Privacy Policy

This Privacy Policy explains how the Luckster brand as offered via the Luckster website at https://lyckster.bet ("we", "us", "our") collects, uses, discloses and protects personal data of players and website visitors in the course of providing online gambling services. It applies to registered players, prospective players, and anyone who accesses or interacts with the lyckster.bet site or related communication channels. This Privacy Policy forms part of our general terms and conditions and should be read together with them. The policy is effective from 6 November 2025.

Who We Are

Data controller for UK players. For the purposes of UK data protection law (including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018), the data controller responsible for your personal data in connection with the Luckster services on lyckster.bet is:

AG Communications Ltd
Company number: C48328
Registered office / legal address: 135 High Street, Sliema SLM 1548, Malta
UK remote gambling licence: 39483, issued by the UK Gambling Commission

AG Communications Ltd operates the Luckster brand for UK players on the Aspire Global white-label platform and is responsible for determining how and why your personal data is processed when you use the Luckster site at lyckster.bet.

Group and platform context. The platform infrastructure is shared with related brands operated on the Aspire Global platform. For certain non-UK players, services may be operated under an additional licence issued by the Malta Gaming Authority (licence number MGA/CRP/148/2007). However, this Privacy Policy focuses on processing for UK-based users of the Luckster site.

Data Protection Officer and contact. We have appointed a Data Protection Officer ("DPO") to oversee questions regarding this Privacy Policy and our privacy practices. You may contact us using the details below:

Email (privacy queries): [email protected]
DPO contact: Data Protection Officer, AG Communications Ltd, 135 High Street, Sliema SLM 1548, Malta, or via [email protected]
Website: https://lyckster.bet

What Personal Data We Collect

We collect and process different categories of personal data when you visit or use the Luckster services on lyckster.bet. The specific data collected depends on how you interact with us, regulatory requirements, and technical circumstances.

Identification and contact data

Account data: full name, username, date of birth, gender (where provided), nationality, residential address, email address, telephone number.
Verification (KYC/AML) data: copies and details of identity documents (e.g. passport, ID card, driving licence), proof of address (e.g. utility bill, bank statement), ownership and source-of-funds / source-of-wealth ("SoW") documentation (e.g. payslips, tax returns, company documents), and any additional due diligence information required under UKGC, UK AML and, where applicable, other regulatory guidance.

Technical and usage data

Technical identifiers: IP address, device identifiers, operating system, browser type and version, language settings, referring URLs, time-zone settings.
Log and activity data: logins and logouts, password changes, session time stamps, accessed pages, clicks, menu navigation, game launches, time spent on site, and technical error logs.

Payment and financial data

Transaction data: deposits, withdrawals, bonuses credited and redeemed, payment methods used, partial payment card details (masked PAN), IBAN or bank account details where required, payment provider identifiers, chargeback and refund history.
Affordability and risk assessment data: aggregated win/loss records, staking patterns, limits requested, and financial risk indicators derived from your gameplay and documentation, collected in line with the enhanced AML and safer-gambling controls applied following UKGC guidance and enforcement actions.

Behavioural and profile data

Gaming behaviour: games played, stakes, wins and losses, bonuses used, game session frequency and duration, self-exclusion status, reality-check acknowledgements, and responsible gambling tools usage (e.g. deposit limits, time-outs).
Marketing and preference data: subscription status for email, SMS, push and on-site marketing, language preferences, communication history, interaction with promotions, participation in surveys and feedback forms.

Cookies and similar technologies

Cookies: small text files placed on your device, including strictly necessary, functional, analytics, and advertising cookies, as described in more detail in the Cookies & Tracking Technologies section.
Similar technologies: tracking pixels, tags, SDKs and local storage used for fraud prevention, analytics, and to tailor content and offers.

Communications and service data

Customer support records: chat transcripts, emails, call notes, complaint records and dispute correspondence (including with ADR services such as IBAS).
Regulatory and compliance data: information relating to responsible gambling interventions, AML investigations, and communications with regulators that involve your account.

Legal Basis for Processing

We process your personal data only where we have a valid legal basis under the UK GDPR, the Data Protection Act 2018 and, where relevant, other applicable data protection frameworks. Depending on the context, one or more of the following legal grounds may apply.

Performance of a contract

Account creation and management: We process identification, contact, technical and account data to register you as a player, provide access to your account, manage your balance, and ensure the correct operation of the Luckster services on lyckster.bet.
Game and payment processing: We process transactional, gameplay and device data to accept deposits, process withdrawals, credit winnings, apply bonuses and loyalty rewards, and deliver our games and features as set out in our terms and conditions.

