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Privacy Policy

This Privacy Policy explains how and why personal information is collected and processed by lukki-casino-new-zealand when you use the services provided via lukki-nz.com. The policy applies to all players and website visitors. Effective as of 6 November 2025, this policy sets out your rights and our obligations regarding your personal data under applicable New Zealand privacy laws and international industry standards.

Who We Are

OBSERVE: Legal entity, address, registration, and contacts identified.
EXPAND: Data Protection Officer (DPO) role clarified for NZ context.
REFLECT: Transparent operator identity and contact points established.

  • Operator: lukki-casino-new-zealand is operated by Dama N.V., a public limited liability company (N.V.) registered under Curaçao law, company registration number 152125.
  • Registered Address: Scharlooweg 39, Willemstad, Curaçao.
  • Gaming Licences:
    • Antillephone N.V., Government of Curaçao, Licence No. 8048/JAZ2020-13 (valid through 2025).
    • Curaçao Gaming Control Board, Licence No. OGL/2025/164/0246 (valid through 2025).
  • Contact for Data Protection:

What Personal Data We Collect

OBSERVE: Data categories identified for casino operations.
EXPAND: Inclusion of technical, behavioural, and regulatory data.
REFLECT: Comprehensive overview ensures transparency and user awareness.

  • Personal Identification Data: Full name, date of birth, residential address, email address, phone number, identification documents (for KYC).
  • Technical Data: IP address, device information (type, operating system, browser), session logs, and access timestamps.
  • Payment Data: Credit/debit card information, bank account details, transaction records, payment processor references (including Friolion Ltd., Cyprus).
  • Behavioural Data: Betting and gaming history, site usage patterns, clicks, in-game actions, responsible gambling interactions.
  • Cookies & Tracking: Session and persistent cookies, third-party analytics tags, advertising identifiers, and tracking pixels.

Note: Some data may be collected automatically or provided voluntarily as part of registration, gameplay, or support interactions.

Legal Basis for Processing

OBSERVE: Legal grounds for data processing under NZ and international standards.
EXPAND: Multiple bases for different data types and usage scenarios.
REFLECT: Ensures processing is lawful, fair, and transparent in every instance.

  1. User Consent: Data is processed when you provide explicit consent (e.g., for marketing communications or cookies).
  2. Contract Performance: Processing is necessary to provide you with casino services, manage your account, and process transactions on lukki-nz.com.
  3. Legal Obligations: Compliance with regulatory requirements, including Know Your Customer (KYC), Anti-Money Laundering (AML), and responsible gambling obligations under NZ and international law.
  4. Legitimate Interests: Ensuring platform security, fraud prevention, service analytics, and business operations, provided such interests do not override your fundamental rights.

Purpose of Processing

OBSERVE: Core and ancillary processing purposes mapped.
EXPAND: Purposes aligned with industry best practices and regulatory mandates.
REFLECT: Full disclosure of all intended data uses to users.

  • Casino Service Delivery: Account creation, identity verification, payment processing, and customer support.
  • Service Improvement: Analysing usage patterns and user feedback to enhance performance, functionality, and user experience.
  • Marketing & Promotions: Sending targeted offers, newsletters, and promotional materials (with your consent).
  • Analytics: Statistical analysis, business reporting, and trend monitoring to support business and regulatory needs.
  • Fraud & Security: Monitoring and preventing fraudulent activities, account abuse, and ensuring the integrity and security of lukki-nz.com.

Disclosure & Sharing

OBSERVE: Data sharing entities and circumstances identified.
EXPAND: Specific partners and regulatory bodies included.
REFLECT: Users informed of all possible data disclosures and protections.

  • Payment Partners: Financial institutions and payment processors (including Friolion Ltd., Cyprus) for deposits, withdrawals, and fraud screening.
  • Service Providers: Technical support, cloud hosting, analytics, and software providers, under strict contractual obligations.
  • Regulatory Authorities: Disclosure as required by the Government of Curaçao, New Zealand authorities, or other competent bodies.
  • Affiliates and Marketing Networks: Third-party partners for promotional activities, only with your explicit consent.
  • Legal Requirements: Where required to comply with legal processes, enforce terms, or protect rights and safety.

All third-party disclosures are subject to contractual safeguards and data protection compliance standards.

International Transfers

OBSERVE: Data transfer locations and mechanisms identified.
EXPAND: Protections under international and NZ data transfer laws articulated.
REFLECT: Users protected from cross-border data risks.

  • Transfer Destinations: Your data may be transferred to and processed in Curaçao, Cyprus (for payment processing), and other countries where our service providers operate.
  • Protection Measures:
    • Use of standard contractual clauses to ensure equivalent data protection standards.
    • Due diligence on third-party service providers to verify compliance with relevant privacy regulations.
    • Implementation of technical and organizational safeguards to protect data during transfer and processing.
  • NZ Compliance: International transfers are conducted in accordance with the New Zealand Privacy Act 2020 and best industry practices.

