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Introduction
This Privacy Policy (the “Policy”) explains how 3-102-960253 SRL (the “Company”, “we”, “us”, “our”) collects, uses, discloses, retains and otherwise processes personal data when you access or use the website https://ludivion.com (the “Website”) and any related or connected services (together, the “Service”).
The Company is a limited liability company registered in Costa Rica under company registration number 3-102-960253, with registered address at Provincia 06 Puntarenas, Canton 11 Garabito, Jaco, East Side of the Municipality Garabito, Costa Rica. The Company is licensed and regulated by Anjouan Licensing Services Inc. (operating as Anjouan Gaming), the competent licensing and supervisory authority acting on behalf of the Autonomous Island of Anjouan under the oversight of the Anjouan Offshore Financial Authority (AOFA), pursuant to the Computer Gaming Licensing Act 007 of 2005.
This Policy should be read alongside our Terms and Conditions, KYC and AML/CTF Policy, Responsible Gaming Policy and Cookie Notice. Capitalised terms used but not defined in this Policy have the meaning given to them in our Terms and Conditions.
Data Controller
For the purposes of applicable data-protection laws, the data controller in respect of personal data processed under this Policy is 3-102-960253 SRL. You may contact us in respect of this Policy at the addresses set out in Section 16 below.
Personal Data We Collect
The categories of personal data we collect depend on how you interact with the Service. They include the following.
3.1 Registration data (Customer Due Diligence)
In line with the AML & CTF Code of Conduct for Anjouan Internet Gaming Operators, no Account is activated unless you provide, at a minimum:
- Your full legal name;
- A valid email address;
- Your date of birth;
- Your residential address.
You will also create a password, accept our Terms and Conditions and this Policy, and confirm that you are at least 18 years of age.
3.2 Enhanced Due Diligence (KYC) data
Where required under our KYC and AML/CTF Policy (for example, upon any first withdrawal request, when aggregate lifetime deposits reach the applicable threshold established by the Company in accordance with AML requirements, or where elevated risk indicators are identified, or at the Company's discretion at any time), we will additionally collect some or all of the following:
- A copy of a valid government-issued photo identification document (e.g. passport, national ID card or driving licence — front and back where applicable);
- A selfie or liveness/identity confirmation, where requested by the Company;
- A recent utility bill or equivalent document confirming your residential address;
- Where required on a risk-based assessment, evidence of source of funds and/or source of wealth (such as payslips, bank statements, tax documents or sale-of-asset documents).
This category may contain sensitive identifiers (for example, identification-document numbers and images). We process this data because we are legally obliged to do so under the AML/CTF framework that applies to our licence.
3.3 Account, transaction and gameplay data
- Account information (username, hashed password, account status, language and currency preferences, communications preferences);
- Financial transactions (deposits, withdrawals, bonuses, balances, payment method identifiers in masked form);
- Gameplay data (bets placed, games played, wins/losses, session times and durations, use of Reality Checks);
- Use of Responsible Gaming tools (deposit, loss and time limits, cooling-off periods, self-exclusion status, self-assessment outcomes).
3.4 Behavioural-monitoring data
As required by the License Conditions and our Responsible Gaming Policy, we analyse player activity to identify and prevent play by potentially vulnerable individuals. This includes monitoring deposit patterns, session duration, betting behaviour, withdrawal cancellations and engagement with self-assessment tools.
3.5 Device, technical and location data
- IP address, approximate geolocation derived from IP, country/region;
- Device identifiers, operating system, browser type and version, language settings, time zone;
- Log data (date, time, pages viewed, referring URL, error logs);
- Authentication data (login timestamps, two-factor-authentication events, security alerts).
We use this data, among other things, to operate effective GEO-IP blocking and to prevent access from prohibited jurisdictions, as required by the License Conditions issued by Anjouan Licensing Services Inc. (operating as Anjouan Gaming).
3.6 Communications data
- Customer support correspondence (emails, support tickets, attachments);
- Complaints submitted to us or escalated through Alternative Dispute Resolution (ADR);
- Marketing preferences and opt-in/opt-out records.
3.7 Data we receive from third parties
- Identity, sanctions, politically-exposed-person (PEP) and adverse-media screening results from KYC/AML service providers;
- Payment authorisation and risk-score data from payment processors and acquirers;
- Fraud-prevention indicators (e.g. device fingerprinting, velocity checks);
- Information from affiliates that referred you, where applicable.
Purposes of Processing and Legal Bases
We process personal data only where we have a lawful basis to do so. The principal purposes and corresponding bases are summarised below.
- Performance of the contract — creating and operating your Account, processing deposits and withdrawals, settling bets, responding to support requests and providing the Service in accordance with our Terms and Conditions.
