Tenant1

Last Updated: May 19, 2026

1. Introduction

This Privacy Policy ("Policy") explains how HeavenOnline ("we", "us", "our", or the "Website") collects, uses, stores, shares, and protects your personal data when you access or use the website located at heavenonline.io and any related services (collectively, the "Services").

HeavenOnline is owned and operated by Lucifer Ltd., registration number: 000054043, registered address: San Victor Street, Orange Walk Town, Belize, licensed by Anjouan Licensing Services Inc. under License No. ALSI-202605018-FI1.

We act as the data controller of your personal data. By using the Services, you acknowledge that you have read and understood this Policy. This Policy should be read together with our Terms & Conditions, KYC Policy, AML Policy, and Responsible iGaming Policy.

2. Personal Data We Collect

We collect the following categories of personal data:

2.1 Information You Provide at Registration

Full legal name
Date of birth
Residential address
Email address
Phone number (where provided)
Username and password (passwords are stored in encrypted form)

2.2 Identity Verification Information (KYC / EDD)

Collected when Enhanced Due Diligence is triggered:

Government-issued photo identification (passport, national ID, or driver's license)
Proof of address (utility bill, bank statement, or equivalent document)
Proof of source of funds (where required based on risk assessment)
Biometric or liveness data, where used for identity verification

2.3 Financial Information

Deposit and withdrawal records
Payment method details (tokenized; we do not store full card numbers)
Transaction history, wagering activity, and account balances
Cryptocurrency wallet addresses (where applicable)

2.4 Technical and Usage Data

IP address and geolocation data
Device type, operating system, and browser information
Unique device identifiers
Login timestamps and session duration
Pages viewed, games played, and interaction patterns
Cookies and similar tracking technologies (see Section 9)

2.5 Communications

Records of correspondence with our customer support
Chat logs, emails, and call recordings where applicable

3. How We Collect Your Data

We collect personal data through the following channels:

Directly from you when you register, deposit, withdraw, contact support, or otherwise interact with the Services
Automatically through cookies, log files, and analytics tools
From third parties, including identity verification providers, payment processors, fraud prevention services, and publicly available sources (such as sanctions and PEP screening databases)

4. Legal Basis and Purposes of Processing

We process your personal data on the following legal bases and for the following purposes:

Purpose	Legal Basis
To create and manage your account	Contract performance
To process deposits, withdrawals, and game transactions	Contract performance
To verify your identity and age	Legal obligation (AML/CTF, gaming regulations)
To comply with KYC, AML, and CTF requirements	Legal obligation
To detect and prevent fraud, money laundering, and other illegal activity	Legitimate interest; Legal obligation
To monitor gameplay for fairness and responsible gaming	Legitimate interest; Legal obligation
To provide customer support	Contract performance
To send service-related communications	Contract performance
To send marketing communications (where permitted)	Consent
To improve our Services and develop new features	Legitimate interest
To enforce our Terms and protect our legal rights	Legitimate interest
To comply with court orders, subpoenas, and regulatory requests	Legal obligation

5. How We Share Your Data

We do not sell your personal data. We share your data only with the following categories of recipients, and only to the extent necessary:

5.1 Service Providers

Identity verification (KYC/EDD) providers
Payment processors and financial institutions
Cloud hosting and infrastructure providers
Game content providers (for gameplay and prize processing)
Fraud prevention and risk management services
Customer support and communications platforms
Analytics and marketing platforms (where consented)

All service providers are bound by contractual obligations to protect your data and process it only on our instructions.

5.2 Regulatory and Legal Authorities

We may disclose your data to:

Anjouan Licensing Services Inc. (our licensing authority)
Financial Intelligence Units (FIUs)
Tax authorities
Law enforcement agencies
Courts and regulators with valid legal authority

Disclosure may occur with or without your prior consent where required by law.

5.3 Corporate Transactions

If we undergo a merger, acquisition, restructuring, or sale of assets, your data may be transferred to the relevant party, subject to equivalent privacy protections.

5.4 With Your Consent

We may share your data with other third parties where you have given explicit consent.

