Privacy Policy

Introduction

This privacy notice (hereinafter, "Privacy Policy") has been drawn up by LUCKIA GAMES, S.A. (hereinafter “LUCKIA” or the "Data Controller") in order to comply with the duty of transparency in the processing of personal data that it may carry out as Data Controller, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (hereinafter, "GDPR").

The information contained in this Privacy Notice allows you to check the details of the different personal data processing of that may be carried out as a result of your access and use of the Website (https://www.luckia-affiliates.com/) (hereinafter, the “Website”) as well as those relating to different legal or commercial relationships that the interested parties may have with LUCKIA.

We inform you that mere access to the Website does not imply the obligation to provide any personal information or acceptance of the processing of your personal data, except as provided in the Cookies Policy.

However, the use of some services or functionalities of the Website or the application and/or subscription to the affiliate programme (hereinafter, the “Affiliate Programme”) does require you to provide certain personal data, indicated in the corresponding forms or Terms and Conditions, and implies their processing for the purposes and on the bases of the legitimisation indicated in this Privacy Notice.

Refusal to provide the data required in these cases may make it impossible to provide you with certain services or functionalities, or to process the requests or contracts made, especially in those cases where they are identified as essential.

As the owner of the personal data, you will be responsible for ensuring that the data you provide through the Website is true, accurate, complete, and updated. For these purposes, you will be responsible for the veracity of all the data you provide, and you must keep the information provided duly updated, in such a way that it reflects your real situation.

Likewise, you shall be liable for any false or inaccurate information provided and for any direct or indirect damages that this may cause to the Data Controller or to third parties.

Under no circumstance may personal data corresponding to third parties be included in the form, unless the applicant has previously obtained their consent, and is personally liable for non-compliance with this obligation. You may be asked to provide documentation justifying this authorisation at any time.

1. Data Controller
   • Title Holder: LUCKIA GAMES, S.A.
   • Registered office: C/ Real, 3, Entreplanta, Oficinas A, 51001, Ceuta, Spain.
   • TAX IDENFICATION NUMBER: A-70301817.
   • Telephone: 981173700.
   • E-mail: [email protected]

Likewise, the following provides details of the processing of personal data that may be carried out at LUCKIA.

In any event, you may request further information on the processing carried out by writing to the LUCKIA Data Protection Officer at [email protected] , who is responsible for ensuring fairness and transparency in the processing of your personal data.

How do we handle your personal data?

The personal data provided will be processed by LUCKIA for the following purposes, depending on the type of data and the relationship established with LUCKIA through the Website. Furthermore, the types of data, their origin, the third parties to whom said personal data may be communicated, as well as the legal basis that LUCKIA has for carrying out the processing are set out below.

1. Customer Service

   Description of processing: If you provide personal data through the e-mails and/or contact telephone numbers that LUCKIA has set up on the Website, your data will be processed for the purpose of managing your requests for information, resolving doubts, answering queries, or processing your claims.

   Data processed for this purpose: The data collected from the use of Customer Service ([email protected]) may include the following data:

   1. Identification data: name, surname, as well as any other data that identifies you that you consider necessary to convey to us.
   2. Contact details: e-mail address, telephone number, or any other means of contact that you decide to provide to us.
   3. Other data (if applicable): any information that the user of the service provides for the processing of their petition.

   Origin of the data: Transmitted directly by the User through the contact channels provided by LUCKIA.

   Legitimate basis: Legitimate interest in allowing communication between LUCKIA and the user, making it possible to provide due attention to any user who contacts LUCKIA for the purposes described above. Therefore, the processing is necessary to enable the appropriate handling of requests for information, resolution of doubts, answering queries or processing of communicated claims and to verify the operation of the service in accordance with the established procedures, as well as to obtain evidence of the content of the requests received and the reason for the processing of the personal data that may be provided.

2. Affiliate Programme Registration.

   Processing definition: Processing operations prior to acquiring the condition of Affiliate and related to the registration process in LUCKIA's affiliation platform.

   Data processed for this purpose:

   • Identification data: name, surname, ID card number, and access credentials (username and password) ...
   • Contact details: postal address, email address, telephone number, blog, website, social media account, etc.
   • Financial data: bank account (including bank name, SWIFT code and any other necessary bank codes, bank number, branch, control digit and Affiliate account number, IBAN), etc.
   • Commercial activity: impressions, clicks, sales, commissions, and statistics generated on information generated, links generated, campaigns.

   Data Origin: Provided by the interested party on the registration form.

   Legitimising basis: The legitimisation of the described processing is the need for the execution of the contractual relationship that will be established, where appropriate, with the Affiliate.

