This is the privacy statement (the “Policy”) for the 21LuckyBet website (the “Website”), which is run by Progressplay Limited (the “Company”), of Soho Office, 3A, Punchbowl Centre, Elia Zammit Street, St. Julians, STJ3154, Malta.

The Company is dedicated to protecting both your privacy and your personal data. In keeping with this pledge, we shall respect the following values:

• To be open and honest about how your personal data is gathered and processed:

It is vital to Us that you always have access to the information needed to make informed decisions about the processing of your personal data. We will employ a variety of strategies and tactics to achieve this goal, all with the intention of giving you pertinent information about how and when your personal data is being processed.

Our comprehensive privacy policy aims to give you the most comprehensive knowledge possible about the kinds of Personal Data that We gather and how We handle it. As a result, it is vital that you review it whenever you can and on occasion.

Furthermore, in cases where We determine that You must receive particular information, We shall give it to you at the proper time and location.

Subject to legal restrictions, we will also be pleased to address any queries you may have and offer you any clarification you need. You can contact our data protection officer for this purpose using the information below:

Officer for Data Protection at Progressplay Limited

Email address: progressplay.com/dataprotection

• To process your personal information only in order to fulfill the objectives specified in the policy:

The provision of Our products and services to you at your request, improving the user experience with Our products and services, protecting Our rights and interests, carrying out business and administrative tasks that support the provision of Our products and services to Our customers, and/or adhering to any legal or regulatory requirements are just a few of the reasons We may process Personal Data about you. Section 7 of the Policy contains a complete list of the reasons We utilize Personal Data concerning natural persons.

Furthermore, We will handle your personal data so that We may better understand your interests and needs and make offers that are specifically catered to you. You have the option to discontinue receiving offers that are specifically tailored to you at any time, and We will comply with your request.

• To commit substantial resources to upholding your rights regarding your personal data:

We use a lot of resources to give you the opportunity to exercise your rights as a data subject. As a result, you can contact Us whenever you’d like to see what Personal Data we have on you, request that we update it, delete it, stop using it generally or for certain purposes, or request that We transfer it to you or a third party. We’ll comply with your requests as required by law.

• To protect your personal information:

Although we are unable to guarantee complete safety of the personal information about you, we can assure you that we have used and will continue to employ a variety of techniques and safeguards to make sure your information is protected.

Our Complete Privacy Policy Guide

What Is Covered by This Privacy Policy?

This Policy explains the types of Personal Data the Company gathers about individuals, as well as how it is collected, used, shared with other parties, secured, processed, and other related activities.

Any information pertaining to an identified or identifiable natural person is referred to as “Personal Data” in this Policy; an identifiable natural person is one who can be identified, either directly or via the use of other information that We have or that We have access to.

Any operation or sequence of operations carried out on Personal Data, such as its collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction, is referred to as “processing” of Personal Data in this policy.

Which Personal Information About You Do We Gather?

Upon registration, we obtain the following personal information from you: email address, first and last name, gender, date of birth, physical address, city and country of residence, zip code, phone number, mobile phone number, account currency, account language, and publicly available information from social media and the internet.

Every time you log in to your account, we gather the following personal information: IP address, device information, operating system information, browser information, screen resolution, flash version, URLs visited both previously and currently, date and time of login, and location data.  

When you use Our products and services, We gather the following personal information about you: deposits, bets, bonuses, game sessions (including date, time, and duration), wins, and losses.

Utility bills, passports, IDs, driving license numbers, and photos are examples of the personal data we obtain with your help.

We obtain personal information from you when you deposit money or request a withdrawal: bank account information, e-wallet information, credit card information and picture, information on the source of funding, phone bill, bank statement.

Personal information that we obtain from you: any information that you voluntarily give us about yourself when contacting us through chat, social media, customer service, or any other channel, including with requests, complaints, or comments. Your calls may be recorded and/or written down by our customer care agents.

Giving Personal Information To Outside Parties

In order to support its operations and the provision of its goods and services, the Company exchanges Personal Data with businesses that are a part of its group of businesses.

Additionally, the following third parties that offer Us their services may get Personal Data about you from the Company:

• Payment services, including banks, payment processors, and service providers;
• Services related to issues of responsible gaming; for example, when We want to make sure that a person’s amount of wagering is appropriate for his financial situation;
• Providers of cloud computing services as well as storage and hosting options.

In addition, the Company may disclose Personal Data about you to regulatory, licensing, governmental, local, official, regulatory, and gaming authorities where necessary to safeguard the rights, interests, and property of Our and third parties, including in the event that legal action is taken, taken, or defended.

Also, in the event of any similar transaction (such as the sale of the Company’s or any company’s assets), We may disclose Personal Data about you to prospective buyers, investors, or lenders of the Company and/or any company within the group of companies of which the Company is a part. Additionally, We may do so in connection with any merger, reorganization, consolidation, or bankruptcy of the Company and/or any company within the group of companies of which the Company is a part.

