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Privacy Policy

This Privacy Policy explains how your personal information is collected, used, and protected when you use lucky-elf-ca.com. It applies to all players and website visitors engaging with casino services through lucky-elf-canada as of November 6, 2025. Please read this policy carefully to understand your rights and our obligations regarding your data.

Who We Are

OBSERVE: The operator of lucky-elf-ca.com is Hollycorn N.V., a legally registered entity responsible for data processing activities for lucky-elf-canada.

  • Legal Entity: Hollycorn N.V.
    • Registration number: 152125
    • Legal address: Scharlooweg 39, Willemstad, Curaçao
    • License: 8048/JAZ2019-015 (issued by Antillephone N.V., Government of Curaçao, valid through 2025)
  • Data Protection Contact:
    • Email: [email protected] (for all privacy and data protection inquiries)
    • Responsible Person: Data Protection Officer (DPO), Hollycorn N.V.

For any questions regarding this Privacy Policy or your data, please contact our DPO at [email protected].

What Personal Data We Collect

OBSERVE: We collect personal, technical, financial, and behavioral information necessary for lawful operation, user experience, and regulatory compliance.

  • Personal Identification Data: Full name, date of birth, residential address, email address, and phone number provided during registration or account management.
  • Technical Data: IP address, device identifiers, browser type, operating system, access logs, and connection timestamps.
  • Payment and Transaction Data: Payment card/bank details, transaction records, deposit and withdrawal history, and financial verification documents (subject to KYC/AML requirements).
  • Behavioral and Usage Data: Game and betting history, site navigation patterns, clicks, interaction logs, and communication records.
  • Cookies and Similar Technologies: Session cookies, persistent cookies, third-party analytics and advertising cookies, beacons, and device fingerprinting.

EXPAND: Data is collected both directly (from you) and indirectly (via automated systems and third-party integrations) and may be supplemented to meet regulatory obligations.

Legal Basis for Processing

REFLECT: Processing of your personal data by lucky-elf-canada at lucky-elf-ca.com is always grounded in recognized legal bases, ensuring compliance with CA, Curaçao, and international standards.

  • Consent: Explicit consent is obtained for marketing communications, cookies, and any use of data not strictly necessary for service provision. You may withdraw consent at any time.
  • Contractual Necessity: Data processing is required for creating, managing, and operating your account, facilitating gameplay, processing payments, and providing customer support.
  • Legal Obligations: Compliance with anti-money laundering (AML), know-your-customer (KYC), and regulatory reporting requirements under applicable laws (including Curaçao and CA standards).
  • Legitimate Interests: Processing to prevent fraud and abuse, ensure network and system security, analyze and improve services, and enforce contractual terms, provided such interests are not overridden by your privacy rights.

Regional Compliance Note: CA users are protected under applicable data protection statutes and gambling regulations. All legal bases are assessed and documented as required by law.

Purpose of Processing

OBSERVE: Data is processed only for clearly defined, lawful purposes that are necessary for the operation and improvement of lucky-elf-ca.com.

  • Provision of Casino Services: To enable account creation, gameplay, deposits, withdrawals, and to deliver requested services.
  • Improvement of Services: To analyze user behavior, optimize website performance, and develop new features based on aggregated user data.
  • Marketing and Promotions: To send newsletters, promotional offers, and personalized content (subject to your consent).
  • Analytics and Statistics: To generate insights into service usage, monitor engagement metrics, and support business decision-making.
  • Fraud Prevention and Security: To detect, investigate, and prevent unauthorized access, fraud, money laundering, and other unlawful activities.
  • Legal and Regulatory Compliance: To fulfill statutory obligations, respond to lawful requests from authorities, and maintain licensing conditions.

EXPAND: Data is never processed for purposes incompatible with those described above, and further processing is always subject to notice and, where required, consent.

Disclosure & Sharing

REFLECT: lucky-elf-canada may share personal data with third parties only as necessary for the lawful operation of lucky-elf-ca.com and always subject to strict data protection safeguards.

  • Payment Processors and Financial Institutions: For processing deposits, withdrawals, and verifying payment details.
  • Technical and Service Providers: Including IT infrastructure, cloud hosting, support, analytics, marketing, and AML/KYC verification partners.
  • Regulatory Authorities: Upon lawful request or to fulfill licensing and regulatory obligations imposed by Curaçao or other competent authorities.
  • Affiliates and Group Companies: Only as necessary for group operations, and always under appropriate data protection agreements.
  • Advertising Networks and Partners: For delivering targeted promotions, subject to your explicit consent and cookie preferences.

All third parties are contractually bound to process your data only on our instructions and in compliance with robust security and confidentiality obligations.

International Transfers

OBSERVE: As lucky-elf-canada operates globally, your data may be transferred to and processed in jurisdictions outside of Canada, including Curaçao and the European Economic Area.

  • Countries: Data may be hosted or accessed in Curaçao (primary legal seat), the EEA, or other countries where technical and operational partners are located.
  • Protection Guarantees: All international transfers are protected by appropriate legal mechanisms, such as standard contractual clauses (SCCs), binding corporate rules (BCRs), or other recognized data transfer safeguards.
  • Third-Party Providers: Only providers demonstrating adequate data protection standards are engaged, and regular risk assessments are conducted to ensure continued compliance.

Regional Compliance Note: International transfers comply with CA data protection laws and, where applicable, with the requirements of the General Data Protection Regulation (GDPR) and other relevant standards.

Data Retention

EXPAND: lucky-elf-canada retains personal data only for as long as necessary to fulfill the purposes described in this policy or as required by law. Retention periods are determined by statutory requirements, regulatory guidance, and business needs.