Compliance with legal and regulatory obligations

UKGC licence conditions and AML laws: As a UKGC licensee (licence 39483), AG Communications Ltd must perform identity checks, affordability assessments, SoW verification, transaction monitoring, record-keeping, and reporting in line with gambling and financial crime legislation. This includes obligations arising from regulatory actions and updated UKGC guidance, such as stricter AML and safer gambling checks implemented from 2022 onwards.
Tax, audit and accounting: We process transactional and related data to comply with accounting, taxation and corporate reporting obligations in Malta, the UK and, where relevant, other jurisdictions.

Legitimate interests

Service improvement and analytics: We use technical, usage and behavioural data to understand how players use our services, improve performance, fix bugs, develop new features, and optimise our site and games. Where possible we use aggregated or pseudonymised information.
Fraud prevention and security: We process device, behavioural and transaction data to detect and prevent fraud, abuse, bonus misuse, money laundering, account takeover, and other unlawful activities. This may involve profiling and automated decision-making to flag high-risk behaviour for manual review.
Business protection: We process limited data as necessary to defend legal claims, manage disputes, and ensure the continuity and integrity of the Luckster brand on the Aspire Global platform.

Consent

Marketing communications: We send email, SMS or other electronic marketing messages about offers and services related to Luckster on lyckster.bet only where you have given us your consent or where permitted by law. You may withdraw your consent at any time via account settings or by using the unsubscribe mechanisms in our communications.
Optional cookies and similar technologies: Where required by the Privacy and Electronic Communications Regulations ("PECR") and UK GDPR, we rely on your consent to place non-essential cookies (for example, certain advertising and analytics cookies), which you can manage through our cookie banner or browser settings.

Purpose of Processing

We use personal data strictly for purposes that are compatible with the reasons for which it was collected, and only to the extent necessary to fulfil those purposes.

Provision and operation of gambling services

Account and identity management: Creating and managing your player account, verifying your identity and age, assigning user IDs, maintaining login credentials, and enabling you to use all core features of the Luckster services on lyckster.bet.
Gameplay and financial operations: Enabling you to deposit, wager, withdraw funds, participate in promotions, and receive winnings, while keeping accurate records for regulatory and accounting purposes.

Regulatory compliance and responsible gambling

Compliance monitoring: Conducting KYC and SoW checks, transaction monitoring, sanctions screening, and reporting obligations to the UKGC, the Malta Gaming Authority (for relevant non-UK activity), and other competent authorities.
Safer gambling and harm prevention: Using behavioural indicators to identify potentially harmful gambling patterns, operate responsible gambling tools, honour GamStop and local self-exclusion obligations, and support interventions in collaboration with organisations such as GamCare.

Customer support, communication and dispute resolution

Support services: Managing queries, technical issues, account requests and feedback via email, chat, forms and other channels.
Complaints and ADR: Handling complaints, investigating issues, and cooperating with alternative dispute resolution services such as the Independent Betting Adjudication Service (IBAS) where necessary.

Marketing, personalisation and analytics

Marketing and promotions: Sending you relevant offers and campaign updates about Luckster on lyckster.bet, subject to your marketing preferences and applicable consent rules.
Personalisation and analytics: Analysing aggregated and pseudonymised data to understand trends, tailor content, assess promotions, and improve games, site navigation and user experience.

Security, fraud prevention and risk management

Security safeguarding: Protecting the confidentiality, integrity and availability of our systems and data, including through logging, monitoring, incident detection, and cooperation with security providers.
Fraud and abuse prevention: Identifying and preventing fraudulent activities, bonus abuse, collusion, and breaches of our terms, using both rule-based systems and, where proportionate, automated profiling subject to human oversight.

Disclosure & Sharing

We do not sell your personal data. We share personal data only where necessary, proportionate and lawful, and subject to appropriate safeguards and contracts (including data processing agreements where required).

Payment and financial partners

Payment service providers and banks: We share necessary payment and transaction data with banks, card schemes, e-wallets, open banking providers and other payment institutions to process deposits, withdrawals, chargebacks and refunds. Your bank statement may display "AG Communications" or "Aspire Global" rather than "Luckster".
Fraud and risk management tools: We may use third-party fraud detection and AML screening services that process device, transaction and identity data to help us comply with regulatory obligations.

