Privacy Policy

Version 2.1

Date Updated: August 12, 2022

Scope of Privacy Policy

Our Privacy Policy sets out our policies regarding the information we collect and how it is used, shared, and securely stored. It applies irrespective of whether you are playing on a PC, a mobile device, or through a third-party application (e.g., Facebook). Please read this Privacy Policy closely before using any of our products. These Rules are to be read in conjunction with our Terms and Conditions, Rules Regarding Fortune Coins, Responsible Social Gaming Policy, Customer Acceptance Policy, and Tournament Rules (the “Documentation”). Any terms defined in the Documentation and not defined in the Privacy Policy have the same meaning as set out in the Documentation. If you have any questions, please contact us at info@fortunecoins.com.

Definitions

The following definitions apply to this Privacy Policy:

• “Account” means your user account with us, which you sign up for at info@fortunecoins.com;
• “Covered Information” means information which includes first and last name, address, email address, phone number, and an identifier which allows a specific person to be contacted either physically or online.
• “Data Protection Officer” means a role within a company or organization whose responsibility is to ensure that the company or organization is correctly protecting individuals' personal data according to current legislation.
• “Event Tagging” means tags that allow us to monitor certain events completed through our Website (e.g., purchases);
• “Marketing Pixels” means pieces of code that allow us to gather information about anyone who visits our Website, including their engagement with our webpage;
• “Mobile Device Identifiers” means the unique customer identifier on every mobile device which is used to distinguish a mobile device. This unique identifier can be used for the purposes of internet-based advertising.
• “Service” means any of the services available through our Website or mobile applications;
• “Website” means our website at www.fortunecoins.com
• “User” means a person who uses the Service;

What We Collect

We collect information about you in a number of ways. Examples of the information we collect are:

• Contact details, including your e-mail address, physical mailing address, mobile phone number (and any other phone number(s) provided).
• Personal information such as your first name, surname, age and likeness.
• Account login details, including your unique username, unique password and any photos associated with your account.
• Transaction information provided by you. This information may include your mailing address, phone number, payment and/or redemption information such as financial institution information, credit card information and bank account statements.
• Information sent as part of live chat, email, or any other method of customer support.
• Information we obtain from a third-party (e.g., Facebook) regarding your connection to our services.
• Your location information, including information provided by a device interacting with our platform.
• Activity and device information about your use of our Service, including which content you view/use, when and for how long you access our Service, how often you use our services, how you heard about our Service, the specific hardware model you are using, the device type you are using, other unique device identifiers, operating system, browser type and IP address; and
• Any documentation which we request to verify that you are eligible to have an account and receive payouts.
• We may also collect information which does not directly or indirectly identify you, as well as information about groups of customers, which does not directly or indirectly identify you.

Your Representations

• By providing your information to us, you represent that any information you provide is true and accurate. You acknowledge that your contact information, including but not limited to, your phone number and e-mail address, are true and accurate. Further, you admit that you are the subscriber to any telephone number provided to us.

How We Collect Information

• User information is collected in a number of ways, including when a User accesses our Service, registers an Account, makes a purchase, answers a survey (including those sent from a related third-party, and in connection with any other service, feature or resource offered by us.

By providing your telephone number(s) to us, you agree to being contacted at the number provided to us. Ways in which you may be contacted include pre-recorded voice messages, autodialed calls, and SMS messages from or on behalf of us related to:

• The Documentation;
• Any purchases or redemptions related to your Customer Account; and
• Promotional matters from or on behalf of us.
• We may communicate in the ways described above even though a phone number is registered on a state, provincial or federal Do Not Call List. We are not responsible for any charges incurred by Users from their telephone provider(s) for texts or calls received from or on behalf of us.

We also collect information from Users through telephone, video or correspondence, including e-mail, instant messaging, physical mail, SMS and/or social media platforms. Telephone and video calls with us may be recorded for the purposes of training, quality control and compliance. By partaking in any such call with us as described above, you consent to your call being recorded.

We use a variety of technologies embedded in our Website or in our applications on third party sites and platforms including cookies, pixels, tags and application program interfaces (“API”). For example:

• In order to enhance your user experience, we use industry standard identifiers, such as cookies or similar technologies. A cookie is a small text file saved locally on your computer or mobile device when you visit our Website. This small text file may include a unique identifier, making it possible to distinguish your device from another device.

Examples of similar identifying technologies that we may use are:

• Marketing Pixels;
• Mobile Device Identifiers. We may, at times, share your Mobile Device Identifiers with advertisers; and
• Event Tagging.

Analytical tools may also be used to collect information, including when you visit our Website or use our applications or services on third party sites or platforms.

