PRIVACY POLICY

Lucky Days

Last updated: 02 October 2026

3-102-961212 Sociedad de Responsabilidad Limitada, operating https://luckydays.co (the "Company", "we", "us" or "our"), respects your privacy and is committed to protecting the personal information of everyone who visits or plays on https://luckydays.co (the "Website"). This Privacy Policy explains what personal information we collect, why we collect it, how we use, share and protect it, and the rights you have in relation to it. This Policy applies to all visitors to and users of https://luckydays.co.

This Policy forms part of, and should be read together with, the Lucky Days Terms and Conditions, KYC Policy and Responsible Gaming Policy. By registering an account or using the Website, you confirm that you have read this Policy and you give your express and informed consent to the collection and processing of your personal information as described in it. If you do not agree with this Policy, you should not register an account or use the Website.

1. Who We Are

Lucky Days is owned and operated by 3-102-961212 Sociedad de Responsabilidad Limitada, a limited liability company with registration number 3-102-961212 and registered address at Province 01, San Jose, Canton 02 Escazu, San Rafael, Spazio Ejecutivo Building, 4th Floor, Office Bufete Solis and Associates, Costa Rica. The Company is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros, under the Computer Gaming Licensing Act 007 of 2005 and operates under License No. ALSI-202607037-FI2.

The Company is the party responsible for the personal information collected through https://luckydays.co and for the database in which it is held. If you have any question about this Policy or about how we handle your personal information, please contact us at [email protected].

2. Information We Collect

We collect the categories of personal information described below. We collect only the information that is necessary for the purposes set out in Section 3.

2.1 Information You Provide to Us     

• Registration details: your full legal name, email address, date of birth and residential address, together with your username, password and any other details requested in the registration form, such as your telephone number, country of residence and preferred currency.
• Verification documents: a copy of your Government-Issued Photo ID, proof of residence (such as a bank statement or utility bill), a selfie of you holding your identity document and, where required, documentary evidence of your source of funds or source of wealth, as described in our KYC Policy.
• Communications: the content of the messages you send us through Customer Support, live chat or email, including any complaint you submit, and our records of that correspondence.
• Preferences and settings: your marketing preferences and any responsible gaming measures you set or request, such as limits, cooling-off periods and self-exclusion.

2.2 Information Generated Through Your Use of the Service

• Transaction information: your deposits, withdrawals, bonuses and account balance, and details of the payment methods you use, such as the type of card and its masked number, e-wallet identifier, bank account details or digital-asset wallet address.
• Gaming activity: the games you play, the bets and wagers you place, your winnings and losses and the date, time and duration of your sessions.
• Technical information: your IP address, device identifiers, browser type and version, operating system, language and time-zone settings, the approximate location derived from your IP address, login history and the pages you view on the Website, including information collected through cookies (see Section 6).

2.3 Information We Receive from Third Parties

In order to confirm your identity and meet our legal obligations, we may obtain information about you from identity verification, fraud prevention and sanctions and Politically Exposed Person screening providers, from payment service providers (for example, confirmation that a payment method belongs to you), from affiliates that referred you to the Website and from publicly available sources. Where we obtain additional personal information about you from third-party sources, we will inform you of the data obtained, unless we are prevented from doing so by law.

2.4 Sensitive Information and Payment Card Data

We do not seek to collect sensitive personal information, such as information revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, health or sexual life. Identity documents and photographs are used solely to verify your identity and age. If you choose to share information about your health or wellbeing with us in connection with responsible gaming, we will use it only to protect you and to apply the
measures you have requested.

Credit and debit card payments are processed by third-party electronic payment processors and are not processed directly by us. We do not store full payment card numbers or card security codes.

3. How We Use Your Information

We use your personal information only for the purposes described below. We do so on the basis of your consent, because it is necessary to perform our agreement with you under the Terms and Conditions, because it is required to comply with our legal and regulatory obligations, or because it is necessary for our legitimate interest in operating a safe, fair and secure Service.

• Account and Service: to open, operate and manage your account, to process your deposits, bets and withdrawals and to provide Customer Support.
• Identity, age and location verification: to confirm that you are who you say you are, that you are at least 18 years of age and that you are not a resident of, or accessing the Website from, a Restricted Country.
• Anti-money laundering and counter-terrorism financing: to carry out Customer Due Diligence and Enhanced Due Diligence, to monitor transactions, to screen against sanctions and Politically Exposed Person lists and to report to the competent authorities where we are required to do so.
• Responsible gaming: to apply limits, cooling-off periods and self-exclusion, and to identify and support players who may be at risk of gambling-related harm.
• Fraud prevention, security and integrity: to detect and prevent fraud, multiple accounts, bonus abuse, collusion, payment reversals and unauthorised access to accounts, and to protect the integrity and fairness of the Service.
• Complaints and disputes: to investigate and resolve complaints, to take part in Alternative Dispute Resolution and to establish, exercise or defend legal claims.
• Service communications: to send you account-related notifications and important information about the Service, including changes to the Terms and Conditions and to this Policy.
• Marketing: with your consent, to send you information about promotions and offers, as described in Section 5.
• Improvement of the Service: to analyse how the Website and games are used so that we can maintain and improve them.
• Regulatory compliance: to comply with the conditions of our license, including record keeping, audits and reporting to Anjouan Gaming.