Service providers and technical partners

Platform and infrastructure providers: Aspire Global and associated hosting and IT service providers support the operation of the Luckster services on lyckster.bet, including servers, databases, and content delivery networks.
Game suppliers and RNG auditors: Game providers and independent testing laboratories such as iTech Labs may access limited data (e.g. technical logs, game session identifiers) to verify fairness, investigate incidents and perform audits.
Analytics and communication providers: Subject to cookie and consent settings, we may use analytics and customer communication tools to send service messages, conduct surveys and measure engagement.

Regulators, authorities and dispute bodies

Regulatory authorities: We may disclose data to the UK Gambling Commission, the Malta Gaming Authority, data protection authorities (such as the UK Information Commissioner's Office) and other competent authorities when required by law, licence conditions, or regulatory investigations.
ADR and complaint bodies: Where a dispute is referred to an approved alternative dispute resolution body such as IBAS, we may share relevant account, transaction and correspondence records.
Law enforcement and government bodies: We may disclose data in response to lawful requests, court orders, or to enforce our terms, protect our rights, or investigate suspected illegal activity.

Marketing, affiliates and advertising networks

Marketing service providers: With your consent where required, we may share limited contact and preference data with email delivery platforms, SMS gateways, and campaign tools acting as processors on our behalf.
Affiliate and advertising partners: We may share pseudonymised or aggregated data with affiliate partners and advertising networks to attribute traffic and measure marketing performance. Personal data is shared only to the extent necessary and in line with cookie and consent settings.

If we are involved in a corporate transaction such as a merger, acquisition or asset sale, personal data relating to the Luckster services on lyckster.bet may be transferred as part of that transaction, subject to confidentiality and continuity of protection.

International Transfers

Your personal data may be transferred to and processed in countries outside the United Kingdom, including within the European Economic Area ("EEA") and, in certain cases, other countries. These countries may have different data protection laws but we ensure that any such transfers are subject to appropriate safeguards.

EEA and Malta: Many of our core systems and support functions are operated from Malta and other EEA countries by AG Communications Ltd and the Aspire Global group. Transfers between the UK and EEA/Malta are supported by adequacy decisions and standard contractual safeguards where necessary.
Other countries: Some of our service providers (for example, cloud hosting, analytics or communication tools) may be located or may process data in countries that do not provide the same level of data protection as the UK. In such cases, we use appropriate safeguards, including:
- the UK International Data Transfer Agreement ("IDTA") or the UK Addendum to the EU Standard Contractual Clauses ("SCCs"), where applicable;
- EU SCCs or equivalent instruments for EEA-related transfers;
- additional technical and organisational measures, such as encryption and access controls.
Onward sharing: Any onward transfer by our partners is restricted by contract and must comply with applicable data protection laws and our instructions.

Where local laws might require authorities to access personal data, we assess such risks and, where possible, implement supplementary measures to protect your privacy.

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, regulatory, accounting or reporting requirements. Retention periods may vary according to data type and jurisdiction-specific obligations.

Player account and identification data: Typically retained for the lifetime of your account and, after account closure, for a period of up to 5 years, or longer where required by gambling, AML or tax laws. This reflects UKGC and AML record-keeping obligations and any extended periods necessary in light of previous regulatory actions and guidance.
Transaction and gameplay data: Retained for at least 5 years from the date of the relevant transaction or event, and longer where needed to resolve disputes, support responsible gambling assessments, or comply with statutory requirements.
KYC/SoW documentation: Retained for the minimum period required by AML and counter-terrorist financing legislation (generally 5 years after the end of the relationship or the date of the last transaction, subject to applicable law), after which it is securely deleted or anonymised.
Marketing and preference data: Retained while you remain opted in to marketing and, where you opt out, for a reasonable period to record your preference and demonstrate compliance, after which it may be anonymised.
Technical logs and security data: Retained for a shorter period, generally between several months and 2 years, unless a longer period is required for security investigations, fraud prevention, incident response or legal claims.
Complaint and dispute records: Retained for the duration of the complaint or dispute and for a period thereafter (usually up to 6 years) in line with limitation periods for legal claims and regulatory expectations.

Where data is no longer required, we will securely delete, anonymise or aggregate it so that it can no longer be associated with you. In some cases, we may retain anonymised data for statistical, research or analytical purposes without further notice to you.

Your Rights

Under the UK GDPR and related UK data protection law, and where applicable under other data protection regimes such as EU GDPR and certain Mexican data protection regulations, you have a range of rights in relation to your personal data. These rights are subject to conditions, exemptions and limitations, particularly where legal or regulatory obligations (such as AML and gambling regulation) require us to retain or process data.

