Last Modified 10 January 2020
For purposes of data protection laws, Super Lucky Casino Inc., PO Box 84, San Francisco, CA 94104-9991, is the “data controller” of your information.
Acceptance and Consent:
1. Information We Collect
We obtain information about you when you use or otherwise access the Service. Please note that we need certain types of information so that we can provide the Service to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use the Service.
Information We Collect From You
We collect information you provide directly to us. For example, you may provide us with information through your:
- Registration for and use of an Account;
- Use of the Service, including mobile applications;
- Requests or questions you submit to us via online forms, email, or otherwise;
- Requests for customer support and/or technical assistance;
- Uploading or posting of user content, such as when you participate in player forums or message boards, post comments to other users’ profiles, send private messages or invitations to other users, chat with other users, or post photos;
- Donations or purchases through the Services;
- Registration for any contest, sweepstakes, or other promotions or events we may sponsor;
- Participation in surveys we may make available; or
- Provision of other information to us within or outside of the Service.
The types of information we collect directly from you include:
- Account Registration Information. When you register for a Super Lucky account (“Account”), we may collect information including your email address and a username.
- Profile Information: You may provide additional information about yourself to create a user profile (“Profile”), including but not limited to a username and other information you elect to provide about yourself. We encourage you to consider carefully what information to share as part of your Profile and elsewhere in the Service, and we recommend that you guard your anonymity and sensitive information and not use your real name as your username, as that may allow other users of the Service to identify you. Any information you choose to share should reflect how much you want other users of the Service to know about you.
- Usage History. You may provide additional information by using our Service, including our mobile applications. For example, when you play our games, we also collect information about your play and interaction with other users and the Service.
- Information About Others. You may decide to provide us with another party’s email address to allow us to contact and invite that party to visit or join the Service or so that Super Lucky may facilitate your communication with such other party through methods of communication enabled by the Service (such as when you upload an address book). Such email addresses will be used only for the purpose of sending email communications to the addressee.
Information We Collect From Third Parties
We may collect information about you or others through our affiliates or through non-affiliated third parties. For example, you may be able to register for an Account through a social networking account. If you access the Service through a social media account, you may allow us to have access to certain information in your social media profile. This may include your user ID, name, email, gender, birthday, current city, profile picture URL and the user IDs of your friends who have also connected with our applications. We may also cache data we receive from the Facebook APIs to improve our user experience. Social networking sites have their own policies for handling your information. For a description of how these sites may use and disclose your information, including any information you make public, please consult the sites’ privacy policies. We have no control over how any third-party site uses or discloses the personal information it collects about you.
We may also collect information about you from non-affiliated third parties for fraud or safety protection purposes, or for marketing purposes. For example, we may receive information about your use of products/services offered by our advertising partners. We may collect also collect information about you, such as your name or email address, from third party websites or other sources from which you download or access Super Lucky applications, services or products that also make up part of the Service.
We likewise may combine information that we collect from you through the Service with information that we obtain from such third parties and information derived from any other products or services we provide.
Information We Collect Automatically
Log Data, Cookies and Web Beacons
We may feature advertisements served by third party advertising companies which deliver cookies to your computer or device so the advertisements you see can be tracked. These advertisers may use information about your visits to our Service in order to provide advertisements about goods and services of interest to you.
You can instruct your web browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If your browser is set to refuse all cookies, however, some features of the Services may not function properly.
We and third party advertising companies may collect information using Web beacons. Web beacons or “gifs”, are electronic images that may be used on our Site, in our Service or in our emails. We use Web beacons to deliver cookies, count visits and to tell if an email has been opened and acted upon. Advertisers may use web beacons in connection with our Service in order to collect and use data regarding advertisement performance and your interests for the purpose of delivering relevant advertising to you.
2. How We Use Information We Collect
We may use the information we collect, alone or in combination, for various business and commercial purposes, including, but not limited to providing the Service as well as the following:
- To fulfill the purposes for which you provided it (such as providing you with the games you seek to play);
- To deliver products or advertisements to you according to your preferences or restrictions, to retarget content, and to otherwise personalize your experiences while using our Service;
- For customer support and to respond to your inquiries;
- For internal record-keeping purposes;
- To communicate with you, including to send you updates, newsletters and other information that may be of interest to you;
- To send push notifications to your wireless device or computer to provide updates and other relevant messages (you can manage push notifications from the “options” or “settings” function in your mobile app);
- To send you SMS notifications (with your consent);
- To improve the Service and to research and develop new services;
- To create or maintain aggregated, anonymized or de-identified information, which we may use and disclose without restriction;
- To investigate, prevent, or take action regarding unlawful or harmful activities, including potential threats to physical safety, potential fraud, and violations of our Terms of Service;
- To safeguard our and others’ rights or property;
- To process any job applications you submit; and
- To otherwise administer and troubleshoot the Service.
