Privacy Policy

This privacy policy explains how and why we collect and process personal information from users of lucky-7-even.com, including players and website visitors. It applies to all individuals engaging with our casino and associated services, effective as of 1 January 2025.

Who We Are

OBSERVE: Compilation of operator identity, legal address, and contact data.

Legal Entity: The services of lucky-7-even.com are operated by Hollycorn N.V., a company registered under the laws of Curaçao with company registration number 144359. The parent company, Hollycorn N.V., was founded in 2023.
Registered Address: Scharlooweg 39, Willemstad, Curaçao.
Website: https://lucky-7-even.com
Data Protection Contact: Direct all data protection inquiries to Chloe Miller (designated Data Protection Officer). Contact information is provided via our website 'Contact Us' form.

REFLECT: All users engaging with lucky-7-even.com should address privacy-related matters exclusively through official channels referenced above. Where statutory requirements under AU law direct, we ensure ongoing compliance with local and international standards.

What Personal Data We Collect

OBSERVE: Mandatory identification of data collection categories as per AU and Curaçao iGaming regulatory standards.

Personal Identification Data: Full name, date of birth, e-mail address, phone number, physical address (where required), and identity documentation for compliance.
Technical Data: IP addresses, device identifiers, browser type and version, operating system, access logs, connection times, and website usage patterns.
Payment Data: Payment card/bank details (in tokenized or masked form where possible), transaction records, account balances, deposit and withdrawal information, and currency preferences.
Behavioral and Gaming Data: Betting history, game choices, session durations, win/loss records, clickstream data, and engagement patterns.
Cookies and Tracking Technology: Session and persistent cookies, third-party cookies, beacons, pixels, device fingerprinting technologies, used for analytics, authentication, and marketing purposes.

REFLECT: Data is collected strictly for lawful, explicit, and stated purposes, aligned with user expectations and AU legal requirements, including those for online gambling operations.

Legal Basis for Processing

OBSERVE: Alignment with AU Privacy Act 1988, APPs, and Curaçao KYC/AML regulations. System 2 reasoning for full clarity.

User Consent: Where your consent is required by law (e.g., marketing communications, cookies), we seek explicit agreement, and you retain the right to withdraw at any time.
Contractual Necessity: Processing personal data necessary for establishing, performing, and administrating your gaming account and facilitating transactions on lucky-7-even.com.
Legal Obligation: Collection and processing are mandated for compliance with obligations under AU anti-money laundering (AML), Know Your Customer (KYC), tax, and lawful reporting requirements.
Legitimate Interests: For preventing fraud, ensuring gaming integrity, conducting security audits, service optimization, analytics, and protecting the rights and assets of users and Hollycorn N.V.

REFLECT: We limit personal data processing to the minimum required under law and industry standards. Processing is always justified by one or more legal grounds identified above and subject to robust protective safeguards.

Regional Compliance Note: AU privacy principles and the Office of the Australian Information Commissioner (OAIC) guidelines are expressly observed where applicable to non-residing service operators engaging AU clients.

Purpose of Processing

OBSERVE: Clear legislative and operational alignment explaining purposes of collected data.

Service Provision: To register, manage, and administer your lucky-7-even.com account, fulfil contractual obligations, process bets, and deliver online casino services.
Regulatory Compliance: To verify your identity, prevent illegal activities (including money laundering, fraud, and underage gambling), and satisfy reporting obligations to relevant authorities.
Service Improvement and Analytics: To analyze site performance, user experience, and consumer trends, enhancing functionality and security.
Marketing and Communication: Subject to user consent, to inform you about promotions, new games, or services via e-mail, SMS, or similar channels. Opt-out is available at any time.
Fraud Prevention and Security: To monitor and investigate suspicious activities, protect both the organization and its users, and maintain the integrity of the gaming environment.

REFLECT: Data will not be processed beyond stated purposes unless required by law or further explicit consent is provided.

Disclosure & Sharing

OBSERVE: Systematic identification of categories of third parties and disclosure contexts under AU and Curaçao law.

Payment and Financial Partners: Data is shared with reputable payment processors, banking institutions, and financial intermediaries to facilitate transactions, deposits, and withdrawals, strictly limited to operational necessity.
Service Providers: External service providers, including hosting, IT security, email delivery, analytics, and identity verification agencies, may process your data under binding confidentiality and data protection agreements.
Regulatory and Legal Disclosure: Data may be disclosed to official regulatory bodies or competent authorities in compliance with statutory obligations, investigation orders, or legal proceedings.
Affiliates and Marketing Partners: With your explicit consent (where required), certain limited information may be shared with trusted affiliates and advertising networks for marketing or promotional activities. Such transfers are governed by separate data-sharing agreements and opt-out mechanisms.

REFLECT: All third parties are contractually obliged to uphold equivalent data protection standards, including those stipulated by AU and Curaçao iGaming regulations. No data is sold to unrelated parties.

International Transfers

OBSERVE: Identification of data transit outside national boundaries relevant to AU clients and implementation of safeguarding measures.