3. Affiliate Programme Management
   • Processing definition. In the event that you join and are accepted by LUCKIA in the Affiliate Programme, your personal data will be processed for the purpose of formalising, managing, maintaining, developing, supervising, and controlling the relationship established between the affiliated data subject and LUCKIA in accordance with the accepted Terms and Conditions. Contact data may also be used for transactional communications related to the service.
   • Data processed for this purpose. Identification and contact data, access credentials, economic and financial data, as well as transactions of goods and services in the context of the contractual relationship with LUCKIA.
   • Data recipients. Tax authorities (e.g., AEAT), Judges and Courts (where necessary) and in the event that you decide to become an Affiliate in other markets (Colombia, Portugal...) to LUCKIA brand companies operating in those markets.
   • Legitimising basis. The need for the execution of the contractual relationship entered into between LUCKIA and the Affiliate.
4. Preventing fraudulent activities.
   • Processing definition. Certain identification data, as well as transactions in the context of the contractual relationship with LUCKIA, will be used to detect, control, prevent and/or report fraudulent and/or criminal conduct.
   • Data processed for this purpose. Identification data and data relating to transactions in the context of the contractual activity with LUCKIA.
   • Data origin. Transmitted directly by the User and obtained from other economic operators.
   • Data Recipients. They may be shared in common fraud prevention files and used by other economic operators in the context of their fraud prevention activities.
   • Legitimate basis. ner LUCKIA's legitimate interest in ensuring the proper use of the services made available to the Affiliate, reducing the risk of being affected by fraudulent transactions. Further information on the prevalence of this legitimate interest can be obtained by contacting [email protected]
5. Sending Commercial communications relating to LUCKIA's products and/or services.
   • Processing definition. The personal data of users who have given their consent during the registration process in the Affiliate Program may be processed for the purpose of sending, where appropriate, commercial communications and promotions related to LUCKIA’s products and services and, where appropriate, other entities within the "Luckia Group". The channels through which these communications may be sent will be postal, telephone and electronic (e-mail, SMS, or equivalent electronic messaging media).
   • Data processed for this purpose. Identification and contact data.
   • Legitimate basis. The consent granted in the registration process, with the right to withdraw at any time by sending an e-mail to [email protected]. Finally, we hereby point out that the withdrawal of consent will not affect the lawfulness of the processing based on the consent prior to its withdrawal.

    

   Furthermore, to accomplish the purposes of the processing described above, we are required to provide access to your personal data to entities of the Luckia Group and to third parties that support us in the services we offer you (financial institutions, technology service providers, to customer services...). For efficiency of service, some of the above-mentioned providers are located in territories outside the European Economic Area which do not provide a level of data protection equivalent to that of the European Union. In such cases, we inform you that we transfer your data with adequate safeguards and always maintaining the security of your data, as we use the most appropriate tools for international data transfer, such as Standard Contractual Clauses or any other relevant complementary measures.

   On the other hand, if you choose to become an Affiliate in different markets, we may need to disclose or transfer information relating to your account or activity to brand companies operating in those markets in so far as they may be directly involved in achieving the objectives described in Section 3 above. We consider this necessary to satisfy our mutual interests and preferences.

   Conservation period

   Personal data will be kept for the duration of the contractual relationship established between LUCKIA and you and, subsequently, provided that you have not exercised your right to deletion, they will be kept for the legal periods that apply in each specific case, taking into account the type of data, as well as the purpose of the processing. By way of reference, personal data relating to the Affiliate relationship will be kept for 10 years from the termination of the legal relationship, as provided for in current legislation on the prevention of money laundering. You can request more information on the data retention periods applied at LUCKIA at [email protected].

   What measures do we adopt to protect your personal data?

   In response to LUCKIA's concern to guarantee the security and confidentiality of your data, we have adopted the required security levels have been adopted for the protection of personal data and we have installed the technical means available to prevent the loss, misuse, alteration, unauthorised access, and theft of personal data provided through this website. Nevertheless, you should bear in mind that security measures on the Internet are not impregnable.

   What are your rights regarding your personal data?

   What are your rights regarding your personal data?

   • Access to your personal data. You have the right to access your personal data to find out what data we are processing concerning you.
   • Request rectification or deletion of your personal data. In certain circumstances, you have the right to rectify any personal data that you consider inaccurate, and which concerns you, and which are processed by LUCKIA, as well as the right to request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
   • Request the restriction of the processing of your data. In certain circumstances, you have the right to request us to restrict the processing of your data, in which case we inform you that we will only retain the data in respect of you have requested to restrict the processing for the purpose of pursing or defending claims.
   • The portability of your data. In certain circumstances, you will have the right to receive the personal data that concerns you, and that you have provided to us, in a structured format for common use and machine-reading, as well as to have it transmitted by LUCKIA to another data controller.
   • Object to the processing of your data. In certain circumstances and for reasons relating to your particular situation, you will have the right to object to the processing of your data, in which case we will stop processing it unless we must continue to do so for compelling legitimate reasons or for the exercise or defence of any possible claims.

   We also remind you that you may withdraw any consent you may have given for the processing of your data, without this affecting the lawfulness of the processing based on the consent prior to its withdrawal. Furthermore, in those data processing operations that involve automated decision-making, it will be possible to request human intervention in the decision-making process or to challenge the results. LUCKIA informs you that you may exercise these rights over your personal data by any of the following channels:

   • By letter addressed to LUCKIA at the postal address Calle Real, 3, Entreplanta, Oficinas A, 51001, Ceuta, Spain, including the reference "Data Protection".
   • By writing to LUCKIA at the email address [email protected] including the subject "Data Protection".

In both cases, the identity of the person exercising their rights or, where appropriate, of the representative, must be accredited by sending (i) a copy of their National ID Card, Foreign Identification Card, Passport, or equivalent document, on both sides, and (ii) a letter providing the following data related to their Affiliate account: Name and Surname, Username, e-mail, and telephone number. LUCKIA will provide the information associated with the right exercised within a maximum period of one month from receipt of the request. This period may be extended for a further two months, if necessary, considering the complexity and number of requests. LUCKIA also informs you that you may lodge a complaint with the competent supervisory authority (in Spain, this is the Spanish Data Protection Agency). However, in the first instance, you may file a complaint with the Data Protection Delegate, who will resolve the complaint within a maximum period of two months.

 

Security measures

Personal data will be treated in the strictest confidence and maintaining the perceptive duty of secrecy with respect to them, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical and organisational measures to guarantee the security of your data and prevent their alteration, loss, unauthorised processing or access, taking into account the state of technology, the nature of the stored data and the risks to which they are exposed.

 

Updating of the Privacy Policy

The Data Controller reserves the right to modify this Privacy Policy in order to adapt it to its needs or to any legislative developments that may be applicable. In such cases, the changes introduced will be made known and published on this Website, so that you can access them easily at all times.

 

Last update: 02/09/2023

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