Effective date: 13 November 2025
This Privacy & Cookies Policy (“Policy”) explains how LuckyHat (“LuckyHat”, “we”, “us”, or “our”) collects, uses, shares, and protects personal data when you visit or use our websites, including luckyhat.com and related subdomains or localized versions (collectively, the “Sites”).
LuckyHat is operated by FTD Digital, a company registered in the United Kingdom, with its registered office at:
3rd Floor, Waverley House, 7–12 Noel Street, London, United Kingdom, W1F 8GQ.
For certain activities, we may act together with our affiliates and group companies (collectively, the “Group”).
This Policy also describes the rights and choices available to users located in:
• the European Economic Area (EEA), the United Kingdom, and Switzerland (“Europe”);
• Brazil; and
• certain U.S. states including California, Colorado, Connecticut, Nevada, Utah, and Virginia.
If you have questions about this Policy or wish to exercise your privacy rights, contact us at [email protected].
1. Scope of this Policy
This Policy applies when you:
• visit or use our Sites;
• subscribe to our newsletters or marketing communications;
• use tools or features on the Sites (such as calculators, simulators, and comparison tools);
• interact with us by email or via contact forms; or
• apply for a role with LuckyHat.
This Policy does not apply to:
• websites, apps, or services we link to (including casinos, sportsbooks, or other third-party operators); or
• our own employees and contractors, whose data is governed by separate internal policies.
When you navigate to a casino, sportsbook, or other third-party service, their own privacy and cookie policies apply. We do not control how those third parties collect or use your data.
2. Personal data we collect
“Personal data” means information relating to an identified or identifiable individual. It does not include information that has been irreversibly anonymized.
We may collect the following categories of personal data depending on how you interact with us.
2.1 Information you provide directly
Contact Information
Such as your name, email address, and any other information you submit when you:
• subscribe to newsletters or updates;
• fill out contact forms;
• request information; or
• participate in surveys or promotions (if available).
Account / Profile Data (if user accounts are offered)
• username and password;
• profile image (if added);
• language, region, or content preferences;
• any other information you choose to include in your profile.
Recruitment Data
If you apply for a job with us, we may collect:
• your CV/résumé and cover letter;
• contact details;
• education and employment history;
• professional qualifications and skills;
• interview notes; and
• where permitted by law, background check or criminal record information.
2.2 Data collected automatically
When you use the Sites, we may automatically collect:
Technical Data
• IP address;
• browser type and version;
• operating system and device type;
• language and region;
• referring URLs;
• error logs and performance information.
Usage Data
• pages visited and time spent on each page;
• links clicked and navigation paths;
• usage of tools and features (e.g., simulator interactions);
• scroll and interaction patterns;
• the site or ad that referred you to us.
We collect this data through cookies, pixels, tags, and similar technologies (see Section 7).
2.3 Data from third parties
We may receive personal data from:
Analytics partners (e.g., Google Analytics, Hotjar)
Marketing and ad-tech partners (e.g., platforms measuring or optimizing campaigns)
Media partners and affiliates (e.g., hashed identifiers for attribution)
Third parties are responsible for having a lawful basis to share personal data with us.
2.4 Aggregated and anonymized data
We may generate aggregated or anonymized statistics that do not identify you. We may use this information for any lawful purpose.
We do not intentionally collect special categories of data (e.g., health, religion, sexual orientation) through the Sites.
3. How we use personal data
We use personal data for the purposes below. Where required, we rely on a legal basis such as consent, legitimate interests, contract, or legal obligation.
3.1 To operate and provide our Sites
• maintain and improve the Sites and their features;
• provide interactive tools and content;
• personalize content by region, language, or settings;
• respond to inquiries and support requests;
• send administrative or service-related communications.
3.2 Marketing and communications
We may use your contact details to:
• send newsletters and marketing related to content, tools, bonuses, and partners;
• show or measure advertising, including via cookies and pixels.
We send direct electronic marketing only where permitted by law, and with consent where required. You may unsubscribe at any time.
3.3 Analytics, research, and improvement
• understand website performance and user behavior;
• identify issues and improve user experience;
• test and develop new features and tools.
3.4 Recruitment
• assess and process your job application;
• communicate with you about opportunities;
• meet legal and regulatory requirements.
3.5 Legal compliance and protection
• comply with laws or regulatory requests;
• enforce our terms and policies;
• protect our rights, users, and others;
• detect and prevent fraud or security incidents.