- Compliance with legal and regulatory obligations — age verification, CDD/EDD, sanctions and PEP screening, transaction monitoring, Suspicious Activity Reports, Currency Transaction Reports, record keeping, regulatory reporting and cooperation with Anjouan Licensing Services Inc. (operating as Anjouan Gaming), AOFA and other competent authorities.
- Legitimate interests — preventing and detecting fraud, collusion, multi-accounting, abuse of bonuses, network security, debugging and improvement of the Service, defence of legal claims, and internal management and audit. Where we rely on legitimate interests we balance them against your rights and freedoms.
- Public interest / player protection — behavioural monitoring and Responsible Gaming interventions, including (where necessary) operator-initiated exclusion to protect players who show signs of harmful play.
- Consent — direct marketing communications (e.g. promotional emails), optional analytics and non-essential cookies, and any other processing for which we expressly request your consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.
Marketing Communications
Where you have given consent, or where applicable law otherwise permits, we may send you marketing communications about the Service. Every marketing email contains a clear unsubscribe link, and you may also opt out at any time by contacting Customer Support or by adjusting your communication preferences in your Account.
Consistent with our Responsible Gaming Policy, if you activate any Responsible Gaming tool (including a deposit, loss or time limit, Reality Checks, cooling-off or self-exclusion), you are immediately removed from all marketing communications for the duration of that restriction. Marketing will not resume automatically upon the expiry of the restriction; you must actively opt in again.
We do not market to, advertise in, or onboard players from any jurisdiction listed as a Restricted Jurisdiction in our Terms and Conditions and KYC and AML/CTF Policy.
Cookies and Similar Technologies
We use cookies and similar technologies (such as pixels, local storage and SDKs) on the Website. Some cookies are strictly necessary to make the Service function (for example, to keep you logged in and to remember your language). Others are used, with your consent where required, for analytics, performance measurement and marketing.
Detailed information on the cookies we use, their purposes and retention periods, and the choices available to you, is set out in our separate Cookie Notice on the Website. You can manage cookie preferences at any time through the cookie banner or your browser settings.
Disclosure of Personal Data
We do not sell your personal data. We share personal data only as set out below and only to the extent necessary.
7.1 Service providers (processors)
We share personal data with carefully selected service providers acting on our behalf and under written agreements that impose appropriate confidentiality, security and data-protection obligations. These include:
- Payment processors and acquirers (to authorise and reconcile deposits and withdrawals);
- KYC, identity-verification, sanctions/PEP screening and fraud-prevention providers;
- Cloud-hosting, data-storage and IT-security providers;
- Communications and customer-support tooling providers;
- Independent testing laboratories approved by Anjouan Licensing Services Inc. (operating as Anjouan Gaming) (for game certification);
- B2B platform and game-content suppliers that hold a valid Anjouan B2B Licence or recognition certificate;
- Independent auditors performing the annual AML audit and other regulatory audits.
7.2 Regulators and law enforcement
We disclose personal data to Anjouan Licensing Services Inc. (operating as Anjouan Gaming), AOFA, financial intelligence units, tax authorities, law-enforcement agencies and other competent authorities where we are required or permitted to do so by law, including for the purposes of Suspicious Activity Reports, Currency Transaction Reports, sanctions compliance, court orders and regulatory investigations.
7.3 ADR provider
Where a complaint is escalated to Alternative Dispute Resolution under our Terms and Conditions, we will share with our designated independent ADR provider — currently EGIS ADR (egis-adr.com), approved by Anjouan Licensing Services Inc. (operating as Anjouan Gaming) — the personal data necessary to investigate and resolve the dispute. This may include account information, transaction history, correspondence and any documents relevant to the complaint. ADR participation is at the Company's cost.
7.4 Corporate transactions
We may disclose personal data to actual or prospective purchasers, investors or advisers in connection with any sale, merger, reorganisation or financing involving the Company, subject to appropriate confidentiality undertakings.
International Transfers
The Company operates internationally. Personal data may be transferred to, and processed in, countries outside your country of residence, including jurisdictions whose data-protection laws may differ from those of your home country. Where we transfer personal data internationally, we put in place appropriate safeguards, such as contractual protections with our service providers, encryption in transit, and restrictions on onward transfer.
Data Retention
We retain personal data only for as long as is necessary for the purposes for which it was collected, including any legal, regulatory, tax, accounting or reporting requirement.
- AML/CTF and KYC records — retained for a minimum of five (5) years from the end of the customer relationship or from the date of the relevant transaction, whichever is later, in line with our KYC and AML/CTF Policy.
- Age-verification records — retained for a minimum of five (5) years for regulatory review, in line with our Responsible Gaming Policy.
- Self-exclusion and Responsible Gaming records — retained for a minimum of five (5) years.
- Account and transaction records — retained for the life of the Account and for at least five (5) years after closure.
- Marketing records — opt-in and opt-out records retained as long as necessary to evidence your preferences.
