Privacy Policy
1. Who we are
This Privacy Policy describes how Prestige Capital Group Limited ("we", "us", "our"), a company incorporated in the Republic of Seychelles (company number 238531, registered office 301 Victoria House, Victoria, Mahé, Seychelles), collects, uses, and protects personal data of users of the Lucky Dragon platform ("the Platform").
We are the data controller in respect of personal data processed in connection with the Platform.
2. Personal data we collect
We collect personal data necessary to operate the Platform lawfully, including:
- Identity data: full legal name, date of birth, nationality, gender (where provided), photograph from identity documents;
- Contact data: email address, telephone number, postal address, country of residence;
- Account data: username, hashed password, security questions, account preferences;
- Verification data: copies of identity documents, proof of address, source-of-funds documentation, video verification recordings where applicable;
- Financial data: cryptocurrency wallet addresses, transaction records, gameplay records, bonus history;
- Technical data: IP address, device identifiers, browser type and version, operating system, geolocation data, session data;
- Communications data: messages exchanged with our Customer Support, complaint records, marketing preferences;
- Behavioural data: patterns of play, deposit and withdrawal behaviour, responsible-gambling indicators.
3. How we use your data
We process your personal data for the following purposes and on the following lawful bases:
- To provide the Services (contractual necessity): account creation and management, processing deposits and withdrawals, settling wagers, customer support, dispute resolution.
- To comply with legal obligations (legal obligation): KYC verification, anti-money laundering and counter-terrorist-financing checks, sanctions screening, regulatory reporting, tax reporting, and responding to lawful requests from authorities.
- To prevent fraud and abuse (legitimate interests): detecting multiple accounts, identifying bonus abuse, monitoring for collusion and fraud, sharing data with fraud-prevention networks.
- To protect Players from harm (legitimate interests, vital interests): identifying signs of problem gambling, applying limits, enforcing self-exclusion, signposting support services.
- To improve and personalise the Services (legitimate interests): analysing usage to improve the Platform, personalising game recommendations.
- For marketing (consent, where required): sending marketing communications about the Services. You may withdraw consent at any time.
4. Sharing of personal data
We share personal data only where necessary and with appropriate safeguards. Recipients may include:
- Game and sportsbook providers (to enable gameplay and bet settlement);
- Payment-processing and cryptocurrency-analytics providers (to process transactions and meet AML obligations);
- KYC and identity-verification providers;
- Cloud-hosting and IT-service providers;
- Affiliates of the Operator;
- Regulators, law-enforcement agencies, courts, and other authorities where legally required;
- Professional advisors (lawyers, auditors, accountants) bound by confidentiality;
- Acquirers or successors in the event of a sale, merger, or restructure of the business.
We do not sell your personal data to third parties.
5. International transfers
Your personal data may be transferred to, processed, and stored in countries outside your country of residence. Where such transfers occur, we ensure appropriate safeguards are in place, including contractual protections.
6. Data retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected and to meet our legal obligations. In particular:
- Account and transaction records are retained for at least five years after Account closure to comply with anti-money-laundering legislation;
- Self-exclusion records are retained indefinitely or as required by applicable law;
- Marketing data is retained until you withdraw consent or for two years of inactivity, whichever is sooner.
7. Your rights
Subject to applicable law, you have the right to:
- Access the personal data we hold about you;
- Request correction of inaccurate or incomplete data;
- Request erasure of your data, subject to our legal retention obligations;
- Object to certain processing, including direct marketing;
- Request restriction of processing in certain circumstances;
- Receive your data in a portable format;
- Withdraw consent where processing is based on consent;
- Lodge a complaint with the relevant supervisory authority.
To exercise any of these rights, contact privacy@luckydragon.com [PLACEHOLDER].
8. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, and destruction, including encryption in transit and at rest, access controls, regular security testing, and staff training. No system is completely secure; we cannot guarantee absolute security.
9. Children
The Platform is not intended for, and we do not knowingly collect personal data from, persons under 18 years of age (or the legal age of majority in their jurisdiction, whichever is higher). If we become aware of such data, we will delete it promptly.
10. Changes to this Policy
We may update this Privacy Policy from time to time. Material changes will be notified by email or in-Account notification. The "Last updated" date at the top of this Policy reflects the most recent revision.
11. Contact
For privacy-related enquiries: privacy@luckydragon.com [PLACEHOLDER]
Prestige Capital Group Limited · 301 Victoria House, Victoria, Mahé, Seychelles