4. When we share personal data
We do not sell personal data in the traditional sense of “selling.” We may share personal data with:
Group companies – for internal administration, analytics, and support.
Service providers – such as hosting providers, analytics tools, email platforms, support tools, and security tools. These parties act on our instructions and are contractually required to protect your data.
Advertising and media partners – where permitted, we may share limited identifiers (e.g., cookie IDs, hashed emails) to measure or optimize campaigns, attribute commissions, or deliver relevant content.
Professional advisers – such as lawyers, auditors, and insurers.
Law enforcement or regulators – where legally required or necessary to protect rights or investigate misuse.
Business transfers – in the event of a merger, acquisition, or reorganization, personal data may be transferred under appropriate safeguards.
5. International data transfers
Your personal data may be transferred to countries outside your own. Where required (e.g., for Europe or Brazil), we use safeguards such as:
• adequacy decisions;
• Standard Contractual Clauses;
• Binding Corporate Rules; or
• other legally approved mechanisms.
Contact us for more information on the safeguards used.
6. Data security and retention
6.1 Security
We implement technical and organizational measures intended to protect personal data against unauthorized access, loss, misuse, or alteration.
While no system is completely secure, we act promptly when aware of a breach and will notify individuals and authorities where required by law.
6.2 Retention
We retain personal data only as long as necessary to:
• operate the Sites;
• comply with legal, tax, and compliance obligations;
• resolve disputes and enforce agreements.
When data is no longer needed, we delete or anonymize it.
7. Cookies and similar technologies
7.1 What are cookies?
Cookies are small text files stored on your device. They may be first-party (set by us) or third-party (set by others). We also use technologies such as pixels and local storage.
7.2 How we use cookies
• Essential cookies – enable core site functionality.
• Preference/functionality cookies – remember settings such as language or region.
• Analytics cookies – help us understand traffic and performance.
• Advertising/measurement cookies – measure campaigns, perform audience measurement, and deliver relevant ads or content.
Where required by law (e.g., in Europe), we will request your consent before setting non-essential cookies.
7.3 Examples of cookies and tools
• Google Analytics
• Meta/Facebook Pixel
• Hotjar or similar analytics tools
• Push notification providers
• Our own first-party cookies
7.4 Managing cookies
You can manage cookies through:
• our cookie banner or consent tool (where available);
• your browser settings.
Disabling certain cookies may affect site functionality.
8. Your rights and choices
Regardless of location, you can:
• Opt out of marketing emails at any time;
• Choose not to provide personal data (though some features may not work);
• Manage cookie choices (see Section 7.4).
Regional rights are summarized in Sections 9–11. Contact us to exercise your rights.
9. Additional information for Europe and Brazil
9.1 Legal bases for processing
We rely on:
• Contract – to provide requested services;
• Legitimate interests – operating and improving our Sites, preventing fraud, measuring marketing;
• Consent – for marketing emails and non-essential cookies where required;
• Legal obligations – compliance with laws.
9.2 Your rights
Subject to limitations, you may:
• access, rectify, or delete your personal data;
• restrict or object to processing;
• request portability;
• withdraw consent;
• lodge a complaint with your supervisory authority.
10. Additional information for California residents
Under the CCPA, you may have the right to:
• know/access personal information we collect;
• delete personal information;
• correct inaccurate information;
• opt out of “selling” or “sharing” personal information (as defined by the CCPA);
• be free from discrimination for exercising your rights.
We do not knowingly sell or share personal information of minors under 16.
11. Additional information for Virginia and other U.S. states
Depending on your state, you may have rights to:
• access, delete, or correct personal data;
• obtain data portability;
• opt out of targeted advertising, sale of personal data, or certain types of profiling.
If your state law provides a right to appeal our decision, we will inform you how to do so.
12. Links to third-party websites
Our Sites contain links to third-party websites or services (e.g., casinos, sportsbooks). We do not control and are not responsible for their privacy or cookie practices. We encourage you to review each third party’s policies.
13. Contacting us
For questions or to exercise your rights, contact:
Email: [email protected]
We will respond within the time periods required by law and keep you informed if additional time is needed.
14. Changes to this Policy
We may update this Policy from time to time. When we do, we will update the effective date and notify you where appropriate (for example, by email or through a notice on the Sites).
