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Privacy Policy

This Privacy Policy explains how your personal data is collected, used, stored, and shared when you visit and use the Luna brand website at lyna-uk.com and related online gambling services operated under the Luna project. It applies to all website visitors, registered players, and anyone who contacts us through our services in Great Britain. By registering an account, using our games, or otherwise interacting with lyna-uk.com, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is effective from 1 January 2026, and it complements (but does not replace) our Terms and Conditions and Bonus Policy available on lyna-uk.com.

Who We Are

For the purposes of applicable data protection laws in the United Kingdom (including the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018), the data controller responsible for your personal data when you use the Luna brand at lyna-uk.com is:

  • Controller: SkillOnNet Ltd (“SkillOnNet”, “we”, “us”)
  • Brand / project: Luna brand for Great Britain operated under the Luna project at https://lyna-uk.com
  • Registered office / legal address: Office 1/5297 Level G, Quantum House, 75 Abate Rigord Street, Ta' Xbiex XBX 1120, Malta
  • Legal entity type: Limited liability company (Ltd), incorporated in Malta and registered with the Malta Business Registry
  • Gambling licence (Great Britain): SkillOnNet Ltd is licensed and regulated by the UK Gambling Commission under account number 39326 to provide remote casino and general betting services to players in Great Britain. Details of the licence are publicly available on the UK Gambling Commission register.

SkillOnNet Ltd operates the Luna brand for Great Britain on the SkillOnNet platform. When you use lyna-uk.com, SkillOnNet Ltd determines the purposes and means of processing your personal data and is therefore the controller.

We have appointed an internal function responsible for data protection compliance for the Luna project.

  • Data Protection Officer (DPO) / Privacy Contact: Data Protection Officer, SkillOnNet Ltd
  • Email (primary contact for privacy matters): privacy@lyna-uk.com
  • Postal contact (for privacy correspondence): Data Protection Officer, SkillOnNet Ltd, Office 1/5297 Level G, Quantum House, 75 Abate Rigord Street, Ta' Xbiex XBX 1120, Malta

If you have any questions about this Privacy Policy or our data protection practices, including requests to exercise your rights, you can contact us using the details above.

What Personal Data We Collect

We collect and process different categories of personal data depending on how you interact with lyna-uk.com and the Luna brand services. Some data is provided directly by you, some is generated by your use of our services, and some is obtained from third parties (for example, payment providers and identity verification services).

Identification and Contact Data

  • Basic identity data: first name, last name, username, date of birth, gender (where provided).
  • Contact details: email address, residential address, country of residence, postcode, and telephone number (where provided or required for verification or responsible gambling purposes).
  • Verification data: copies or details of identity documents (such as passport, national ID card, driving licence), proof of address (utility bills, bank statements), and other KYC (Know Your Customer) documents required under UK gambling and AML regulations.

Account, Gameplay and Behavioural Data

  • Account information: account ID, registration date, account status, login history, language preferences, communication preferences (including marketing consents and opt-outs).
  • Gameplay data: game sessions, games played, stake sizes, wins and losses, betting patterns, game errors or crashes, bonus usage, tournament participation and leaderboard positions.
  • Responsible gambling data: self-exclusion status, time-outs, deposit limits, reality checks, affordability assessments, and interactions relating to safer gambling.
  • Behavioural and interaction data: clicks, navigation paths, pages viewed, session duration, interaction with banners and offers, responses to messages and promotions.

Technical and Device Data

  • Device and browser information: IP address, device identifiers, operating system, browser type and version, screen resolution, language settings.
  • Log data: access times and dates, pages requested, HTTP response codes, crash logs, error reports, and other diagnostic information generated by our systems.
  • Network data: approximate location derived from IP address (for example, to confirm you are located in Great Britain), connection provider, and general network performance information.

Payment and Financial Data

  • Payment details: masked card details (for example, last four digits), card type, expiration date, and failure codes, as processed by our payment service providers.
  • Transaction data: deposits, withdrawals, bonus credits, wagering requirements, applied fees, refunds, chargebacks, and related communication.
  • Source of funds / affordability information: where required by law or regulator guidance, we may collect information such as employment status, income range, or financial documents to support affordability and anti-money laundering checks.