We will not use your personal information for a purpose that is incompatible with those described above without informing you first and, where required, obtaining your consent.

4. Verification, Monitoring and Automated Processing

As set out in our KYC Policy, you will be required to complete the full KYC process when you request your first withdrawal, regardless of the amount, when your aggregate lifetime deposits reach USD 10,000 (or equivalent in any other currency) on https://luckydays.co, or where a transaction is deemed suspicious or elevated risk indicators are identified. While verification is pending, withdrawals will not be processed and the financial activity of your account will be restricted.

We use automated systems to monitor transactions and gaming activity, to assess risk and to detect fraud, money laundering and indicators of gambling-related harm. These systems may result in your account being restricted while a review takes place. Restrictions are reviewed by our compliance personnel under the oversight of the Company's Compliance Officer, and you may contact us to ask for a decision that affects you to be reviewed.

Where we are legally required to report suspicious activity to the competent authorities, we are prohibited from informing you that a report has been made.

5. Marketing Communications

With the consent you give when you register, we may contact you by email, and through the other contact details you have provided, with information about betting, promotional offers and other news from Lucky Days. You can withdraw your consent at any time, free of charge, by using the unsubscribe link in any marketing message or by submitting a request to Customer Support. Opting out of marketing does not affect the account-related messages we need to send you.

If you self-exclude or take a cooling-off period, no promotional material will be sent to you for the duration of that period. We do not sell or rent your personal information to third parties for their own marketing purposes.

6. Cookies

The Website uses cookies and similar technologies. Cookies are small text files placed on your device that allow the Website to recognise it. We use them for the following purposes:

• Essential cookies: to keep you logged in, to keep your session secure and to make the Website and games function. The Website cannot operate properly without them.
• Security and compliance cookies: to detect fraud and multiple accounts and to help enforce the Restricted Countries list.
• Preference cookies: to remember your settings, such as language and currency.
• Analytics and affiliate cookies: to understand how the Website is used and to record which affiliate, if any, referred you to us.

You can control or delete cookies through your browser settings. If you disable essential cookies, parts of the Website, including login and gameplay, may not work.

7. Who We Share Your Information With

We share your personal information only where it is necessary and only with the
following categories of recipients:

• Service providers acting on our behalf: platform and software providers, game providers, hosting providers, identity verification and screening providers, payment service providers and processors, fraud prevention services, customer support and communication tools, and our professional advisers and auditors. These providers may use your information only to provide their services to us and are bound by obligations of confidentiality and security.
• Regulators and authorities: Anjouan Licensing Services Inc. (Anjouan Gaming), the Anjouan Offshore Financial Authority, financial intelligence units, law enforcement agencies, courts and other competent authorities, where we are required to do so by law or by the conditions of our license. This includes suspicious activity reports and reports of transactions that meet the regulatory reporting thresholds.
• Anjouan Gaming self-exclusion network: self-exclusion requests submitted through the "Self Exclusion" button in the Anjouan Gaming seal are processed confidentially. The information shared is used only to enforce the exclusion within the Anjouan Gaming network and is not disclosed unless required by law or for official investigations.
• Dispute resolution bodies: the Alternative Dispute Resolution providers designated or approved by Anjouan Gaming, where a complaint is escalated to them.
• Successors to the business: a third party to which the Company transfers its rights and obligations in accordance with the Terms and Conditions, for example in the event of a merger, sale or reorganisation. Your information will remain subject to this Policy.

The Company operates more than one gaming website under its license. Because the
same company is responsible for each of them, we may use your information across those websites where this is necessary to comply with our legal obligations, to prevent fraud, duplicate accounts and bonus abuse, and to protect players.

8. International Transfers

The Company is established in Costa Rica and licensed in Anjouan, and our service providers may be located in other countries. Your personal information may therefore be transferred to, stored and processed in countries other than your country of residence, where data protection laws may differ from those that apply to you. Where we transfer your personal information, we require the recipient to protect it through contractual obligations of confidentiality and security consistent with this Policy. By accepting this Policy, you expressly consent to these transfers.

9. How Long We Keep Your Information

We keep your personal information for as long as your account is open and, after it is closed, for as long as is necessary to comply with our legal and regulatory obligations, to resolve disputes and to enforce our agreements.