Core data protection rights

Right of access: You can request confirmation as to whether we process your personal data and obtain a copy of that data, together with information about how we use it.
Right to rectification: You can request correction of inaccurate or incomplete personal data we hold about you. In many cases you can update certain details directly through your account settings on lyckster.bet.
Right to erasure: You can ask us to delete your personal data in certain circumstances, for example where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and there is no other legal basis for processing. We may be unable to delete data that we must keep to comply with AML, gambling or other legal obligations.
Right to restriction of processing: You can request that we restrict processing of your data (for example, while we verify its accuracy or assess an objection) so that we only store it and do not use it for other purposes, except as permitted by law.
Right to object: You may object to processing based on our legitimate interests, including profiling, on grounds relating to your particular situation. We will stop processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or the processing is required for legal claims.
Right to data portability: Where processing is based on consent or on a contract and carried out by automated means, you may request to receive personal data you provided to us in a structured, commonly used and machine-readable format, and, where technically feasible, to have it transmitted to another controller.
Right to withdraw consent: Where we rely on your consent (for example, for marketing or certain cookies), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

Mexican privacy law alignment

In certain circumstances, players who are residents of Mexico and access our services under specific arrangements may benefit from additional rights under Mexican data protection legislation, such as the Federal Law on Protection of Personal Data Held by Private Parties and related regulations. These rights are broadly aligned with the rights described above and may include access, rectification, cancellation and objection (often referred to as "ARCO" rights). Where such laws apply, we will handle requests in accordance with those regulations, while still respecting our legal and regulatory obligations (including AML and gambling-related requirements).

How to exercise your rights

Submitting a request: You can exercise your rights by contacting us at [email protected] or writing to the DPO at AG Communications Ltd, 135 High Street, Sliema SLM 1548, Malta. Please clearly indicate which right you wish to exercise and provide sufficient information to verify your identity and account.
Response time: We aim to respond to all valid requests within one month (30 calendar days) of receipt. If your request is particularly complex or we have received a large number of requests, we may extend this period in accordance with applicable law, in which case we will inform you of the extension and reasons.
Fees: Requests are handled free of charge. However, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded, excessive or repetitive, as permitted by law.
Verification and limitations: To protect your account, we may require additional information to verify your identity. In some cases we may not be able to fully comply with your request where legal or regulatory obligations require us to continue processing certain data (for example, AML record-keeping). In such cases, we will explain the reason for our decision.

Cookies & Tracking Technologies

We use cookies and similar technologies on the Luckster website at lyckster.bet to ensure the site functions correctly, to improve performance, to analyse usage, and to deliver relevant content and offers. Cookies are small text files placed on your device when you visit our site.

Types of cookies we use

Strictly necessary (session) cookies: Essential for the operation of the site and services, enabling basic functions such as page navigation, secure login, maintaining your session, and processing transactions. These cookies are usually session-based and expire when you close your browser.
Functional (persistent) cookies: Help us remember your preferences (for example, language, display settings, saved credentials where permitted) and provide enhanced, more personalised features. These cookies may remain on your device for a defined period or until you delete them.
Analytics and performance cookies: Used to collect aggregated information about how visitors use our site, such as pages visited, time spent, and any error messages. This helps us improve the performance and usability of the Luckster services. Where possible, data is anonymised or pseudonymised.
Advertising and targeting cookies: Used, where allowed, to deliver more relevant adverts and promotional messages related to Luckster and to measure the effectiveness of our marketing campaigns, including via affiliates and advertising networks. These cookies may be set by us or by third parties acting on our behalf.

Managing cookies

Consent and settings: On your first visit, and periodically thereafter, you may be presented with a cookie banner allowing you to manage non-essential cookies. You can update your preferences at any time via the cookie management tool on our site, where available.
Browser controls: Most browsers allow you to view, delete or block cookies, and to configure settings for certain sites. If you block all cookies, some parts of the Luckster services on lyckster.bet may not function correctly or may become unavailable.
Third-party cookies: Some cookies are placed by third-party service providers, such as analytics or advertising partners. We encourage you to review their privacy and cookie policies where relevant.

Data Security

We take the security of your personal data very seriously and implement technical and organisational measures designed to protect it against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Technical measures

Encryption in transit and at rest: Data transmitted between your browser and our systems is protected using Transport Layer Security (TLS) protocols (TLS 1.2 or higher). Sensitive data is protected at rest using industry-standard encryption and access controls. The site utilises SSL/TLS certificates issued by reputable certificate authorities (such as Sectigo RSA) as part of our security stack.
Access controls and authentication: Access to personal data is restricted to authorised personnel and service providers who need it for legitimate business and regulatory purposes. Strong authentication mechanisms, segregation of duties, and role-based access controls are applied.
Infrastructure security: The Aspire Global platform on which Luckster operates implements network segmentation, firewalls, intrusion detection and prevention systems, logging, and regular patching. We work towards alignment with recognised security standards and industry best practices (for example, ISO 27001-aligned controls), and many of our critical providers follow frameworks such as SOC 2.

