GreenLuck Privacy and Data Notice

Information Provided When Using GreenLuck

The information collected depends on how a person interacts with the platform. Some details are provided directly during registration, verification, payment activity or communication with GreenLuck.

Account Information

When an account is created, GreenLuck may request information needed to establish and maintain the player profile.

• Full name
• Date of birth
• Country of residence
• Phone number
• Gender where required
• Postal or ZIP code
• Username
• Social security or similar identification number where applicable
• IP address and general location information

Identity and Verification Records

Additional information may be requested as part of Know Your Customer, age verification, Anti-Money Laundering or licensing requirements.

• Passport details
• Identity card information
• Driving licence information
• Proof of address
• Source of funds
• Source of wealth information
• Bank identification information
• Financial statements where required

Payment Information

Certain financial details may be processed when deposits or withdrawals are made. This can include Bank ID information, IBAN, CPR or CPF numbers and information associated with the selected payment system.

Financial information may also be used where verification is necessary for KYC, AML or other regulatory purposes.

Information Collected Automatically

Some technical information is generated automatically when the GreenLuck website or related services are used.

Device Data

GreenLuck may receive information about the device and software used to access the platform, including IP address, operating system version and device identifiers.

Website Activity

Technical logs can contain information about how the website is used. This may include session dates and times, pages viewed, searches, interactions with website content, links followed and the amount of time spent during a session.

Some of this information may be collected through cookies and similar technologies.

General Location

GreenLuck may determine or estimate a general location from technical information when the service is accessed.

Information Obtained From Other Sources

GreenLuck may obtain information from external sources where this is necessary to provide services, verify account information, manage risk or meet legal requirements.

• Government and public databases
• Publicly accessible online sources
• Financial and credit institutions
• Fraud prevention services
• Public authorities
• Commercial databases
• Public social media information
• Linked third-party accounts where used

GreenLuck may also derive information from account activity. For example, game preferences or areas of interest may be inferred from pages viewed and games played.

How Personal Information Is Used

Personal information is processed only where there is a defined operational, legal, security or service-related purpose.

• Providing and maintaining GreenLuck services
• Creating and managing player accounts
• Responding to requests and support questions
• Improving website features and services
• Testing and troubleshooting technical systems
• Detecting fraud and suspicious activity
• Managing operational and financial risk
• Handling disputes and regulatory enquiries
• Meeting legal and licensing obligations
• Maintaining website and network security

Where permitted and where the required consent has been provided, information may also be used to manage promotions, rewards, competitions and personalised communications.

Legal Grounds for Processing

GreenLuck processes personal information only where an appropriate legal basis applies under GDPR or other relevant data protection requirements.

Providing a Contracted Service

Some information is needed to establish or perform the relationship between GreenLuck and the player. This includes creating an account, providing account functions and carrying out obligations described in the applicable Terms and Conditions.

Meeting Legal Requirements

Personal information may be processed where GreenLuck is required to comply with legal, regulatory or licensing obligations.

• Age and identity verification
• KYC and AML checks
• Determining applicable jurisdiction requirements
• Problem gambling risk management
• Responsible Gambling controls
• Network and information security
• Fraud prevention
• Money laundering and terrorist financing prevention
• Compliance with court orders and lawful requests
• Regulatory and financial reporting

Legitimate Interests

Information can also be processed where GreenLuck, a third party or another legitimate commercial interest requires it, provided that the individual’s rights and freedoms do not override that interest.

This may include protecting systems and assets, preventing misuse, managing legal claims, improving services, carrying out analytics and detecting activity that may affect the integrity of the platform.

Account and gaming behaviour may also be analysed to identify unusual patterns, support Responsible Gambling measures, improve services and provide relevant platform features.

Consent

Certain processing activities are carried out only where valid consent has been provided. Depending on the service, this can include personalised promotions, SMS or phone communications, website or application notifications, targeted advertising and participation in loyalty schemes, tournaments or promotional events.

