Privacy Policy

Last updated: 23 July 2026

Who We Are

Club Lucky is operated by Traffic Label, with registered offices at 8 Sandridge Park, Porters Wood, England, AL3 6PH. We are the data controller responsible for your personal data collected through clublucky.com ("the Platform", "the Site", "Club Lucky"). For any privacy-related enquiries, you can contact us at: legal@clublucky.com.

What This Policy Covers

This Privacy Policy explains how we collect, use, store, and protect your personal data when you: visit our website, apply for Club Lucky membership, use the VIP Portal as an active member, or communicate with our team.

What Personal Data We Collect

When You Apply for Membership: Full name (first name, last name), email address, phone number (optional), casino partner(s) you currently play at (optional).

When You Register as a Member: Full name, email address, phone number, date of birth, residential address (country, county, city, postcode), password (stored encrypted).

When You Use the VIP Portal: Wallet balance and transaction history, cashback credits and withdrawal requests, communication preferences, profile updates.

Gaming Activity Data: We receive aggregated gaming activity data from our casino partner operators. This includes your activity levels at partner casinos and data used to calculate your cashback rewards. This data is received through affiliate tracking systems and our Data Platform partners. We do not have direct access to your casino accounts.

Automatically Collected Data: IP address, browser type and version, device information, pages visited and time spent, cookies and similar technologies (see Section 10).

How We Use Your Data

We process your personal data for the following purposes (with legal basis):

Processing your membership application — Legitimate interest
Creating and managing your VIP account — Performance of contract
Calculating and crediting cashback rewards — Performance of contract
Processing withdrawal requests — Performance of contract
Assigning you a dedicated Account Manager — Performance of contract
Sending invitation emails — Consent / Legitimate interest
Communicating service updates (cashback credits, withdrawals) — Performance of contract
Sending marketing communications — Consent
Verifying your age and identity — Legal obligation
Preventing fraud and ensuring platform security — Legitimate interest
Improving our services and user experience — Legitimate interest
Complying with legal and regulatory obligations — Legal obligation

We may share your personal data with the following categories of recipients:

Casino partner operators — limited data necessary to process cashback withdrawals and verify your membership.
Email service providers (SendGrid) — to deliver invitation emails and service communications on our behalf.
Data Platform partners — to retrieve and reconcile gaming activity data used for cashback calculation.
Identity verification providers — if and when KYC verification is introduced.
Professional advisors — legal, accounting, or audit services where required.
Law enforcement or regulators — where we are legally required to disclose information.

We do not sell your personal data to third parties. We do not share your data for third-party marketing purposes without your explicit consent.

International Transfers

Your personal data may be processed in countries outside your country of residence, including within the European Economic Area (EEA). Where we transfer data outside the EEA, we ensure appropriate safeguards are in place, including Standard Contractual Clauses or adequacy decisions.

How Long We Keep Your Data

Membership applications (approved): Duration of membership + 6 years
Membership applications (rejected): 12 months
Account and transaction data: Duration of membership + 6 years
Wallet and cashback history: Duration of membership + 6 years
Marketing consent records: Duration of consent + 2 years
Website analytics data: 26 months

After the retention period, data is securely deleted or anonymised.

Data Security

We implement appropriate technical and organisational measures to protect your personal data, including: encryption of data in transit (TLS/SSL), encrypted password storage, access controls and role-based permissions, regular security reviews, and secure infrastructure hosting. While we take all reasonable steps to protect your data, no method of transmission over the Internet is 100% secure. You are responsible for keeping your login credentials confidential.

Your Rights

Under applicable data protection laws (including GDPR), you have the following rights:

Right of access — Request a copy of the personal data we hold about you.
Right to rectification — Request correction of inaccurate or incomplete data.
Right to erasure — Request deletion of your data where there is no compelling reason to continue processing.
Right to restrict processing — Request that we limit how we use your data.
Right to data portability — Request a copy of your data in a structured, machine-readable format.
Right to object — Object to processing based on legitimate interests or direct marketing.
Right to withdraw consent — Where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at: legal@clublucky.com. We will respond within 30 days of receiving your request. We may ask you to verify your identity before processing your request. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

Cookies

We use cookies and similar technologies to operate and improve our website. Cookies are small text files stored on your device when you visit our site.

Types of Cookies We Use:

Essential — Site functionality, security, session management (Required)
Analytics — Understanding how visitors use our site, e.g. page views, navigation patterns (Optional)
Marketing — Measuring effectiveness of marketing campaigns (Optional)

You can manage your cookie preferences at any time through the cookie settings on our site. You can also configure your browser to reject cookies, though this may affect site functionality. For full details, see our Cookie Policy.

Minors

Club Lucky is not intended for persons under the age of 18. We do not knowingly collect personal data from anyone under 18 years of age. If we become aware that we have collected data from a minor, we will take steps to delete it promptly. If you believe a minor has provided us with personal data, please contact us immediately.

Marketing Communications

We may send you marketing communications about Club Lucky services, promotions, and partner offers where you have given consent or where we have a legitimate interest. You can opt out of marketing communications at any time by: using the unsubscribe link in any marketing email, updating your preferences in the VIP Portal (Profile & Settings), or contacting us at legal@clublucky.com. Opting out of marketing will not affect service-related communications (e.g., cashback credits, withdrawal confirmations, account security).

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or legal requirements. When we make significant changes, we will notify you via email or through the Platform. The "Last updated" date at the top indicates the most recent revision.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or how we handle your data:

Email: legal@clublucky.com
Operator: Traffic Label
Address: 8 Sandridge Park, Porters Wood, England, AL3 6PH

For data protection complaints, you may also contact the relevant supervisory authority in your jurisdiction.