protected]. You may also reach the Privacy Contact Author: Chloe Anderson via the official website contact page.

What Personal Data We Collect

OBSERVE: Identifying specific data types collected as required by AU privacy law (Privacy Act 1988, AML/KYC obligations).

EXPAND: Including all data necessary for gambling operations, user protection, and legal compliance, covering all technology touchpoints.

REFLECT: Ensuring unequivocal notice of all data categories to users in clear, accessible language.

• Personal Identification Data: Full name, date of birth, residential address, email address, and telephone number.
• Account & Verification Data: Copies of identification documents, age verification materials, KYC/AML compliance records.
• Payment Data: Bank account details, credit/debit card numbers, payment provider particulars, transaction records.
• Technical Data: IP address, device information, browser type, operating system, log data, and unique account identifiers.
• Behavioral Data: Betting and gaming activity, deposit and withdrawal history, session information, navigation clicks, time spent, and preferences.
• Cookies & Tracking: Session cookies, persistent cookies, third-party cookies, device fingerprinting, analytics identifiers, and location data (as permitted by device/browser settings).

Legal Basis for Processing

OBSERVE: Conformance with AU Privacy Principles and international gaming KYC/AML laws.

EXPAND: Articulating each lawful ground for data processing in the gambling sector and the interplay between consent, contract, and regulatory requirements.

REFLECT: Presenting users with transparency on why and under what authority their data is processed.

1. User Consent: We process data with your explicit consent for activities such as promotional communications and optional marketing preferences.
2. Contractual Necessity: Data is processed to fulfil our obligations in providing gaming services, account management, payment processing, and customer support as per the terms of service.
3. Legitimate Interests: For preventing fraud, ensuring service integrity, conducting internal analytics, and enhancing user experience, provided such processing does not override your fundamental privacy rights.
4. Legal & Regulatory Compliance: Processing is mandated to comply with applicable laws, including AML/KYC regulations, responsible gambling frameworks, dispute resolution obligations, and reporting to authorities.

Regional Compliance Note: Processing activities are aligned to AU Privacy Act (1988), Anti-Money Laundering and Counter-Terrorism Financing Act 2006, and associated regulations.

Purpose of Processing

OBSERVE: Defining all principal uses of user data within platform operations.

EXPAND: Distinguishing between primary service, regulatory compliance, enhancement, and marketing/analytics purposes.

REFLECT: Explicitly stating the range of data uses and underlying lawful intent.

• Provision of Casino Services: Creating, verifying, and maintaining player accounts; enabling gameplay; processing deposits and withdrawals.
• Regulatory Compliance: Satisfying KYC/AML/CTF verification processes and meeting reporting obligations to authorities.
• Fraud and Risk Management: Preventing cheating, fraud, abuse, or other unlawful behaviour.
• Service Improvement and Personalisation: Analysing usage patterns to identify service improvement opportunities and deliver a tailored user experience.
• Marketing and Promotions (with consent): Sending offers, newsletters, and communications about new services, features, or promotions.
• Analytics and Reporting: Internal statistical analysis for business and compliance purposes.

Disclosure & Sharing

OBSERVE: Identify all parties with whom personal data may be shared in the course of providing services.

EXPAND: Detailing legal or contractual bases for data sharing, including international transfers, with due consideration of AU cross-border disclosure principles.

REFLECT: Communicating to users the limited, controlled circumstances under which their data may be shared.

1. Payment Processing Providers: Data disclosed to reputable payment processors to effect payments and withdrawals, subject to strict confidentiality agreements.
2. Third-Party Service Providers: IT support, analytics, marketing agencies, or game content suppliers are engaged only as necessary and under contractually binding data protection terms.
3. Regulators and Law Enforcement: Information may be disclosed to authorities upon lawful request or where required under applicable laws (e.g., AU regulator, Curaçao licensing body).
4. Affiliates and Advertising Networks (with consent): Select user data may be shared for marketing purposes only where explicit consent has been given and safeguards are in place.

Legal Obligation: All data disclosures are governed by strict diligence to comply with AU and international privacy laws, minimising transfer volumes and ensuring data minimisation principles apply.

International Transfers

OBSERVE: Evaluating all cross-border data flow risks and legal constraints for AU residents.

EXPAND: Ensuring transfer mechanisms meet AU Privacy Principle 8, leveraging internationally recognised safeguards.

REFLECT: Providing assurance on data protection, regardless of destination country.

• Data Destinations: Personal information may be transferred to data processors or service providers in Curaçao, Cyprus, the European Economic Area (EEA), or other jurisdictions where Dama N.V. or approved processors operate.
• Protection Safeguards: All international transfers adhere to contractual safeguards, including Standard Contractual Clauses (SCCs) and equivalent measures to ensure data remains protected in accordance with AU standards.
• Legal Basis: Transfers occur only where necessary for service delivery, compliance, or where the receiving country provides adequate data protection, as assessed under AU law.