Communications and Support Data

  • Customer support records: transcripts of live chats, emails, and internal notes concerning your queries, complaints, responsible gambling interactions, and technical support requests.
  • Call recordings: where we provide telephone support and clearly inform you that calls are being recorded for quality and compliance purposes.
  • Marketing communications: records of newsletters and offers sent to you, open and click rates (where legally permitted), and your preferences regarding email, SMS, push notifications, and on-site messages.

Cookies and Similar Technologies

  • Cookies: small text files stored on your device when you visit lyna-uk.com, including strictly necessary, functional, analytics, and advertising cookies.
  • Similar technologies: tracking pixels, tags, SDKs, and local storage used to recognize your browser or device, maintain your session, and measure performance.

More detail about our use of cookies and similar technologies is provided in the “Cookies & Tracking Technologies” section below.

Legal Basis for Processing

Under the UK GDPR, we must have a lawful basis to process your personal data. Depending on the specific processing activity, we rely on one or more of the following legal bases:

  • Performance of a contract: We process personal data that is necessary to enter into and perform the contract we have with you (our Terms and Conditions), including:
    • creating and managing your player account at lyna-uk.com;
    • verifying your identity and eligibility to gamble legally in Great Britain;
    • processing deposits, bets, game outcomes, and withdrawals;
    • providing customer support and handling routine queries;
    • implementing bonus and loyalty programmes that you participate in.
  • Compliance with legal obligations: We process certain data because we are required to do so by law or regulation, including:
    • UK gambling legislation and UK Gambling Commission (“UKGC”) licence conditions and codes of practice;
    • anti-money laundering (“AML”) and counter-terrorist financing laws (for example, customer due diligence, record retention and transaction monitoring);
    • responsible gambling obligations and social responsibility codes;
    • taxation, accounting, and statutory reporting requirements;
    • responding to lawful requests from competent authorities and regulators.
  • Legitimate interests: We may process your personal data where necessary for our legitimate interests or those of a third party, provided these interests are not overridden by your rights and freedoms. These interests include:
    • maintaining and improving the security and integrity of our platform and services;
    • preventing, detecting, and investigating fraud, abuse, and collusion;
    • protecting our business and users from cybersecurity threats;
    • developing and improving our products, games, and user experience;
    • performing internal analytics, reporting and business planning;
    • defending, exercising, or establishing legal claims.
    Where we rely on legitimate interests, we balance our interests against your privacy rights and implement safeguards (such as data minimisation and access controls).
  • Consent: In some cases we rely on your consent, which you can withdraw at any time, including:
    • sending you direct marketing communications by email, SMS or other electronic means that are not strictly necessary for providing our services;
    • using certain non-essential cookies and similar technologies (for example, for advertising and detailed analytics) as described in our cookie information;
    • sharing data with certain advertising and affiliate partners for personalised marketing where this is not based on our legitimate interests.
    Where we rely on consent, we will ask you to take a clear affirmative action (for example, ticking a box or adjusting cookie settings) and you can change your preferences at any time.
  • Vital interests: In rare situations, we may process personal data to protect the vital interests of you or another person; for example, where we believe there is an imminent risk of serious harm and we need to contact appropriate services.

Purpose of Processing

We use your personal data for clearly defined purposes that are compatible with our role as a licensed remote gambling operator. These purposes include:

  • Providing and operating our services: To register and manage your account, verify your identity and age, enable deposits, gameplay and withdrawals, provide customer support, and ensure that you can use the Luna brand services at lyna-uk.com in accordance with our Terms and Conditions and applicable law.
  • Compliance and risk management: To meet our legal and regulatory obligations (including UKGC licence conditions and AML/CTF requirements), perform affordability and source-of-funds checks, monitor transactions for suspicious activity, and maintain records as required by law.
  • Responsible and safer gambling: To identify patterns of potentially harmful gambling, to apply and manage self-exclusion and other responsible gambling tools, and to interact with you about safer gambling measures where necessary.
  • Service improvement and analytics: To analyse how players use lyna-uk.com and our games, measure performance, fix bugs, optimise user journeys, and develop new features, games, promotions, and security controls.
  • Marketing and personalisation: With your consent or where permitted by law, to send you marketing messages, promotions, and newsletters relating to Luna and our services, to personalise offers and content, and to measure the effectiveness of campaigns.
  • Security and fraud prevention: To ensure the security of our platform and systems, prevent and investigate fraud, account takeovers, collusion, money laundering, bonus abuse, and other prohibited activities.
  • Handling queries and disputes: To respond to your questions and complaints, manage disputes and chargebacks, cooperate with alternative dispute resolution (ADR) bodies such as eCOGRA, and defend or pursue legal claims.
  • Administrative and business operations: To perform internal audits, reporting, accounting, and business planning, including the management of our relationship with suppliers, affiliates, and white-label partners.

Disclosure & Sharing

We do not sell your personal data. However, we do share it with carefully selected third parties where this is necessary for the operation of lyna-uk.com, to comply with legal obligations, or where you have provided your consent. These third parties process your data only on our instructions or where they act as independent controllers under applicable law.

  • Payment service providers and banks: To process deposits, withdrawals, refunds and chargebacks, and to conduct payment-related fraud prevention checks.
  • Platform and IT service providers: Companies providing hosting, cloud infrastructure, software development, maintenance, monitoring, security services, communication tools, and data analytics that support operation of the Luna brand on the SkillOnNet platform.
  • Identity verification and AML providers: Third parties assisting us in verifying your identity, age, address, and source of funds, and in screening against sanctions lists and politically exposed person (PEP) databases, as required by law and our UKGC licence.
  • Regulators, law enforcement and public authorities: The UK Gambling Commission, financial intelligence units, tax authorities, courts, police, and other competent authorities, where we are legally required or allowed to share data (for example, for investigations, reporting obligations or enforcement of our licence conditions).
  • Affiliates and marketing partners: Where you register via an affiliate or tracking link, we may share limited information necessary for attribution, reporting and payment of affiliate commissions. Where you have consented, we may also share data for personalised marketing and campaign measurement.
  • Alternative Dispute Resolution (ADR) bodies: When you escalate a gambling-related complaint to an ADR such as eCOGRA, we may share relevant account and transaction data to enable them to review and resolve your dispute.
  • Professional advisers: Lawyers, auditors, consultants, and other professional advisers who need access to data in the course of providing services to us and are bound by confidentiality obligations.
  • Corporate transactions: In connection with any actual or prospective merger, acquisition, sale of assets, or restructuring of SkillOnNet Ltd or the Luna brand, your data may be shared with relevant third parties subject to appropriate safeguards.

Where third parties act as our processors, we enter into written contracts that require them to process your personal data only on our documented instructions, to keep it confidential, and to implement appropriate security measures.

International Transfers

Because SkillOnNet Ltd is headquartered in Malta and uses global service providers, your personal data may be transferred and stored outside the United Kingdom, including in the European Economic Area (EEA) and in other countries. These transfers are necessary for providing you with our services at lyna-uk.com and for operating the Luna project.

  • Transfers within the UK and EEA: Data may be processed in the UK, Malta and other EEA states where our group companies, platform infrastructure, or certain service providers are located. The UK government has recognised the EEA as providing an adequate level of data protection.
  • Transfers to other countries: Some of our service providers (for example, certain cloud, security, or analytics providers) may be located outside the UK and the EEA, including in countries that do not have an adequacy decision from the UK government.
  • Safeguards: Where we transfer personal data to a country without an adequacy decision, we implement appropriate safeguards, such as:
    • the UK International Data Transfer Agreement (IDTA) or UK addendum to the EU Standard Contractual Clauses;
    • contractual commitments requiring recipients to protect your data to UK-equivalent standards;
    • technical measures (for example, strong encryption in transit and at rest, access controls, and minimisation of data shared);
    • where applicable, reliance on the UK extension to the EU-U.S. Data Privacy Framework for certified US-based providers.

