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Privacy Policy

This Privacy Policy describes how luckyelf, operating via luckyelfz.com, manages and protects the personal information of all players and website visitors in accordance with applicable Australian privacy legislation and global industry standards. This Policy applies to all interactions with luckyelfz.com and is effective as of 1 January 2025.

Who We Are

OBSERVE: Luckyelf is operated by Hollycorn N.V., a registered company under the laws of Curaçao (Legal Entity Type: N.V.), with headquarters at Kaya Richard J. Beaujon Z/N, Curaçao. Luckyelfz.com is its official online platform.

  • Legal Details:
    • Operator: Hollycorn N.V.
    • Legal Address: Kaya Richard J. Beaujon Z/N, Curaçao
    • Company Registration Number: not specified
    • Game License: 144359 (Curaçao, valid until 31 December 2025)
    • Parent Company: Hollycorn N.V.; Subsidiary: Libergos Limited (Cyprus)
    • Regional Office: Cyprus (address not specified)
  • Contact for Privacy Matters (Data Protection):

REFLECT: These details ensure transparency about the responsible legal entity and direct contact information for privacy inquiries, as required for lawful data processing under Australian and international standards.

What Personal Data We Collect

OBSERVE: Luckyelfz.com collects a range of personal, technical, payment, and behavioral data to fulfil contractual, regulatory, and operational obligations.

  • Personal Data:
    • Full name, date of birth, e-mail address, telephone number, residential address, identification documentation
  • Technical Data:
    • IP address, device type, browser, session logs, operating system, access times
  • Payment Data:
    • Bank details, card information (processed securely), transaction history, payment method identifiers
  • Behavioral Data:
    • Betting history, wagering activity, website interactions (clicks, navigation), player preferences, responsible gambling usage data
  • Cookies & Similar Technologies:
    • Session cookies, persistent cookies, third-party cookies, local storage, web beacons

REFLECT: Collection of these data categories is necessary for the operation of luckyelfz.com, compliance with anti-money laundering (AML)/know your customer (KYC) obligations, and service optimisation, as required by relevant Australian and Curaçaoan regulations.

Legal Basis for Processing

OBSERVE: Processing of personal data by luckyelfz.com is governed by Australian Privacy Principles, Gambling regulation, and international standards.

  1. User Consent: Personal data is processed based on informed consent for account creation, marketing communications, and use of cookies/analytics. Users may withdraw consent at any time via account settings or by contacting [email protected].
  2. Contractual Necessity: Data is processed where required for fulfilling contracts with players, including account management, deposits, withdrawals, and bonus administration.
  3. Legal Obligations: Luckyelfz.com is required to collect and retain certain data to comply with anti-fraud, KYC, AML, and responsible gambling obligations mandated by relevant laws (including reporting to regulators).
  4. Legitimate Interests: Personal data may be processed to improve services, conduct analytics, secure transactions, enforce terms, and prevent abuse or violations.

REGIONAL COMPLIANCE NOTE: All lawful grounds for data processing reflect both Australian Privacy Act 1988 (Cth), associated guidelines, and international gambling regulatory obligations.

Purpose of Processing

OBSERVE: Data collected by luckyelfz.com is processed for specific, explicit, and legitimate purposes as mandated by law and business practice.

  • Service Provision: To enable creation, verification, and management of user accounts; process deposits, bets, and withdrawals; provide bonuses and support services.
  • Compliance and Security: To meet regulatory (including AML/KYC) requirements, identify suspicious activity, and ensure site and payment integrity.
  • Analytics and Optimisation: To monitor website performance, analyse user behaviour, and enhance luckyelfz.com services according to user needs and preferences.
  • Marketing and Communication: To send promotional offers or service updates (with user consent), operate loyalty and retention campaigns.
  • Fraud & Abuse Prevention: To detect, prevent, and respond to unauthorised or unlawful activities, abuse of services, or violations of site terms.

REFLECT: These defined purposes are aligned with the requirements of Australian and Curaçao regulations for data minimisation, purpose limitation, and transparency.

Disclosure & Sharing

OBSERVE: Luckyelfz.com may share your data in a controlled, secure manner with specific categories of third parties to fulfil contractual and statutory requirements.

  • Payment Partners: Banks, payment processors, and other financial institutions (including Libergos Limited in Cyprus) to process deposits and withdrawals.
  • Service Providers: Technical support, hosting, IT security, analytics, and marketing partners who facilitate site operations under strict confidentiality.
  • Regulators & Authorities: Data may be disclosed to regulatory or governmental authorities upon lawful request-e.g., for KYC/AML compliance or dispute resolution.
  • Affiliates & Advertising Networks: Selected disclosure for marketing purposes, always subject to user consent and applicable privacy laws.

Legal Obligation: Every such disclosure is conducted via secure means, under contract, and only to the extent required for compliance or service provision. No data is sold to unauthorised third parties.

REFLECT: All sharing of data by luckyelfz.com is strictly regulated and justified under privacy legislation and gambling regulatory frameworks applicable in Australia and Curaçao.