In accordance with the Anjouan Gaming AML & CTF Code of Conduct, we retain all AML-related records for a minimum of five (5) years from the end of the business relationship. This includes CDD and EDD documentation, transaction records (deposits, wagers and withdrawals), suspicious activity reports and internal reports, and audit and compliance records. Self-exclusion and other responsible gaming records are kept for at least the duration of the measure concerned.

We do not keep personal information for longer than ten (10) years after the end of the business relationship, unless a longer period is required by law or is necessary in connection with legal proceedings. When personal information is no longer required, it is securely deleted or anonymised.

10. How We Protect Your Information

We protect the integrity and confidentiality of your personal information through
appropriate technical and organisational safeguards, including:

• Secure Socket Layer (SSL) encryption of all data transmitted between your device and the Website;
• Encrypted storage of sensitive personal and financial information;
• Firewalls, intrusion detection systems and anti-malware software;
• Access to personal information restricted to authorised personnel who need it to perform their duties and who are bound by confidentiality obligations; and
• Regular testing of our systems for vulnerabilities.

You are responsible for keeping your password confidential and for the security of your Registered Email Address. We recommend that you use a strong, unique password, change it regularly and enable any additional account security features made available on the Website. If you believe that your account or password has been compromised, you must notify us immediately.

If a security incident affecting your personal information occurs, we will inform you without undue delay, and in any event within five (5) business days of becoming aware of it, of the nature of the incident, the personal information affected and the measures taken. We also report cybersecurity incidents to Anjouan Gaming within 24 hours.

11. Your Rights

You have the following rights in relation to your personal information:

• Access: to obtain confirmation of whether we hold personal information about you and to receive a copy of it.
• Rectification: to have inaccurate or incomplete personal information corrected. You can update most of your details in your account or by contacting Customer Support.
• Deletion: to have your personal information deleted where it is no longer needed for the purpose for which it was collected.
• Objection: to object to the processing of your personal information, including for marketing purposes.
• Withdrawal of consent: to withdraw your consent at any time. Withdrawal does not affect processing carried out before it, and we may no longer be able to provide the Service to you.

To exercise any of these rights, please email [email protected] from your Registered Email Address. We may ask you to verify your identity before acting on your request. Requests are free of charge and we will respond within five (5) business days of receiving a valid request.

These rights are subject to our legal obligations. In particular, we cannot delete or stop processing personal information that we are required to retain under anti-money laundering rules, the conditions of our license or an active self-exclusion, or that we need in connection with a complaint, dispute or legal claim.

If you are not satisfied with our response, you may lodge a complaint with the Costa Rican data protection authority, the Agencia de Protección de Datos de los Habitantes (PRODHAB). If you are located in the European Economic Area and the General Data Protection Regulation applies to our processing of your personal information, you also have the right to request the restriction of processing and the portability of your personal information, and to lodge a complaint with the data protection authority of your country of residence.

12. Minors

The Service is intended only for persons who are at least 18 years of age, or the legal age for gambling in their jurisdiction if higher. We do not knowingly collect personal information from anyone under that age. If we become aware that a person under the legal age has registered on https://luckydays.co, the account will be closed in accordance with the Terms and Conditions and the personal information will be retained only to the extent required by law.

13. Links to Other Websites

The Website may contain links to third-party websites that are not operated or controlled by us. This Policy does not apply to those websites, and we recommend that you review their privacy policies before providing any personal information to them.

14. Changes to This Policy

We may amend this Policy from time to time to reflect changes in the law, in our licensing obligations or in the way we operate the Service. The amended Policy will be published on the Website with a new "Last updated" date. Where a change is material, we will notify you by email to your Registered Email Address or by a notice on the Website before the change takes effect. Your continued use of the Website after publication indicates your acceptance of the amended Policy.

15. Contact and Complaints

Questions, requests and complaints about this Policy or about the way we handle your personal information should be sent to [email protected]. Complaints are acknowledged within 72 hours and we make every effort to resolve them within 30
calendar days of receipt. If a complaint is not resolved within that period, you will be informed of the Alternative Dispute Resolution options available to you, at no cost to you.

16. Regulatory Basis

This Privacy Policy is maintained in compliance with the obligations imposed on the Company as a licensed gaming operator under the Computer Gaming Licensing Act 007 of 2005 administered by the Anjouan Offshore Financial Authority, the Code of Conduct for Anjouan Internet Gaming Operators, the Anjouan Gaming AML & CTF Code of Conduct and the website compliance requirements issued by Anjouan Licensing Services Inc., and with Costa Rican Law No. 8968 on the Protection of Individuals with regard to the Processing of their Personal Data and its Regulation (Executive Decree No. 37554-JP), which apply to the Company as a Costa Rican entity. Where these requirements differ, the Company applies the stricter standard.