by Lush Drive
31/05/18

Your privacy is important to us and we are fully committed to protecting your personal info. We’re never gonna give you up, never gonna let you down, never gonna run around and desert you. Gotta make you understand why we collect your personal info, how we use it and what your rights are when you’re using our website. So here it is.


If you’re not okay with the statements contained within this Privacy Policy, that’s cool, just don’t proceed any further. If you do, keep in mind that registering an account on our website, placing bets and transferring funds will be deemed confirmation of your full agreement with our T’s & C’s and this Privacy Policy.


You can stop using the website at any time, obviously. However, even if you do, we may still be legally required to retain some of your personal info (because gambling).


We may periodically make changes to this Privacy Policy and will notify you of these changes by posting the new terms on our platforms. Check it out once in a while if you’d like, although realistically, we kind of know you won’t.

Who’s Lush Drive & where’s your info kept

 

“Lush Drive”, “we”, “our” and “us” relates to Silky Pearl Ltd, a limited liability company, registered in Malta with company number 126922, having its registered address at Emancipatie Boulevard 29, Malta. Your information is held by us on servers based in Costa Rica and elsewhere from time to time.

Ask away

 

If you have concerns or would like any further information about how Lush Drive handles your personal information, you can contact our Data Protection Officer at dpo@LushDrive.com

What we know about you

 

We probably know where you live

 

You provide “personally identifiable information” to us in the process of setting up an account, placing bets and using the services of the website. This stuff is required to give you access to certain parts of our website and related services. This data is collected when you:

  • Register an account with Lush Drive;
  • Voluntarily provide it when using the website;
  • Personally disclose the information in public areas of the website;
  • Provide it when you contact our customer support team.


This includes your:

  • Username;
  • First and last name;
  • Date of birth;
  • Email address;
  • Residential address;
  • Phone number;
  • Billing address;
  • Identification documents;
  • Proof of address documents;
  • Transaction history;
  • Website usage preferences;
  • Any other info you provide us when using our platforms;
  • Credit/debit card details, or other payment info.


This is also required for billing purposes and to protect kids (as described here, kids shouldn’t be using this website). You can amend and update this information by reaching out to customer support. This data is for internal use only and is never passed to any third parties except those stated below.

Creepy behavior stuff

 

You know the saying, the best place to hide a dead body is page 2 of Google’s search results. That’s why we strive to make our website as user friendly as possible and easy to find on the internets.

 

Lush Drive collects data on how you use the site, which doesn’t identify you personally, but helps us figure out what ‘people’ are up to. We probably put you in big buckets called ‘segments’ and ‘personas’ and may even have found imaginary names for you so we can ‘humanize’ all this anonymous data. I mean, let’s be honest, it’s pretty boring to work for ungrateful numbers. Aside from that, we’re pretty healthy people though.

Now that we’ve got you worried, here’s an example. When you interact with our services, our servers keep an activity log that’s unique to you and collects certain administrative and traffic information. Stuff like source IP address, time of access, date of access, web page(s) visited, language used, software crash reports (ideally none) and type of browser used. That’s pretty important stuff for us to be able to provide our services, but nothing that should keep you up at night.

Cookies are better when shared

 

Lush Drive uses cookies to ensure our website works efficiently and to enhance your visits. Further information can be found in our Cookie Policy (we just had to call it that).

How and why we use your personal information

 

We use your personal info in a range of ways that fall into four categories:

  • To provide you with the products & services you asked for;
  • To meet our legal or regulatory obligations;
  • To monitor our website performance;
  • To provide you with marketing information.


Your rights over your personal info differ according to which category and lawful basis these fall into. Don’t worry though, we’ll explain all of it in a sec.

Providing products and services

 

This one’s pretty straight forward. We use your info so you can use our website. This covers the essential activities required in order for us to provide you with the services you use or have signed up for. To set up your account, participate in the online casino and to provide you with customer service assistance.


Again, if you don’t want your data used in this way, cool, just don’t use our services and close your account. No hard feelings.


Also, to provide our products and services, we’ll sometimes share your info with external companies working on our behalf. More on that later.

The legal stuff

 

This is boring but important stuff so bear with us. We will use your ID documents and/or proof of address to check your details so we can protect our members from fraudulent behavior and promote responsible gambling.

 

We can conduct a security review at any time to validate the registration data you provided and to verify your use of our services. We can also check your financial transactions for potential breach of our T’s & C’s and of applicable law.

 

These security reviews can include (but are not limited to) ordering a credit report and/or otherwise verifying the info you provide against third-party databases.

 

We’re required to carry out these activities to provide our products and services legally and responsibly. We can’t provide you with our services without carrying out these activities, so, again, if you don’t want your info used in this way, it’s best if you just close your account. We’re not insisting because we don’t want you here, really, it’s just how things work around here, and we gotta make it fair for everyone. Sorry.

Making sure the website’s doing alright

 

Who doesn’t love cookies?! As mentioned before, we use cookies and traffic analysis to improve the performance of our website and services. We have a legitimate interest in doing this and we do care about your privacy, so we’re doing our best to minimize the impact on your data.

 

You have the ‘right to object’ to activities carried out for our legitimate interest if you think your right to privacy outweighs our legitimate business interests. That being said, since this is quite central to our business, if you want to object further than managing your cookies, this could mean you’ll have to close your account.