You can obtain more information about the safeguards we use for international transfers, or request a copy of the relevant contractual protections (with commercially sensitive information redacted), by contacting us at privacy@lyna-uk.com.

Data Retention

We keep your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including to meet legal, regulatory, accounting, and reporting requirements. Because we operate in a regulated gambling environment, some retention periods are determined by law and by the UK Gambling Commission licence conditions.

As a general principle, we retain your core player account data and transactional records for up to five (5) years after your account is closed, unless a longer period is required or permitted by law (for example, due to ongoing investigations, disputes, or regulatory requests).

Category of data Typical retention period Retention rationale
Account and identification data (name, DOB, contact details, account ID) Up to 5 years after account closure Required for AML/CTF and gambling regulatory obligations, handling disputes and defending legal claims.
KYC and verification documents (ID, proof of address, source-of-funds) At least 5 years after the end of the business relationship or last transaction, subject to legal requirements Compliance with AML legislation and regulatory guidance.
Gameplay and transaction data Up to 5 years after account closure, or longer if necessary in case of disputes or investigations Evidence for audits, dispute resolution, and regulatory reporting.
Responsible gambling and interaction records Up to 5 years after account closure, subject to regulatory expectations Demonstrating compliance with safer gambling and social responsibility obligations.
Marketing preferences and communications logs While you have an active account and for up to 2 years after your last interaction, or until you withdraw consent / object Managing marketing preferences, proving compliance with consent requirements.
Technical logs and security data From several months up to 2 years, depending on the type of log Ensuring platform security, investigating incidents, and improving performance.
Customer support and complaint records Up to 5 years after resolution of the complaint Demonstrating handling of complaints, defending legal claims, and meeting regulatory expectations.

When data is no longer required for the purposes for which it was collected and there is no legal or regulatory requirement to retain it, we will securely delete, anonymise, or aggregate it so that it can no longer be associated with you. If you exercise your rights (for example, erasure), we may retain minimal information to demonstrate that we have acted on your request and to prevent future contact.

Your Rights

Under the UK GDPR and the Data Protection Act 2018, you have several rights in relation to your personal data. Where applicable, similar or additional rights may exist under other privacy laws, including Mexican data protection law. We explain these rights and how you can exercise them below.

  • Right of access: You can request confirmation as to whether we process your personal data and, if so, receive a copy of that data together with information about how we use it.
  • Right to rectification: You can ask us to correct inaccurate or incomplete personal data that we hold about you. In many cases, you can update basic account details directly in your lyna-uk.com account.
  • Right to erasure (“right to be forgotten”): You can request that we delete your personal data in certain circumstances, for example where it is no longer needed for the purposes for which it was collected, or where you withdraw consent and there is no other legal basis. This right is subject to important exceptions; for example, we may need to retain data to comply with AML and gambling regulations or to defend legal claims.
  • Right to restriction of processing: You can request that we restrict the processing of your data (for example, temporarily suspend use) in certain situations, such as while we verify the accuracy of the data or our grounds for processing.
  • Right to object: You can object to processing based on our legitimate interests, including profiling related to those interests. We will stop processing unless we have compelling legitimate grounds that override your interests, rights and freedoms, or where processing is necessary for legal claims.
  • Right to object to direct marketing: You can object at any time to the processing of your data for direct marketing, including profiling for marketing. If you do so, we will stop sending you marketing communications. You can use the “unsubscribe” links in emails or adjust your preferences in your account.
  • Right to data portability: In certain circumstances, you can ask to receive the personal data you provided to us in a structured, commonly used and machine-readable format, and to have that data transmitted to another controller where technically feasible.
  • Rights related to automated decision-making and profiling: Where we make decisions that produce legal effects or similarly significant effects for you based solely on automated processing (for example, certain fraud checks), you may have the right to obtain human intervention, to express your point of view, and to contest the decision.
  • Right to withdraw consent: Where we rely on your consent (for example, for marketing or non-essential cookies), you can withdraw that consent at any time. This does not affect the lawfulness of processing carried out before withdrawal.