Consent can be withdrawn where the processing depends on consent. Withdrawal does not affect processing that was lawful before consent was withdrawn.

When Information May Be Shared

Personal information is not limited to use within GreenLuck when an external party is necessary to operate the service, process payments, comply with regulations or protect the platform.

Information may be shared with:

• Authorized GreenLuck employees
• Affiliates and subsidiaries
• Joint controllers
• Contractors and agents
• Payment providers
• Financial institutions
• Technology and hosting providers
• Customer support providers
• Communication service providers
• Game providers
• Fraud prevention agencies
• Analytics and data service providers
• Marketing partners where legally permitted
• Regulators and licensing authorities
• Law enforcement agencies where required

Payment providers may receive information necessary to process a transaction or satisfy their own legal and AML requirements. Where required, relevant KYC documentation may also be shared with them.

External Complaints and Disputes

If a player submits a complaint, review or dispute relating to GreenLuck through an independent website, gambling forum or dispute resolution service, GreenLuck may respond to that platform when necessary to investigate or resolve the matter.

Any personal information disclosed in these circumstances should be limited to information reasonably required to identify the relevant account and provide factual context. Such disclosure is not intended to take place unless the player, or someone acting on the player’s behalf, has first raised the matter externally.

How Long Information Is Retained

Personal information is generally retained while the GreenLuck account remains active and for as long as it is necessary to fulfil the purposes described in this notice.

Some records may need to be retained after an account has been closed when AML rules, financial regulations, licensing requirements or other legal obligations require a longer retention period.

When there is no longer a legal or legitimate business reason to retain information, it may be deleted or anonymised so that it can no longer be associated with an identifiable person.

Your Personal Data Rights

Depending on the applicable data protection law and individual circumstances, players may have a number of rights concerning information held by GreenLuck.

• Request access to personal information
• Ask for inaccurate information to be corrected
• Request deletion where legally permitted
• Request restriction of certain processing
• Request data portability in a commonly used format
• Object to processing based on legitimate interests
• Object to direct marketing
• Withdraw previously given consent
• Submit a complaint to an appropriate supervisory authority

Privacy-related requests can be submitted to GreenLuck Customer Support or the Data Protection Officer through the contact options made available by the platform.

Cookies and Similar Technologies

GreenLuck may use cookies, pixels, tags, web beacons and similar technologies to operate the website, understand how it is used and support selected platform functionality.

Consent is requested for non-essential cookies where required. Cookies that are strictly necessary for basic website operation can be used without consent where permitted by applicable law.

Cookie preferences and additional information about specific technologies can be managed through the relevant cookie settings and Cookie Notice.

Protecting Personal Information

GreenLuck applies administrative, technical and physical safeguards intended to reduce the risk of unauthorized access, misuse, loss, alteration or disclosure of personal information.

Security measures are regularly reviewed and may be updated as technologies and risks change. However, no online system or method of storing or transmitting information can provide an absolute guarantee against every possible security incident.

International Data Transfers

Personal information may be processed in countries located outside the European Union or European Economic Area.

Where such transfers take place, appropriate safeguards are used where required. These may include transfers to countries recognised by the European Commission as providing adequate protection, approved Standard Contractual Clauses or other legally recognised mechanisms.

Changes in Business Ownership

Personal information may form part of a business transaction involving a merger, acquisition, financing, restructuring, sale or other change in control of GreenLuck or its assets.

A new owner or controlling entity may continue to process personal information under the terms of this Privacy Notice unless another form of processing is separately authorised or legally permitted.

Privacy Questions

Questions about this notice, the use of personal information or available privacy rights can be directed to GreenLuck Customer Support or the Data Protection Officer through the contact channels provided on the platform.

Changes to This Privacy Notice

This notice may be revised when GreenLuck services, technology, legal obligations or data protection requirements change.

The version published on the website applies from its stated effective date. Players and website visitors should review the current notice periodically to remain informed about how personal information is handled.