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Privacy Policy

Privacy Policy for luckytri.com

Effective Date: 18.11.2025
Last Updated: 18.11.2025

1. Introduction

SuperBluck Global Ltd. ("SuperBluck," "we," "us," or "our") is committed to protecting the privacy and security of the personal information we process. This Privacy Policy explains our practices for handling the information we collect from or about you in a business-to-business (B2B) context.

This policy applies to personal data collected through our corporate website, luckytri.com, as well as during other B2B interactions, such as industry events, email communications, and client onboarding processes.

Important Scope Clarification. As a B2B supplier, we do not engage directly with end-players. This Privacy Policy does not apply to any player data that our systems may process on behalf of our licensed B2C operator clients. Our role in processing player data is strictly defined as a "Data Processor" under applicable regulations like the GDPR and the Tobique Gaming Commission's General Code of Practice (Section 28.4). The handling of all player data is governed by the separate Data Processing Agreements (DPAs) we have in place with our B2C operator clients, who are the "Data Controllers" for that information.

2. Who We Are (The Data Controller)

For the purposes of personal data collected through this website and our B2B activities, the Data Controller is:

Company Name: SuperBluck Global Ltd.
Contact Email: [email protected]

3. What Information We Collect

We collect information necessary to manage our business relationships and provide our services.

A. Information You Provide Directly to Us
  • Contact and Professional Information: When you fill out a "Contact Us," "Request a Demo," or similar form, or communicate with us directly, we collect information such as your full name, business email, phone number, company name, and job title.
  • Client Onboarding Data: During the establishment of a business relationship, we may collect due diligence information about key personnel and beneficial owners of our client companies to fulfill our legal and regulatory obligations.
  • Correspondence: We keep records of our communications with you, including emails and meeting notes.
B. Information We Collect Automatically
  • Technical and Usage Data: We automatically collect certain information when you visit our website, including your IP address, browser type and version, device identifiers, operating system, and referring URLs. We also collect data about your interaction with our site, such as pages viewed and links clicked, primarily through cookies.
C. Information From Other Sources
  • We may obtain information from other sources, such as professional networking sites (e.g., LinkedIn), public databases, and joint marketing partners to identify potential business opportunities and enrich our understanding of our clients.

4. How We Use Your Information and Our Legal Basis

We process your B2B personal information for the purposes and on the legal bases set out in the table below, in compliance with GDPR and other major data protection frameworks.

Processing Purpose Categories of Personal Data Used Legal Basis (under GDPR)
To Respond to Inquiries and Provide Services Contact Information, Professional Information, Correspondence Legitimate Interest (to respond to your business inquiries and grow our business).
To Manage Business Relationships and Fulfill Contracts Contact Information, Professional Information, Client Onboarding Data, Correspondence Performance of a Contract (to fulfill our obligations to your company under our service agreements).
For B2B Marketing and Communications Contact Information, Professional Information Consent (where you have opted-in to receive marketing) or Legitimate Interest (to inform our clients about our services, with a clear opt-out).
To Improve and Secure our Website Technical and Usage Data Legitimate Interest (to ensure our website is functional, secure, and user-friendly).
To Comply with Legal and Regulatory Obligations Client Onboarding Data, Contact Information Legal Obligation (to perform necessary due diligence on our business partners as required by gaming authorities).

5. When and With Whom We Share Your Information

We do not sell the personal data of our business contacts. We may share your information in the following specific situations:

  • Service Providers: We share information with third-party vendors who perform services on our behalf, such as CRM platform providers, cloud hosting services (built on a cloud-based architecture as per our business plan), and marketing automation tools.
  • Legal and Regulatory Purposes: We may disclose information to respond to legal processes, government inquiries, or to regulatory bodies like the Tobique Gaming Commission, and to protect our rights and interests.
  • Business Transfers: In the event of a merger, sale of company assets, or other corporate transaction, your information may be transferred as a business asset.
  • Corporate Affiliates: We may share your information with our corporate affiliates, who are required to adhere to this policy.

6. International Data Transfers

Your information may be transferred to, stored, and processed in countries other than your own. We take necessary measures to protect your information in accordance with this Privacy Policy and applicable law. Where we transfer data outside of jurisdictions like the EEA or UK, we implement appropriate safeguards such as Standard Contractual Clauses (SCCs) to ensure your data remains protected.

7. How Long We Keep Your Information

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (e.g., for tax, accounting, or other legal requirements).

8. How We Keep Your Information Safe

We are committed to protecting your information through a system of robust organizational and technical security measures. In line with our technology and security commitments, these measures include:

  • Encryption: All partner and user data is stored with AES-256 encryption and transmitted via secure protocols such as TLS 1.3.
  • Access Control: We enforce Role-Based Access Control (RBAC) to ensure that access to personal data is restricted to authorized personnel on a "need-to-know" basis.
  • Regular Audits: We conduct regular security audits and vulnerability scans to ensure the robustness of our systems.

9. Your Privacy Rights and Choices

Depending on your location, you may have the following rights regarding your personal data:

  • Right to Access: To request a copy of the personal information we hold about you.
  • Right to Rectification: To request that we correct any inaccurate information.
  • Right to Erasure (Right to be Forgotten): To request that we delete your personal data.
  • Right to Restrict Processing: To request that we temporarily suspend the processing of your data.
  • Right to Object: To object to our processing of your data based on our legitimate interests.

To exercise these rights, please contact us at [email protected]. We will respond to your request in accordance with applicable data protection laws.

Opting out of Marketing: You can unsubscribe from our B2B marketing communications at any time by clicking the "unsubscribe" link in the emails we send.

10. Updates to This Policy

We may update this Privacy Policy from time to time to stay compliant with relevant laws. When we make changes, we will revise the "Last Updated" date at the top of this policy. We encourage you to review it frequently.

11. How to Contact Us

If you have any questions or comments about this Privacy Policy or our privacy practices, please contact us at:

Email: [email protected]