Mexican privacy law alignment: If you are located in Mexico and interact with our services in circumstances where Mexican privacy law applies, you may also benefit from rights commonly known as ARCO rights (Acceso, Rectificación, Cancelación y Oposición) under Mexican data protection regulations. These broadly correspond to access, rectification, cancellation (erasure), and objection rights described above. We will consider and handle such requests in a manner consistent with both UK GDPR principles and applicable Mexican regulations, taking into account our legal and regulatory obligations as a UK-licensed gambling operator.

How to exercise your rights:

  1. Submit your request to our DPO or privacy contact at privacy@lyna-uk.com, or via any dedicated privacy interface that may be provided in your lyna-uk.com account.
  2. Provide sufficient information for us to identify you and your account (for example, username, registered email, and details of your request).
  3. We may ask for additional information to verify your identity before acting on your request, particularly where sensitive data or financial information is involved.

We will respond to your request without undue delay and in any event within one month (30 days) of receipt. In complex cases or where we receive multiple requests, this period may be extended by up to a further two months, in which case we will inform you of the extension and the reasons for it. As a rule, we handle rights requests free of charge, although we may charge a reasonable fee or refuse to act on unfounded, excessive, or repetitive requests as permitted by law.

Cookies & Tracking Technologies

When you visit lyna-uk.com, we use cookies and similar technologies to ensure the site functions correctly, to improve your experience, to analyse performance, and, where permitted, to deliver relevant advertising.

Types of Cookies We Use

  • Strictly necessary (session) cookies: These cookies are essential for the operation of our website and services. They enable core functions such as navigating secure areas, maintaining your login session, processing bets and payments, and keeping your account secure. Without these cookies, the site may not function properly.
  • Functional (persistent) cookies: These cookies allow the site to remember your choices and preferences over time, such as language settings, display preferences, and whether you have seen certain notifications. They help make your experience more convenient and personalised.
  • Analytics and performance cookies: These cookies collect information about how visitors use lyna-uk.com (for example, which pages are visited most often, and whether users get error messages). The data is typically aggregated and used to improve the performance, design, and usability of our services.
  • Advertising and targeting cookies: With your consent, we and our advertising partners may use cookies and similar technologies to deliver relevant adverts on and off lyna-uk.com, to limit the number of times you see an advert, and to measure the effectiveness of our marketing campaigns. These cookies may track your browsing activity across websites operated by different entities.

Managing Cookies

  • On-site controls: When you first visit lyna-uk.com, you may be presented with a cookie banner that allows you to accept or manage different categories of cookies (other than strictly necessary cookies). You can adjust your preferences at any time by revisiting the cookie settings link, where available, in the website footer or within your account settings.
  • Browser settings: Most browsers allow you to view, delete or block cookies, and to configure settings for specific websites. If you block all cookies (including strictly necessary cookies), some parts of lyna-uk.com may not function correctly or may be unavailable.
  • Third-party opt-outs: Some third-party analytics and advertising providers offer their own opt-out mechanisms. Where applicable, we will provide information or links to these mechanisms in our cookie notices.

Your choice to refuse or delete cookies may affect your user experience but will not prevent you from using essential features necessary to comply with our legal obligations and to operate your account.

Data Security

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

  • Encryption in transit and at rest: We use up-to-date transport layer security (TLS 1.2 or higher) to encrypt data transmitted between your browser and our servers. Where appropriate, we also encrypt sensitive data at rest within our systems and databases.
  • Access controls and authentication: Access to personal data is strictly limited to authorised personnel and service providers who need it to perform their duties. We apply role-based access controls, strong authentication mechanisms, and, where practical, multi-factor authentication for administrative access.
  • Segregation and minimisation of data: We design our systems to separate key functions, restrict direct access to production data, and minimise the personal data collected and retained to what is necessary for the specified purposes.
  • Network and system security: Our platform is protected by firewalls, intrusion detection and prevention systems, anti-malware technologies, and regular vulnerability assessments.
  • Monitoring and logging: We maintain logs and monitoring processes to detect suspicious activities, account takeovers, fraud attempts, and technical anomalies on lyna-uk.com and related systems.
  • Security audits and testing: We conduct regular internal reviews, and may engage external specialists, to test and assess the effectiveness of our security controls. We aim to align our practices with recognised industry standards for information security management (such as ISO/IEC 27001) and good practice for online gambling providers.
  • Staff training and confidentiality: Employees and contractors with access to personal data are subject to confidentiality obligations and receive training on data protection, information security and responsible gambling requirements applicable to the Luna project.
  • Incident response: We maintain incident response procedures to handle suspected or actual data breaches. Where a personal data breach is likely to result in a risk to your rights and freedoms, we will notify the appropriate supervisory authority and, where required by law, inform affected individuals without undue delay.