Organisational measures

Policies and training: Staff who handle personal data receive appropriate training on data protection, security, AML, responsible gambling and confidentiality. Internal policies and procedures govern how data is accessed, used and disclosed.
Vendor management: We carefully select service providers and require them to implement adequate security measures and data protection safeguards through contractual obligations, including data processing and confidentiality clauses.
RNG testing and fairness: Independent auditors such as iTech Labs regularly test and certify our Random Number Generator (RNG) and game fairness, which contributes to the integrity of our gaming operations.

Incident response

Monitoring and detection: Systems and logs are monitored to detect unusual or suspicious activities that may indicate security incidents, fraud or misuse.
Response and notification: Where a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority in accordance with legal requirements, and, where required, we will inform affected individuals without undue delay, providing information on the nature of the breach, potential consequences and measures taken.

Complaints & Contacts

If you have any questions, concerns or complaints about how we process your personal data in connection with the Luckster services on lyckster.bet, you should contact us first so we can attempt to resolve the issue.

Contacting us

Privacy and data protection queries: [email protected]
Data Protection Officer: [email protected], Data Protection Officer, AG Communications Ltd, 135 High Street, Sliema SLM 1548, Malta
Website: https://lyckster.bet

When contacting us, please include your username (but not your password), relevant account details, and a clear description of your concern or request.

Complaint handling process

Initial review: We will acknowledge receipt of your complaint or query and conduct an initial assessment, typically within a few working days.
Investigation: We will investigate the matter, which may involve reviewing internal records, consulting relevant teams, and, if necessary, requesting additional information from you.
Response: We aim to provide a substantive response within one month (30 calendar days). If we are unable to respond within this timeframe due to complexity or volume, we will inform you of the delay and the expected timeframe.
Escalation: If you are not satisfied with our response, you may request that the matter be escalated internally or pursue external remedies as described below.

Supervisory authorities and external escalation

United Kingdom - ICO: If you are located in the UK and believe that we have not handled your personal data lawfully or satisfactorily addressed your concern, you have the right to lodge a complaint with the Information Commissioner's Office (ICO). Further information is available at https://ico.org.uk.
European Union/EEA: If EU/EEA data protection law applies to you, you may have the right to complain to your local data protection authority where you live, work, or where you believe a breach has occurred.
Mexico: Where Mexican data protection regulations apply (for example, for certain Mexican residents accessing our services), you may have the right to lodge a complaint with the Mexican data protection authority, the National Institute for Transparency, Access to Information and Personal Data Protection (INAI). Details on how to do this can be found on INAI's official website.
ADR and gambling-related disputes: For gambling-related disputes that cannot be resolved with us, you may be able to refer the matter to the Independent Betting Adjudication Service (IBAS) or another approved ADR provider as set out in our general terms and conditions. While ADR bodies primarily address transactional disputes rather than data protection issues, relevant personal data may be reviewed as part of such processes.

Updates

We may update or modify this Privacy Policy from time to time, for example to reflect changes in our services, legal obligations, regulatory guidance, or technological developments affecting the Luckster services on lyckster.bet.

How we will inform you

Website publication: The current version of this Privacy Policy will always be available on https://lyckster.bet. Please check back regularly to stay informed.
Direct notifications: For material changes, we will take reasonable steps to notify you in advance by means such as email, account notifications, or prominent banners on the site.
Account dashboard alerts: Where appropriate, we may display update notices or require you to actively acknowledge the updated Privacy Policy when you next log in.

Effective date, versioning and your options

Last updated: November 2025. We may include a short summary of material changes (a "changelog") where appropriate, highlighting significant updates such as new processing activities, new partners, or changes required by law or regulators.
Advance notice: For significant changes that materially affect your rights or how we use your data, we will provide, where feasible, at least 30 days' notice before the changes take effect, unless a shorter period is required by law, regulatory instruction, or is necessary for security or operational reasons.
Your continued use: If you do not agree with the updated Privacy Policy, you should stop using the Luckster services on lyckster.bet and may request account closure through customer support. Where changes are based on consent (for example, new marketing uses), you will have the opportunity to grant or withhold consent separately.

We encourage you to review this Privacy Policy periodically to remain informed about how we protect the personal data processed in connection with your use of the Luckster services on lyckster.bet.