Privacy Policy

1. Introduction

We respect your privacy and are committed to protecting your personal data. This Lucky Gem Privacy Policy (“Policy”) will inform you how we look after your personal data when you use program, site, operated by Lucky Gem (“Service”). It also covers our collection of personal data from third parties and publicly available sources such as social media platforms, data aggregators, and credit reference agencies. It sets out your privacy rights and how the law protects them.

We use cookies and similar technologies to collect personal data.

This Policy forms an integral part of the Terms and Conditions, and by accepting the Terms and Conditions, you also accept the terms of this Privacy Policy and the use of your personal data in accordance with this Privacy. If you do not agree with the terms of this Privacy, you should not use this Service or otherwise provide us with your personal data.

2. Purpose of this Privacy Policy

This Policy aims to give you information on how we collect and process your personal data when you use our Service.

This Service is not intended for children, and we do not knowingly collect personal data relating to children.

It is important that you read this Policy together with any other privacy policy or fair processing policy we provide.

This ensures that you are fully aware of how and why we use your data when collecting or processing personal information.

3. Who we are and how to contact us

Service is operated by Lucky Gem, a duly registered company in accordance with the laws of the Autonomous Island of Anjouan, Union of Comoros with registered company No. 15925.

If you have any questions about this Privacy Notice, including any requests to exercise your rights in relation to personal data, you should contact our data privacy manager by email: luckygem.help@gmail.com.

You have the right to make complaints at any time to the relevant data protection and privacy regulator. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so we kindly request that you contact us in the first instance.

4. Changes to the Policy and Players’ duty to inform us of changes

We keep this Policy under regular review. This version was last updated on the date at the end of the Policy.

It is important that the personal data that we hold about Players is accurate and current. We kindly request that you keep us informed if your personal data changes at any time whilst you have an account with us.

5. Third-party links

The Service may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share personal data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Service, we encourage you to read the privacy policy of every website that you visit.

6. The data we collect about you

Personal data, or personal information means any information about an individual from which that person can be identified.

Anonymous data is excluded.

We collect information that you provide directly, such as when you register an Account or contact customer services. We may also receive information from public sources and third parties, including social platforms and data aggregators.

We may collect, use, store and transfer:

• Identity Data, including a Telegram account, telephone number and email address.
• Technical Data, including IP address, login data, time zone, location, operating system, platform and device technology used to access the Service.
• Photographs in your Account.
• Transaction Data, including purchases and details of services used.
• Profile Data, including usernames and services used.
• Usage Data about how you use the Service, products and services.
• Marketing and Communications Data, including your marketing and communication preferences.

We also collect, use and share Aggregated Data, such as statistical or demographic data, for any purpose. Aggregated Data may be derived from personal data but is not considered personal data in law when it does not reveal your identity. If Aggregated Data is combined with personal data so that you can be identified, we treat the combined data as personal data under this Policy.

7. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you (for example, where it is required under our Player Terms and Conditions), and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

8. How is your personal data collected

We use different methods to collect data from and about Players, including:

• Direct interactions: you may give us Identity, Contact and Financial Data by completing forms in the Service or corresponding with us.
• Automated technologies or interactions: as you interact with the Service, we automatically collect Technical Data about equipment, browsing actions and patterns through cookies and similar technologies.
• Third parties or publicly available sources: analytics providers, advertising networks, search information providers, technical and payment service providers, and aggregators.

9. How we use your personal data

We collect your personal information so that we can provide an excellent level of service and so that you can use the Service in an agile and secure way. Collecting personal data also allows us to offer more customisation in the Service.

10. Marketing

You will receive marketing communications from us if you have an Account and have not opted out of receiving such marketing communications at the time we first collected your personal data or at any time.

You can ask us or third parties to stop sending marketing messages at any time by contacting us or adjusting the marketing settings in the Service.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us for reasons other than marketing.

11. Disclosures of your personal data

We may share your personal data with the following parties for the purposes described above.

Internal third parties

• Other group companies acting as joint controllers or processors and providing IT, HR, customer service, system administration or leadership reporting services.

External third parties

• IT service and system administration providers.
• Payment solutions providers.
• Identity verification providers used to prevent fraud.
• Providers that send marketing communications on our behalf.
• Professional advisers, including lawyers, bankers, auditors and insurers.
• Tax authorities, regulators, government agencies and other authorities that require reporting.
• Parties involved in a sale, transfer, merger or acquisition of our business or assets. If a change happens to our business, new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

12. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

13. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your data; to do so, please see the section 14 below for further information.

Sometimes we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

14. Your rights

Under certain circumstances, you may have the following rights under data protection laws:

• Request access to the personal data we hold about you.
• Request correction of incomplete or inaccurate personal data. We may need to verify the accuracy of new data you provide.
• Request erasure where there is no good reason for continued processing, where you successfully object, where processing was unlawful, or where local law requires erasure. Legal or regulatory obligations may prevent us from complying in some cases.
• Object to processing based on your particular situation and its impact on your rights and freedoms. We may demonstrate compelling legitimate grounds that override those interests.
• Request restriction of processing of your personal data. This enables you to ask us to suspend processing in certain scenarios.
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it, to establish, exercise or defend legal claims.
  • Your objection is under review.
• Request transfer of personal data to you or a chosen third party in a structured, commonly used, machine-readable format. This applies to automated information processed through consent or performance of a contract.

If you wish to exercise any of these rights, contact us and we will confirm whether we are able to do so.

You will not have to pay a fee to access your personal data or exercise your other rights. We may charge a reasonable fee or refuse a request that is clearly unfounded, repetitive or excessive.

We may request specific information to confirm your identity and ensure that personal data is not disclosed to someone without a right to receive it. We may also request further information to speed up our response.

We try to respond to legitimate requests within one month. Complex or numerous requests may take longer; in that case, we will notify you and keep you updated.

This Privacy Policy was last updated on 22/03/2026.