International Transfers

OBSERVE: Luckyelfz.com's operations necessitate transfer of personal data outside Australia, principally to Curaçao (operator's headquarters) and Cyprus (payment & technical processing via Libergos Limited).

  1. Data Transfer Mechanisms: All cross-border transfers are governed by legally mandated safeguards, including use of standard contractual clauses, technical encryption, and adherence to Curaçaoan regulatory requirements.
  2. Protections & Guarantees: Data protection standards equivalent to Australian and EU requirements are maintained to ensure that transferred data remains secure and is not processed for purposes other than those set by luckyelfz.com.
  3. User Notification: Players are informed of the possibility of international transfers at registration and may contact [email protected] for further details.

REFLECT: International transfer protocols are established in compliance with the Australian Privacy Principles (APPs) and industry best practices for gambling operators with global presence.

Data Retention

OBSERVE: Luckyelfz.com retains different categories of data for timeframes set by law and regulatory guidance.

  • Personal Data: Retained for the duration of the user's account and for up to 5 years after account closure, as required for legal defence, fraud prevention, and regulatory obligations.
  • KYC, AML, and Transaction Records: Kept for at least 5 years following the last transaction, to comply with applicable gambling and anti-money laundering laws.
  • Cookies and Technical Logs: Retained according to technical necessity (typically up to 2 years) or until manually deleted by the user via browser/device settings.

Deletion Criteria: Data is deleted when it is no longer required for the purposes collected, upon valid user request (unless law requires retention), or if retention period ends.

REFLECT: Retention protocols are established to meet Australian requirements (Privacy Act 1988) and international gaming law, with 2025 alignment on all durations.

Your Rights

OBSERVE: Players and visitors of luckyelfz.com have rights in relation to their personal data under the Privacy Act and relevant global standards.

  • Access: You can request a copy of your personal data held by luckyelfz.com at any time.
  • Correction: You have the right to correct or update inaccurate or incomplete data via your account or by contacting us.
  • Deletion: Request erasure of your data, subject to legal retention obligations.
  • Restriction of Processing: You may request limitations on how your data is processed in certain circumstances.
  • Objection: You can object to processing based on legitimate interests or for direct marketing purposes.
  • Data Portability: Request transfer of your data to another operator where technically feasible.
  • Withdrawal of Consent: Withdraw previously given marketing or analytics consents at any time.

REFLECT: Luckyelfz.com ensures these rights are actionable and provides mechanisms for users to exercise their rights, consistent with Australian and international legal practice.

Cookies & Tracking Technologies

OBSERVE: Luckyelfz.com uses cookies and similar tracking technologies to enhance user experience, enable functionality, and gather analytics.

  • Session Cookies: Temporary cookies used for site navigation and security, deleted when the session ends.
  • Persistent Cookies: Remain on your device for a set period (up to 2 years), supporting preferences and login sessions.
  • Third-party Cookies: Provided by analytics and advertising partners for traffic analysis and personalised marketing, subject to user consent.

Cookie Management

  • Users may manage or disable cookies via browser settings or internal account panels.
  • Disabling cookies may limit some site features.

REFLECT: Usage of cookies by luckyelfz.com is transparent and fully configurable by the user, in compliance with Australian privacy rules and EU best practices.

Data Security

OBSERVE: Luckyelfz.com is committed to robust technical and organisational measures safeguarding personal data.

  • Technical Protections:
    • SSL/TLS encryption for all transmissions
    • Data encryption at rest and in transit
    • Regular vulnerability scans and penetration testing
  • Organisational Protections:
    • Access to personal data strictly limited to authorised staff with confidentiality training
    • Mandatory staff security training and awareness programs conducted annually
    • Independent security audits performed regularly

REFLECT: These layered protections ensure compliance with both Australian legal requirements and global gambling best practices, providing effective data security for all luckyelfz.com users.

Complaints & Contacts

OBSERVE: Luckyelfz.com provides clear procedures for raising privacy concerns or complaints.

  • Contact Data Protection Officer:
  • Complaint Procedure:
    1. Submit your complaint by e-mail or in writing with details of your concern
    2. Your complaint will be acknowledged within 5 working days
    3. A thorough investigation will be conducted by the data protection team
    4. You will receive a reasoned response or resolution within 30 days of acknowledgment
    5. If unresolved, you may escalate to the appropriate regulatory authority in Australia (e.g. Office of the Australian Information Commissioner, OAIC)

REFLECT: The complaints procedure ensures prompt, fair, and transparent handling of data protection concerns, consistent with Australian statutory requirements.

Updates

OBSERVE: Luckyelfz.com commits to notifying users of significant changes to this Privacy Policy via prominent website notices and, where relevant, via e-mail.

  • Notification Methods:
    • Policy updates published on luckyelfz.com's Privacy Policy page
    • Direct notifications by e-mail to registered users if changes are material
  • Revision Date: Last updated on 1 January 2025

REFLECT: Users are encouraged to review this Policy regularly to stay informed about how luckyelfz.com protects personal data in a changing regulatory environment.