Data Retention

OBSERVE: Retention periods and deletion protocols defined by law.
EXPAND: Categories and criteria for data deletion clarified.
REFLECT: Data is not held longer than necessary for its purpose or legal requirements.

  • Personal Data: Retained for as long as your account is active and for up to 5 years after account closure or last transaction, in line with regulatory and anti-money laundering requirements.
  • Payment and Transaction Data: Retained for up to 7 years for tax, auditing, and legal compliance purposes.
  • Cookies & Analytics: Data retention periods vary but do not exceed 2 years from collection.
  • Deletion Criteria: Data is deleted or anonymised upon expiry of retention periods, upon your request where legally permissible, or when processing purposes no longer apply.

Retention is governed by legal, regulatory, and business requirements, including dispute resolution and fraud monitoring provisions.

Your Rights

OBSERVE: User rights under GDPR, NZ Privacy Act 2020, and relevant international standards.
EXPAND: Procedures for exercising rights and response guarantees clarified.
REFLECT: Empowerment of users and full legal alignment achieved.

  1. Access: Request a copy of your personal data held by lukki-casino-new-zealand via support@lukki-nz.com.
  2. Correction: Request rectification of inaccurate or incomplete data.
  3. Deletion: Request deletion of your data where no lawful basis for retention exists ("right to be forgotten").
  4. Restriction: Request restriction of processing in certain circumstances (e.g., contesting accuracy or lawfulness).
  5. Objection: Object to processing based on legitimate interests or direct marketing at any time.
  6. Data Portability: Receive your data in a structured, commonly used, machine-readable format and transmit it to another controller.
  7. Withdrawal of Consent: Withdraw consent to marketing or non-essential processing at any time, without affecting the lawfulness of prior processing.
  • How to Exercise Rights: Submit your request to support@lukki-nz.com. We will respond within 30 days, free of charge, except in manifestly unfounded or excessive cases.
  • NZ Compliance: All rights are granted in accordance with the New Zealand Privacy Act 2020. For unresolved complaints, you may contact the Office of the Privacy Commissioner (privacy.org.nz).

Cookies & Tracking Technologies

OBSERVE: Cookie types and management options specified.
EXPAND: Functional, analytics, and advertising cookies differentiated.
REFLECT: User control and transparency prioritized.

  • Session Cookies: Essential for website operation and user authentication; expire when browser is closed.
  • Persistent Cookies: Remain on your device for a defined period to remember preferences and improve experience.
  • Third-Party Cookies: Used for analytics (e.g., Google Analytics) and advertising based on user consent.
  • Cookie Management: Adjust settings in your browser to block or delete cookies. You can also manage preferences through the site's internal cookie panel where available.

Disabling cookies may limit certain features or functionality of lukki-nz.com.

Data Security

OBSERVE: Security controls and standards outlined.
EXPAND: Industry best practices and compliance measures detailed.
REFLECT: Comprehensive safeguards for user data implemented.

  • Encryption: TLS 1.2+ encryption for all data in transit; strong encryption standards for data at rest.
  • Access Controls: Role-based access restrictions and multi-factor authentication for sensitive systems.
  • Security Audits: Regular penetration testing, vulnerability assessments, and compliance audits.
  • Staff Training: Ongoing employee education on data protection and privacy obligations.
  • Incident Response: Documented response procedures for data breaches, including user notification obligations under the New Zealand Privacy Act 2020.
  • International Standards: Alignment with recognised frameworks such as ISO 27001 and SOC 2 where applicable.

Complaints & Contacts

OBSERVE: Multi-channel complaint procedures established.
EXPAND: Escalation pathways and supervisory contact details included.
REFLECT: Transparent, user-centric approach to privacy concerns.

  1. Contact Channels:
  2. Complaint Procedure:
    • Submit your privacy complaint via email or the website's contact form (when available).
    • Your complaint will be acknowledged within 5 business days.
    • Resolution or substantive response will be provided within 30 days.
  3. Escalation:
    • If you are unsatisfied, you may escalate your complaint to the New Zealand Office of the Privacy Commissioner:
    • Website: privacy.org.nz
    • Phone: 0800 803 909 (within NZ)

Updates

OBSERVE: Policy change notification mechanisms identified.
EXPAND: User options and version controls established.
REFLECT: Ongoing transparency and user empowerment ensured.

  • Notification Methods: Users will be informed of material changes to this Privacy Policy via email, website banners, and/or account dashboard alerts.
  • Advance Notice: Significant changes will be notified at least 30 days in advance. Users may object or request account closure if they do not accept the changes.
  • Version Control: This Privacy Policy is versioned and includes a "Last updated: 6 November 2025" timestamp.
  • Changelog: Material changes will be summarised in a changelog for user reference.

Continued use of lukki-nz.com following policy updates constitutes acceptance of the revised Privacy Policy.