  • Account-Related Data: Retained for up to 5 years from the date of account closure or last user activity to comply with AML/KYC and anti-fraud regulations.
  • Transaction Data: Retained for up to 7 years for financial reporting and audit purposes, as mandated by applicable laws.
  • Marketing Data: Retained until consent is withdrawn or for a maximum of 2 years after last interaction with marketing communications.
  • Technical and Behavioral Data: Retained for up to 3 years for analytical purposes, unless otherwise required by law.
  1. Deletion Criteria: Data is deleted or anonymized upon expiry of the retention period, upon user request (where permitted), or when the data is no longer necessary for processing purposes.
  2. User Requests: Users may request early deletion of their data; requests are assessed in accordance with legal and regulatory obligations.

Regional Compliance Note: Retention practices are tailored to comply with CA and Curaçao regulatory requirements, ensuring no data is kept longer than necessary.

Your Rights

REFLECT: As a user of lucky-elf-ca.com, you have a comprehensive suite of data protection rights aligned with GDPR, CA, and international standards.

  1. Right of Access: You may request confirmation of whether your data is processed and receive a copy of your personal information in a structured, commonly used format.
  2. Right to Rectification: You may request correction of inaccurate or incomplete personal data.
  3. Right to Erasure: You may request deletion of your data ("right to be forgotten") where processing is no longer necessary, consent is withdrawn, or processing is unlawful, subject to regulatory requirements.
  4. Right to Restrict Processing: You may request suspension of processing where accuracy is contested, processing is unlawful, or pending objection assessment.
  5. Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes at any time.
  6. Right to Data Portability: You may request to receive your data in a portable format or have it transmitted directly to another controller where technically feasible.
  7. Right to Withdraw Consent: You may withdraw your consent to marketing communications or other non-essential processing at any time without affecting the lawfulness of prior processing.
  • How to Exercise Your Rights: Submit requests via email to [email protected]. Requests are processed free of charge, and a response will be provided within 30 days unless extended due to complexity.
  • Regulatory Reference: Rights are granted under applicable CA data protection law, GDPR (where relevant), and international industry standards. Mexican data protection rights are referenced for users accessing from Mexico or with relevant legal ties.

Protective Clause: Some rights may be limited by applicable gambling, financial, or anti-fraud regulations, especially regarding retention or mandatory reporting obligations.

Cookies & Tracking Technologies

OBSERVE: lucky-elf-ca.com utilizes cookies and other tracking technologies to enhance user experience, ensure site functionality, and support analytics and marketing.

  • Session Cookies: Temporary cookies necessary for secure site operation and user authentication, deleted after your session ends.
  • Persistent Cookies: Remain on your device to remember preferences, login details, and improve user experience over time.
  • Third-Party Cookies: Placed by analytics (e.g., Google Analytics), advertising partners, and affiliate tracking systems to collect aggregated usage statistics and deliver targeted content.
  1. Cookie Management: You can manage or disable cookies via your browser settings or, where available, through the site's internal privacy panel.
  2. Consent Management: Non-essential cookies are only activated based on your explicit consent and can be withdrawn at any time.

For more detailed information, please refer to our Cookie Policy or contact [email protected].

Data Security

REFLECT: lucky-elf-canada implements industry-leading security measures to protect your personal data from unauthorized access, loss, or misuse, in line with ISO 27001 and SOC 2 standards where applicable.

  • Encryption: All data transmitted over lucky-elf-ca.com is protected by TLS 1.2 or higher. Data at rest is encrypted using robust algorithms to prevent unauthorized access.
  • Access Controls: Strict authentication protocols, including multi-factor authentication for staff, and granular user privileges ensure data is accessible only to authorized personnel.
  • Security Audits: Regular internal and external security assessments, vulnerability scans, and penetration testing are conducted to identify and mitigate risks.
  • Staff Training: All personnel undergo ongoing training in data protection, information security, and incident response procedures.
  • Incident Response: In the event of a data breach, a documented incident response plan is activated, affected users are notified immediately, and all regulatory reporting obligations are fulfilled.

Security controls are continuously reviewed and updated in line with evolving threats and technological advancements.

Complaints & Contacts

OBSERVE: lucky-elf-canada is committed to resolving all privacy concerns promptly and transparently.

  1. Contact Channels:
  2. Complaint Procedure:
    1. Submit your complaint or inquiry via email or postal address, providing as much detail as possible.
    2. Our DPO or designated privacy team will acknowledge receipt within 5 business days.
    3. A comprehensive response or resolution will be provided within 30 days, unless further investigation is necessary.
    4. If you are dissatisfied with our response, you may escalate your complaint to the relevant supervisory authority.
  3. Supervisory Authorities:
    • Office of the Privacy Commissioner of Canada (OPC):
    • EU Data Protection Authorities: For users located in the EEA, refer to the relevant national DPA.
    • Mexican Data Protection Authority (INAI):

We are committed to upholding your privacy rights and facilitating fair, transparent, and timely resolution of all complaints.

Updates

EXPAND: lucky-elf-canada may update this Privacy Policy to reflect changes in legal requirements, operational practices, or technological developments. You will be notified of material updates as follows:

  • Email Notification: Notice will be sent to your registered email address at least 30 days before significant changes take effect.
  • Website Banner: Prominent notification banners will be displayed on lucky-elf-ca.com.
  • Account Dashboard Alerts: Alerts will be visible in your account area for your review.
  1. Version Control: This policy is effective as of November 6, 2025. The latest version will always be available on lucky-elf-ca.com. Material changes will be documented in a changelog section.
  2. User Options: You may object to any material changes or close your account before the changes become effective. Continued use constitutes acceptance of the revised policy.

Last updated: November 6, 2025

  • Changelog: All significant updates to policy content, legal requirements, or user rights will be summarized in this section for transparency.