Data Retention

OBSERVE: Identifying legally mandated minimum and maximum retention periods under AU law and Curaçao gaming licence conditions.

EXPAND: Categorising retention by data type and defining triggers for deletion.

REFLECT: Communicating clear policies supporting data minimisation and user rights.

• Personal Data: Retained for the duration of the customer relationship and for five (5) years after account closure or cessation of the business relationship, in accordance with legal and anti-money laundering obligations extending through 2025.
• Technical and Cookie Data: Retained for as long as required to fulfil the processing purposes, generally not exceeding two (2) years unless required for a legitimate business or legal compliance reason.
• Deletion Criteria: Your data will be securely erased or anonymised when the retention period expires, upon verified user deletion request (subject to legal retention obligations), or once the processing purpose is satisfied.

Legal Note: Even if a deletion request is made, luckydreamsclub.com may retain necessary data in accordance with AU and international obligations for dispute resolution, regulatory, and fraud prevention purposes.

Your Rights

OBSERVE: Ascertaining user rights under the AU Privacy Act and international best practice models.

EXPAND: Detailing each actionable user right, access procedures, and complaint mitigation processes.

REFLECT: Empowering users with clarity on exercising privacy rights and remedies.

1. Right of Access: You may request access to your personal data held by luckydreamsclub.com and receive a copy within a reasonable timeframe.
2. Correction and Deletion: Users may request correction of inaccurate data or deletion of personal data where further processing is not legally required.
3. Restriction of Processing: In some circumstances, you may request temporary suspension of data use pending review.
4. Objection to Processing: You may object at any time to processing, especially for direct marketing purposes, without detriment to your gaming access rights.
5. Data Portability: Where technically feasible, you may request to export personal data in structured, commonly used formats.
6. Marketing Consent Withdrawal: You may opt out or withdraw consent to receive non-essential marketing communications at any stage via your account or by contacting [email protected].

Cookies & Tracking Technologies

OBSERVE: Enumerating the tracking technologies in use and their respective compliance requirements.

EXPAND: Classifying cookies according to function, source, and user control mechanisms.

REFLECT: Informing users on how to manage all cookie-related preferences for privacy protection.

• Session Cookies: Essential for navigation and platform functionality; these expire when you close your browser and are not used for tracking.
• Persistent Cookies: Remain on your device to remember preferences and enable quicker access; typically set for up to two (2) years.
• Third-Party Cookies: Used by analytics, advertising, and affiliate partners (e.g., Google Analytics, ad networks) to track engagement and improve marketing effectiveness. Such cookies are only deployed with user consent as required by law.
• Managing Cookies: You may disable or manage cookies via your browser settings. Some preferences can also be managed from within your account settings panel on luckydreamsclub.com.

Legal Obligation: Disabling certain cookies may impact website functionality, but essential cookies cannot be refused where required for site operation or security.

Data Security

OBSERVE: Reviewing all security controls and organisational measures implemented by luckydreamsclub.com.

EXPAND: Describing specific safeguards, staff awareness measures, and ongoing monitoring as required by AU and Curaçao standards.

REFLECT: Reassuring users with evidence of data protection diligence and continuous improvement.

• Technical Security: SSL/TLS encryption protects all communications and financial transactions. Sensitive data is stored using advanced encryption and is access-controlled at all stages.
• Organisational Measures: Access to personal data is restricted to trained, authorised personnel only as required for operational purposes.
• Monitoring & Audits: Regular security reviews, vulnerability assessments, and audits are conducted to identify and mitigate risks in line with industry standards.
• Staff Training: Employees and contractors receive ongoing privacy and data security training as part of our compliance programme.

Complaints & Contacts

OBSERVE: Enabling user complaint resolution mechanisms and contact transparency.

EXPAND: Mapping procedures for questions, disputes, and escalation as per legal mandates and industry best practice.

REFLECT: Providing straightforward and accessible pathways for all privacy-related concerns.

• Contact Details: For data protection inquiries, users should direct correspondence to our designated privacy contact, Chloe Anderson, via [email protected] or the online contact interface at luckydreamsclub.com.
• Complaint Procedure:
  1. Submit your inquiry or complaint by email or web form.
  2. We will acknowledge receipt within five (5) business days and aim to resolve all matters within thirty (30) days.
  3. If you are dissatisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC) or relevant data protection authority in your jurisdiction.

Updates

OBSERVE: Outlining transparent mechanisms for future policy updates.

EXPAND: Establishing user notification standards and triggers for material changes.

REFLECT: Reinforcing user awareness and continued consent regarding privacy practices.

• Notification of Changes: Any updates to this Privacy Policy will be posted prominently on luckydreamsclub.com, with advanced notice provided for material changes via email and/or website alert.
• Review Date: Users are advised to periodically review this Policy to remain informed. The latest revision date is 16 June 2025, with all terms projected through at least 2025.