Marketing

 

If you’ve given us consent to do so, we’ll send you offers and promotions via email, SMS and/or online. We don’t share your info with third parties for them to use for their own marketing. We’ll only do so if they provide us with a service for which you gave express consent.

 

You have the right to withdraw your consent or update your marketing preferences at any time, of course, so feel free to do so.

Your rights

 

Your rights to rectification

 

If you think the personal info we hold on you is incorrect, you have the right for it to be rectified. For any info that cannot be updated through your Profile, feel free to reach out to support@LushDrive.com

 

Your right to request a copy of your personal info

 

If you’d like to get a copy of the personal info we hold about you, ask live chat or email dpo@LushDrive.com and we’ll provide you with a form to complete. The form isn’t compulsory but it helps us provide you with the info you’re looking for in a reasonable time frame.

 

To ensure the security of your personal info, we’ll ask you for a valid ID, and once we’ve received it, we’ll provide our response within a month. If your request is unusually complex and likely to take longer than that, we’ll let you know as soon as we can and give you an approximate time frame.  

Your right of erasure

 

Oh boy, who has never wished this was also a thing IRL, amirite! Seriously though, this is a weird one. You can request us to erase your personal data where there’s no compelling reason to continue processing. This only applies in certain circumstances, so it’s not a guaranteed or absolute right.

 

For instance, regulators ask that we keep some stuff about you, so it is possible we can’t satisfy you both. Actually, as confusing as this sounds, the right to erasure doesn’t apply in a number of cases. To name a few: if processing is necessary to exercise the right of freedom of expression and information, to comply with a legal obligation, for the performance of a task carried out in the public interest or in the exercise of official authority, for achieving purposes in the public interest, scientific research, historical research or statistical purposes where erasure is likely to render impossible or seriously impair the achievement of that processing, or for the establishment, exercise or defence of legal claims. Thanks, GDPR.

 

Sharing your personal info

 

As mentioned above, there are some cases where we may disclose your personal data to third parties.

 

  • if we are under a duty to disclose or share your personal information to comply with any legal or regulatory obligation;
  • to enforce or apply the terms of this policy or any other agreements;
  • to assist us in providing you with the products and services you request, including but not limited to third party software providers;
  • if, in our sole determination, you are found to have cheated or attempted to defraud us (not cool), or other users of the service in any way including but not limited to game manipulation or payment fraud;
  • for the purpose of research on the prevention of addiction (this data will be made anonymous, but still);
  • to protect the rights, property or safety of us, our members or others; and
  • where we have received your permission for us to do so.

 

Personal info collected on the services may be stored and processed in any country in which we or our affiliates, suppliers or agents maintain facilities. By using our services, you expressly consent to any transfer of information outside of your country.

 

When we transfer any part of your personal data, we will take reasonable steps to ensure that it is treated as securely as it is within Costa Rica where our servers are located.  

Security

 

Security matters on the Internet, we’re very well aware. That’s why we store all of the personal information we receive directly from you in an encrypted and password protected database residing within our secure network behind active state-of-the-art firewall software.

 

Our services support SSL Version TLS 1.2 with 128-bit encryption. We also take measures to ensure our subsidiaries, agents, affiliates and suppliers employ adequate security measures.

Retention

 

We retain personal info for as long as we reasonably require it for legal or business purposes. In determining data retention periods, Lush Drive takes into consideration local laws, contractual obligations, and the expectations and requirements of our members. When we no longer need your data, we securely delete or destroy it.

Third-party practices

 

If you’ve ever browsed the web, this will sound obvious, but we gotta get this out of the way. We can’t ensure the protection of any info you provide to a third-party site that links to or from our services or any info collected by any third party administering our affiliate program or any other program, since these third-party sites are owned and operated independently from us. Any info collected by these third parties is governed by the privacy policy, if any, of such third party.

Also, our website may contain links to other websites, which are outside our control and are not covered by this privacy policy. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours. We are not responsible. I mean, come on. We can’t be. Also, climate change’s not our fault, and neither are the results of the elections. Solely the operators of these websites shall be responsible for their functionality or possible errors so please, go ask them to fix it.

Analytics

 

This is where we list the services we use to allow us to monitor and analyze web traffic and which can be used to keep track of user behavior (the creepy stuff from above).

Google Analytics (Google Inc.)

 

In case you’ve been living under a rock, Google Analytics is a web analysis service provided by Google Inc. (Google, Alphabet, whatever they call themselves these days). Google uses the data collected to track and examine the use of Lush Drive, to prepare reports on its activities and share them with other Google services.


Google may use the data collected to contextualize and personalize the ads of its own advertising network.

 

Personal Data collected: Cookies and Usage Data

 

Place of processing: US-Privacy Policy-Opt out

Disclaimer

 

Our services operate “as-is” and “as-available” without liability of any kind. We are not responsible for events beyond our direct control. Due to the complex and ever-changing nature of our technology and business, we can’t guarantee, nor do we claim that there will be error-free performance regarding the privacy of your personal info and we won’t be liable for any indirect, incidental, consequential or punitive damages relating to the use or release of said personal information.


Version 1.1 dated 30/08/2018