While no system can be guaranteed as completely secure, we continually review and enhance our safeguards to protect your personal data in line with technological developments and regulatory expectations.

Complaints & Contacts

If you have concerns about how we handle your personal data, or you wish to make a complaint about our privacy practices, we encourage you to contact us first so that we can attempt to resolve the matter.

How to Contact Us

  • Primary privacy contact / DPO: privacy@lyna-uk.com
  • Postal address: Data Protection Officer, SkillOnNet Ltd, Office 1/5297 Level G, Quantum House, 75 Abate Rigord Street, Ta' Xbiex XBX 1120, Malta

Internal Complaint Procedure

  1. Step 1 - Contact customer support: For routine questions or minor concerns, you can contact our customer support team via the help channels available on lyna-uk.com. Many issues can be resolved quickly at this level.
  2. Step 2 - Escalate to the DPO / privacy contact: If your concern relates specifically to privacy, data protection, or the way your personal data has been handled, or if you are not satisfied with the response from customer support, you should contact our DPO at privacy@lyna-uk.com. Please provide details of your concern, including any relevant account information and correspondence.
  3. Step 3 - Our response times: We aim to acknowledge your complaint and start investigating it promptly. For privacy-related complaints, we will generally provide a substantive response within one month (30 days). If your complaint is particularly complex, we may extend this period as allowed by law, but we will keep you informed.

Escalation to Supervisory Authorities

If you remain dissatisfied after contacting us, or you prefer not to contact us first, you have the right to lodge a complaint with a data protection authority.

  • United Kingdom - Information Commissioner's Office (ICO):
    • Website: https://ico.org.uk
    • Telephone: +44 303 123 1113
    • Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom
  • European Union / EEA: If you are located in the EU/EEA and EU data protection law applies to our processing of your data, you may have the right to complain to the data protection authority in your country of residence, place of work, or place of the alleged infringement. Contact details are available via the websites of national supervisory authorities and the European Data Protection Board.
  • Mexico - Data protection authority: Where Mexican privacy law applies, you may also lodge a complaint with the Mexican data protection authority, the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (“INAI”).
    • Website: https://www.inai.org.mx

Please note that for gambling-related disputes (for example, about the outcome of bets or account balances) that are not primarily about privacy, you may be able to refer your complaint to an Alternative Dispute Resolution (ADR) body, such as eCOGRA, in accordance with our Terms and Conditions and UK Gambling Commission rules. In such cases, we may share relevant account data with the ADR provider to enable them to review and decide on your complaint.

Updates

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, regulatory guidance, or technical developments affecting the Luna project and lyna-uk.com. When we make changes, we will revise the “Last updated” date below and, where appropriate, provide additional notice.

  • Notification methods: For material changes, we will take reasonable steps to inform you in advance, for example by:
    • displaying a prominent notice or banner on lyna-uk.com;
    • sending you an email notification to the address registered on your account;
    • providing an in-account message or dashboard alert when you next log in.
  • Advance notice: Where a change materially affects your rights or how we use your data, we will, where practicable, provide at least 30 days' notice before the new version takes effect. If you do not agree with the updated policy, you may choose to close your account and stop using our services.
  • Version control and changelog: We may maintain previous versions of this Privacy Policy and a high-level description of material changes on or via lyna-uk.com so that you can see how our practices have evolved over time.

Your continued use of lyna-uk.com and the Luna brand services after the effective date of an updated Privacy Policy will constitute your acceptance of the changes, to the extent permitted by applicable law.

Last updated: January 2026