Your Rights Regarding Your Personal Information

Regarding the Personal Data concerning you, you have the following rights. The process for exercising these rights is to send an email to [email protected] with a request to exercise your rights.

Access right

You have the right to receive from the Company confirmation as to whether or not Personal Data about you is being processed, and, where that is the case, access to the Personal Data and the following information: (1) the purposes of the processing; (2) the categories of Personal Data concerned; (3) the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries outside the European Economic Area (EEA) or international organisations; (4) where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period; (5) the existence of the right to request from the Company rectification or erasure of Personal Data or restriction of processing of Personal Data about you or to object to such processing; (6) the right to lodge a complaint with a supervisory authority; (7) where the Personal Data is not collected from you, any available information as to its source; (8) the existence of profiling; and (9) where personal data is transferred to a third country outside the EEA or to an international organisation, the appropriate safeguards relating to the transfer.

If you request additional copies of the Personal Data, the Company will provide one copy and may charge a reasonable fee. If you request the copies electronically, the information will be provided in a commonly used electronic format unless you specify otherwise.

The right to acquire a copy of the Personal Data may not be used in a way that would negatively impact the rights and freedoms of others. Accordingly, the Company may refuse to comply with your request or may only comply in part with it.

Rectification Right

You are entitled to have any erroneous Personal Data about you corrected by the Company. You have the right to have incomplete Personal Data completed, including by submitting an additional statement, while keeping in mind the purposes of the processing.

Erasure right

When one of the following circumstances applies, you have the right to request that the Company erase any Personal Data about you: (a) the Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; (b) you withdraw your consent, if there is no other legal basis for the processing; (c) you may object at any time, for reasons specific to your situation, to the processing of Personal Data about you that is based on the legitimate interests that We or a third party is pursuing and there are no other legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been processed unlawfully; and (f) the Personal Data has been removed from the Company

This right does not apply to the extent that the processing is required in order for the Company to: (a) comply with a legal obligation that is mandated by European Union or Member State legislation, or (b) establish, exercise, or defend legal claims.

Processing restriction right

You have the right to obtain from the Company restriction of processing of Personal Data about you where one of the following applies: (a) the accuracy of the Personal Data is contested by you, for a period enabling the Company to verify the accuracy of the Personal Data about you; (b) the processing is unlawful and you oppose the erasure of the Personal Data about you and request the restriction of its use instead; (c) the Company no longer needs the Personal Data about you for the purposes of the processing, but it is required by you for the establishment, exercise or defense of legal claims; (d) where the processing of Personal Data about you is necessary for the purpose of the legitimate interests pursued by the Company or by a third party, unless We demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims; (e) where Personal Data about you is processed for direct marketing purposes, including profiling the extent that it is related to such direct marketing.

If you have requested that the processing of your personal data be restricted, then, aside from storage, such personal data may only be processed with your consent, for the purpose of establishing, exercising, or defending legal claims, for the protection of the rights of another natural or legal person, or for reasons of significant public interest to the European Union or a Member State.

Right to freedom in moving data around

In the event that (a) the processing is done with your consent or in accordance with a contract you are a party to, or (b) the processing is done automatically, you have the right to receive the Personal Data about you that you have given the Company in a structured, widely used, and machine-readable format. You also have the right to transfer such Personal Data to another controller.

When it is technically possible, you have the right to request that the Company transfer your Personal Data directly to another controller in order to exercise your right to data portability. The Company’s and your rights under your right to erasure are unaffected by the exercise of your right to data portability. Furthermore, the freedom and rights of others cannot be negatively impacted by the right to data portability.

Right to object

You have the right to object at any time to processing of your personal data that is based on the Company’s or a third party’s legitimate interests, including profiling based on such interests, on the basis of reasons specific to your circumstances. Unless we can provide strong, justifiable reasons that outweigh your rights, freedoms, and interests—or that the processing is necessary for the pursuit, establishment, or defense of legal claims—we will no longer process the personal data we have on you.

Anytime that Personal Data about you is used for direct marketing purposes, including profiling to the extent that it is relevant to such direct marketing, you have the right to object.

Right to revoke consent

You have the right at any time to revoke the consent you gave Us to process your personal data, but doing so will not impact the legality of any processing done using that consent up to that point.

Protection of Your Personal Information

We put in place the necessary organizational and technical safeguards to guarantee a suitable level of security for your personal information, keeping in mind the risks associated with processing it. These risks include those related to accidental or illegal destruction, loss, alteration, unauthorised disclosure, or access to personal information that is transferred, stored, or processed in any other way.

We might have to give Personal Data about you to third parties, like public agencies, because of legal requirements or other duties that are beyond our control. Under these situations, We have little control over how well these third parties are protecting your personal information.

It is impossible to completely protect any internet-based Personal Data transfer. As a result, the Company cannot guarantee that your Personal Data will be protected when it is sent over the internet to the Company’s website.