6. International Data Transfers

Your personal data may be transferred to, stored in, and processed in countries outside your country of residence, including jurisdictions that may not provide the same level of data protection. Where such transfers occur, we ensure appropriate safeguards are in place, including:

Standard contractual clauses
Adequacy determinations
Other lawful transfer mechanisms recognized under applicable data protection law

7. Data Retention

We retain your personal data only for as long as necessary for the purposes set out in this Policy and to comply with our legal obligations.

Data Category	Retention Period
Account and KYC records	Minimum 5 years after account closure (AML requirement)
Transaction and AML records	Minimum 5 years from the date of transaction
Communications and support records	Minimum 5 years
Marketing data	Until you withdraw consent or 24 months of inactivity
Technical logs	Up to 12 months, unless required longer for security or legal reasons

Where longer retention is required by law or regulation, we will retain data for that extended period.

8. Your Rights

Subject to applicable law (including the EU General Data Protection Regulation, where it applies to you), you have the following rights:

Right of access — to obtain a copy of the personal data we hold about you
Right to rectification — to correct inaccurate or incomplete data
Right to erasure ("right to be forgotten") — to request deletion of your data, subject to our legal retention obligations
Right to restriction of processing — to limit how we process your data in certain circumstances
Right to data portability — to receive your data in a structured, machine-readable format
Right to object — to object to processing based on legitimate interests or for direct marketing
Right to withdraw consent — where processing is based on consent
Right to lodge a complaint — with a relevant data protection authority

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days of receiving a verified request.

Please note that certain rights are limited by our legal obligations. In particular, we cannot delete data we are required to retain for AML, regulatory, or audit purposes during the retention period.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to:

Maintain your login session
Remember your preferences
Analyze site traffic and usage patterns
Detect fraud and protect account security
Deliver relevant marketing (where consented)

You can manage your cookie preferences through your browser settings or our cookie banner. Disabling certain cookies may affect the functionality of the Services.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

SSL/TLS encryption for data in transit
Encrypted storage for sensitive data at rest
Access controls based on the principle of least privilege
Multi-factor authentication for internal systems
Regular security audits and vulnerability testing
Firewalls, intrusion detection, and anti-malware systems
Staff training on data protection and information security

In the event of a personal data breach, we will notify Anjouan Licensing Services Inc. within 24 hours and, where required by law, notify affected individuals without undue delay.

11. Children's Privacy

The Services are strictly for individuals aged 18 or older (or the legal age of majority in your jurisdiction, whichever is higher). We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will delete it promptly and close the related account.

12. Marketing Communications

Where you have provided consent, we may send you marketing communications about products, promotions, and offers. You can withdraw your consent at any time by:

Clicking the "unsubscribe" link in any marketing email
Updating your communication preferences in your account settings
Contacting [email protected]

Withdrawing marketing consent does not affect service-related communications, which are necessary for the operation of your account.

13. Automated Decision-Making

We may use automated systems to support decisions on:

Fraud and risk scoring
AML transaction monitoring
Responsible gaming behavioral analysis
Bonus and promotion eligibility

Where an automated decision produces a significant effect on you (such as account restriction), you have the right to request human review by contacting [email protected].

14. Third-Party Links

The Services may contain links to third-party websites. We are not responsible for the privacy practices of those websites. We encourage you to review their privacy policies before providing any personal data.

15. Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices, technology, or legal requirements. Material changes will be notified through the Website and/or by email. The "Last Updated" date at the top of this Policy indicates when it was last revised.

16. Contact Us

For any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

HeavenOnline — Data Protection
Operated by Lucifer Ltd.
Email: [email protected]
General Support: [email protected]
Licensed by: Anjouan Licensing Services Inc.
License No.: ALSI-202605018-FI1

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Heavenonline.io is owned and operated by Lucifer Ltd., registration number: 000054043, registered address: San Victor Street, Orange Walk Town, Belize.
Contact us at [email protected].
Heavenonline.io is licensed and regulated by the Government of the Autonomous Island of Anjouan, Union of Comoros and operates under License No. ALSI-202605018-FI1. Heavenonline.io has passed all regulatory compliance and is legally authorized to conduct gaming operations for any and all games of chance and wagering.