We may combine any of the information that we collect from you with other information, including information that we obtain from third parties, or with information derived from any other products or services we provide. For example, we may combine personal information you provide us, such as an email address, with information automatically collected about your device. We may use this combined information to, among other things, provide you with personalized recommendations.
3. How We Share the Information We Collect
- Advertising Partners
We share your information with third parties with whom we have a business relationship such as advertisers, ad networks and analytics providers. The information shared with these third parties may be used for industry analysis, ad targeting, tracking ad conversions or demographic profiling, or other purposes related to providing the Services to you.
- Service Providers
We may employ third party companies and individuals to facilitate the Service, to provide the Service on our behalf, or to assist us in analyzing how the Service is used. These third parties have access to your information to perform these tasks on our behalf and we use good faith efforts to obtain their commitment not to use your information for any other purpose.
- Business Partners
We may also provide your information to our business partners or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you.
- Legal Requirements and Protection of Rights
We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Super Lucky or any third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.
- Business Transfers
We may transfer your information in connection with a change or transfer of Super Lucky’s ownership, or a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy, including in the course of diligence.
- Consent or At Your Direction
We may share your information with your consent, including where you post information to be shared publicly or with other users. For example, you may post content to a blog, message board, chat room or within Super Lucky’ applications or other forums (“Forums”). Certain of your information, such as your username and other information, will always be publicly visible by other users of the Forums, including when such users view your Account profile page. Your email address will not be publicly visible unless you choose to make it visible in your Account profile page. You may also direct us to share information when you participate in player forums or message boards post comments to other users’ profiles, send private messages or invitations to other users, chat with other users, and post photos in your public Profile.
- Aggregated or Anonymous Information
The sharing scenarios identified above apply to personally identifiable information, not aggregated or anonymous information. We may share aggregated or anonymous information about you and other users with advertisers, publishers, business partners, sponsors, and other third parties, in which case such information may be disclosed and used for a broad range of commercial purposes without limitation.
4. Analytics and Tailored Advertising
We may use third-party web analytics services (such as those of Google Analytics and Amplitude) on our Site to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
The Service may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Service, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your age and gender, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.
Third parties, whose products or services are accessible or advertised via the Service, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. We also allow other third parties (e.g., ad networks and ad servers such as Google Analytics and others) to serve tailored ads to you on the Service, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Service. We sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.
Please note that if you exercise the opt out choices above, you will still see advertising when you use the Service, but it will not be tailored to you based on your online behavior over time.
5. EEA Data Subjects
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your “personal data” (as defined in such applicable laws). To the extent those laws apply, our legal grounds are as follows:
- To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to allow you to play our games.
- Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
- Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes: operating our business and the Service; providing security for our websites, products, software, or applications; marketing; receiving payments; preventing fraud; and knowing the customer to whom we are providing the Service.
- Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations (such as our obligation to share data with tax authorities).
6. Retention of Your Information
We generally retain information for so long as it may be relevant to the purposes above and in compliance with applicable law. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.
Super Lucky takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your Account or any of your information will be protected against, loss, misuse, or alteration by third parties.
8. Your Choices
When you register for an Account or later access your Account, you will able to adjust settings and preferences within your Account to choose whether to share and make publicly visible other pieces of your information, and the Service will display your information based on the settings and preferences you choose. You can review and revise your Profile information at any time.
You may “opt-out” of receiving certain types of communications at any time by contacting Super Lucky at support@SuperLucky.com.
For Residents of the European Union and EEA Countries:
Residents of the European Economic Area (“EEA”), can exercise certain data subject rights available to them under applicable data protection laws. Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. If these rights apply to you, they may permit you to request that we:
- provide access to and/or a copy of certain information we hold about you
- prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
- update information which is out of date or incorrect
- delete certain information which we are holding about you
- restrict the way that we process and disclose certain of your information
- transfer your information to a third party provider of services
- revoke your consent for the processing of your information
For more information on how to exercise these rights, please contact us using the information in the “Contacting Us” section below. If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
For Residents of Nevada:
Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by NevadaPII@superlucky.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
For Residents of California:
Please click https://www.superluckycasino.com/CAsupplemental to view details on rights for California residents.
9. International Users
10. Third Party Links
11. Our Policy Regarding Children
The Service is not directed to children under the age of 13. We do not knowingly collect or solicit personally identifiable information from children under 13. If you are under 13, please do not attempt to register for an Account on the Service or send any information about yourself to Super Lucky. If we become aware that a child under 13 has provided us with personal information (as defined by the United States Children’s Online Privacy Protection Act), we will delete such information from our files as required by applicable law.
We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.
12. Contacting Us