- Customer support and complaint records — retained for as long as necessary to respond to the matter and to defend legal claims.
Where longer retention is required by law (for example, by tax, accounting or AML legislation), we will retain the data for the longer period. After the applicable retention period ends, we securely delete or anonymise personal data.
Security
We implement appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful processing, accidental loss, destruction, damage, alteration or disclosure. These measures include:
- SSL/HTTPS encryption of personal data in transit;
- Encryption at rest of sensitive data, including KYC documents;
- Role-based access controls and the principle of least privilege;
- Two-factor authentication (2FA) available to all players for Account access;
- Firewalls, intrusion-detection systems and anti-malware controls;
- Regular vulnerability scanning and penetration testing;
- Staff training on data protection, AML/CTF and information security;
- Incident-response procedures, including business-continuity and disaster-recovery planning.
Despite these measures, no method of transmission over the internet or method of electronic storage is fully secure. You also have a role to play in protecting your data by keeping your password confidential, enabling 2FA, avoiding shared devices and notifying us immediately if you suspect any unauthorised access to your Account.
Data Breach and Cybersecurity Incident Reporting
In accordance with the Code of Conduct for Anjouan Internet Gaming Operators, the AML & CTF Code of Conduct and the Website Compliance Guide issued by Anjouan Licensing Services Inc. (operating as Anjouan Gaming), the Company reports cybersecurity incidents that may affect the integrity or confidentiality of player data, or the security of the Service, to Anjouan Licensing Services Inc. (operating as Anjouan Gaming) within 24 hours of detection. Where required by applicable law, we will also notify affected players and other competent authorities without undue delay.
Your Rights
Subject to applicable law, you have the following rights in respect of your personal data:
- Access — to obtain confirmation of whether we process personal data about you and, if so, a copy of that data.
- Rectification — to request correction of inaccurate or incomplete personal data.
- Erasure — to request deletion of your personal data where there is no overriding legal basis for us to keep it. Please note that, because of our legal and regulatory obligations under the AML/CTF framework, the License Conditions and applicable law, we are required to retain certain categories of data (including identification documents and transaction records) for a minimum of five (5) years, and we cannot delete these earlier.
- Restriction — to request restriction of processing in certain circumstances.
- Portability — to receive certain personal data you provided to us in a structured, commonly used and machine-readable format, and to ask us to transmit that data to another controller.
- Objection — to object, on grounds relating to your particular situation, to processing based on legitimate interests, and to object at any time to processing for direct marketing.
- Withdraw consent — to withdraw your consent, at any time, for any processing based on consent (including marketing), without affecting the lawfulness of prior processing.
- Lodge a complaint — to lodge a complaint with the competent data-protection authority in your jurisdiction. We would, however, appreciate the opportunity to address your concerns first by contacting us at the addresses in Section 16.
You may also request access to your transaction and gaming history, which will be provided within a reasonable timeframe in accordance with applicable requirements and as set out in our Responsible Gaming Policy.
To exercise any of your rights, please contact us using the details in Section 16. We may need to verify your identity before responding (for example, by requesting confirmation from your Registered Email Address). We will respond to your request within the timeframes required by applicable law.
Children
The Service is strictly limited to adults aged 18 or over, or such higher minimum age as may be required by the law applicable to you. We do not knowingly collect personal data from minors. If we discover that an Account has been opened by a minor, the Account will be closed in accordance with our Terms and Conditions and Responsible Gaming Policy, and we will retain only such records as we are required by law to retain. If you believe a minor has provided us with personal data, please contact us immediately using the details in Section 16.
Automated Decision-Making and Behavioural Profiling
We use automated tools to detect patterns of potentially problematic play (Responsible Gaming monitoring), and to detect fraud, multi-accounting, structuring and other suspicious activity (AML/CTF monitoring). Outcomes of these automated tools that have a significant effect on you — for example, the imposition of operator-initiated limits, account suspension, or filing of a regulatory report — are reviewed by trained Company personnel before any final decision is taken. You have the right to obtain meaningful information about the logic involved in such processing and to contest decisions through our complaints procedure (see our Terms and Conditions).
Changes to this Policy
We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements or regulatory expectations. The most recent version will always be available on the Website, and the “Last updated” date at the top of this Policy will be revised. Where the changes are material, we will provide you with additional notice (for example, by email to your Registered Email Address or by a prominent notice on the Website) before they take effect.
Contact Us
If you have any questions, comments or requests in relation to this Policy or to the way we handle your personal data, please contact us at:
- Email: privacy@ludivion.com
- Postal address: 3-102-960253 SRL, Provincia 06 Puntarenas, Canton 11 Garabito, Jaco, East Side of the Municipality Garabito, Costa Rica.
For Responsible Gaming queries, please contact responsiblegaming@ludivion.com. For general customer support, please use the contact form available on the Website.