Transfers: Since Hollycorn N.V. operates from Curaçao with services extended to Australia, user data may be processed and stored in jurisdictions beyond Australia, primarily Curaçao and EEA-aligned data centers when required.
Protection Measures: All cross-border transfers are conducted using legally recognized mechanisms, including standard contractual clauses, data processing addenda, and ongoing compliance with international frameworks such as EU GDPR where applicable.
Legal Safeguards: Extra safeguards, including encryption in transit, restricted access, and audit requirements, are enforced to uphold the privacy rights of AU residents during and after transfer.

REFLECT: Contact our Data Protection Officer for more information on applicable transfer mechanisms and safeguards for your personal information.

Data Retention

OBSERVE: Explicit documentation of retention schedules, per AU/AML regulations and industry best practices.

User Account Data: Maintained for the duration of the active account and up to five (5) years post-closure to comply with legal and anti-fraud obligations.
KYC/AML Documentation: Held for a minimum of five (5) years after account closure or last transaction, as required under anti-money laundering laws.
Marketing and Communication Records: Retained only for the operational period of consent or until opt-out/withdrawal.
Behavioral/Analytics Data: Aggregated and anonymized data may be retained for statistical, security, and compliance purposes without linkage to identifiable persons.

REFLECT: Data is securely deleted or anonymized when storage is no longer necessary for the purposes it was collected, including upon verified request or statutory expiration.

Your Rights

OBSERVE: Rights in accordance with the AU Privacy Act and international standards adopted in gaming jurisdiction.

Access: Request details of your personal data held by lucky-7-even.com.
Correction: Request correction of inaccurate or incomplete data.
Erasure: Seek deletion of your data where permissible by law ("right to be forgotten").
Restriction: Limit processing of your data under specified conditions.
Objection: Object to processing based on legitimate interests or direct marketing.
Data Portability: Obtain a machine-readable copy of your data and transmit it to another provider (where technically feasible).
Consent Withdrawal: Revoke marketing or non-essential consent at any time without affecting lawfulness of previous processing.

REFLECT: Requests may be exercised by contacting our Data Protection Officer as detailed below. Identity verification is mandatory before fulfilling rights-based requests in order to protect user privacy and security.

Cookies & Tracking Technologies

OBSERVE: System 1 listing of cookie types with System 2 legal articulation of management and rights.

Session Cookies: Essential for secure access, authentication, gameplay integrity, and page navigation during your visit. Expire once browser is closed.
Persistent Cookies: Facilitate preferences, saved settings, and faster login. Retained for a predetermined period or until deleted by the user.
Third-Party Cookies: Placed by analytics (e.g., Google Analytics), advertising partners, or affiliate networks to enhance service functionality and deliver targeted offers, subject to your consent where required.

Management: You can manage or disable cookies via your browser settings or within our site's internal cookie management panel. Note, disabling essential cookies may impact site performance.

REFLECT: Full cookie usage details are outlined in our Cookie Policy, available on lucky-7-even.com.

Data Security

OBSERVE: Description of technical and organizational measures to protect data integrity and confidentiality.

SSL/Transport Layer Security: All transmitted data is protected via 256-bit SSL encryption, securing data between your device and our servers.
Encryption & Tokenization: Sensitive data, including payment information and identity documentation, is encrypted or tokenized as per industry best practices.
Access Controls: Restricted administrative access to data systems, with robust authentication and permission management.
Auditing and Monitoring: Regular independent security audits, log monitoring, and intrusion detection protocols ensure threats are promptly identified and mitigated.
Staff Training & Policies: All employees and contractors sign confidentiality agreements and are trained in data protection and security responsibilities.

REFLECT: In the event of a data breach affecting AU users, regulatory reporting requirements are observed, and impacted users are notified in accordance with OAIC guidance.

Complaints & Contacts

OBSERVE: Provision of DPO contact and complaint escalation procedures as mandated by AU and international law.

Data Protection Contact: All data protection, privacy inquiries, or requests should be directed to Chloe Miller, Data Protection Officer, via the official contact form at lucky-7-even.com.
Complaint Process: If you believe your data has been processed in violation of this policy or applicable laws, you may file a formal complaint using the methods above. We will address your complaint in writing within thirty (30) days, subject to the complexity of the issue.
Regulatory Recourse: If dissatisfied with our response, you retain the right to escalate your complaint to the Office of the Australian Information Commissioner (OAIC).

REFLECT: All communications are handled with strict confidentiality in accordance with statutory requirements.

Updates

OBSERVE: Transparency in policy modifications, update methodology, and effective dating.

Notice of Changes: Substantial updates to this privacy policy will be communicated through prominent notices on lucky-7-even.com and, where appropriate, by e-mail to registered users.
Policy Version: This document was last revised on 1 January 2025 and supersedes all earlier versions.

REFLECT: Continued use of lucky-7-even.com after notification of changes constitutes acceptance of the revised policy. Users are encouraged to review this page periodically for the latest information on our privacy practices.