How We Use Your Information

• We may use your information for the purposes set out in this Privacy Policy. Your information may also be accessed by other companies within our group of companies when acting on behalf of us as a data processor as outlined in this Privacy Policy.

We retain all customer information collected by means described in this Privacy Policy as long as required by this Privacy Policy or as long as is permitted by law. We may share your information collected with our group of companies or third-party companies providing a service to customers directly or indirectly through us. We may use and/or share your information with third parties, in accordance with applicable law, to offer the best possible experience for you. Some reasons for which your information may be collected and used/shared are:

• To provide services as requested by you, including the establishment and maintenance of your Account and routine security checks to ensure the security of your information.
• To provide you with the best customer service experience possible. Information provided and/or collected from you will help us in responding to any customer service requests. Feedback provided by you may be used to improve our products and services.
• In the processing of payments, we may use information provided by you in order to comply with various due diligence requirements, including as related to anti-money laundering and to verify payment details. We do not share any payment information with third party payment processors except to the extent necessary in providing transactional services.
• Aggregated information may be used to best understand our users in order to deliver the most tailored user experience possible.
• To contact you about our services, we may contact you by e-mail, live chat, telephone, SMS, physical mail or social media in order to manage promotions and competitions that you elect to enter.
• In sending you important notices regarding matters such as purchases you have made or changes to any of our policies.
• In complying with all our legal and/or regulatory obligations, we may use the information we collect to ensure compliance with the Documentation and our regulatory obligations.

Your Rights Over Your Information

• By law, you have a number of rights concerning the information about you that we collect and store securely. Please contact our Data Protection Officer if you wish to exercise any of these rights.
• You have the right to access personal information about you that we securely store, the right to object to the processing of your personal information and the right to withdraw any consent given through this Privacy Policy.
• You may lodge a complaint to the appropriate data protection supervisory authority about how we process your personal information.
• You may object to the processing of personal information being used for the purpose of direct advertising.
• You may opt-out of receiving communications from us by following the instructions in those message (found at the bottom of the page) or through customer support.

How We Protect Your Information

Keeping your personal information secure is our top priority. Through the use of physical, electronic and operational protocols we are able to protect your personal information. We use industry-standard practices for data collection, data storage, and data processing to protect your information against unauthorized access, manipulation, disclosure or destruction. We regularly review our security protocols and make sure that they meet industry-standards.

How Long Will Do We Keep Your Information

• We may retain your information as long as we require in order to fulfill the practices outlined in this Privacy Policy or as long as we are required by law.

Sharing Your Information

• We may share your information within our group of companies or with a third party who will provide services to you for us. We may also share your information with other third parties in order to stay compliant with our legal obligations.
• We reserve the right to use a User’s information when it comes the winning of any prize through use of our Service, including their name, the amount of Fortune Coins or Gold Coins, their city, state (or province), country, profile picture or any other personal information collected as described in this Privacy Policy for marketing purposes including on social media platforms, affiliated marketing channels and through physical media channels (radio, television, print media).

Changes To This Privacy Policy

• This Privacy Policy may be updated from time to time to reflect changes in the law and changes to our policies. You will be made aware of any material changes and, where required by law, we will obtain your consent.
• Any changes to the Privacy Policy will become effective when the updated Privacy Policy is posted on our Website.
• Users are responsible for staying up to date on the changes to our Privacy Policy posted on our Website. We recommend checking this page regularly for updates.

Contacting Us

• Please contact our Data protection office by opening a ticket on our customer support portal at support.fortunecoins.com.

Information for Specific Groups

• Our Services are restricted to individuals who have attained the age of majority in their jurisdictions. Accordingly, we will never knowingly collect or maintain information from minors.

For Nevada Residents

• Under Nevada law, Nevada residents who have made purchases related to the Services may opt out of the “sale” of “Covered Information” (as such terms are defined under Nevada law) for financial consideration to a person for that person to license or sell such information to additional persons. While we may share your information with third parties we believe can provide you with offers and promotions for goods and services of interest to you, we do not believe this sharing would qualify as a sale under Nevada law. Regardless, if you are a Nevada resident who has made purchases related to the Services, you may submit a request to record your preference to opt out by emailing the Data Protection Officer at []. We may take reasonable steps to verify your identity and that the request came from you.

For California Residents

• As a California resident, you have the right to request that we disclose what personal information we collect from you, to delete that information, and, subject to certain restrictions, to opt out of the sale of your personal information.
• You may exercise your California privacy rights by contacting the Data Protection Officer by opening a ticket on our customer support portal at support.fortunecoins.com. We will verify your identity when you request to exercise your rights. Logging into your Account may be sufficient, however if we have reason to suspect that your Account has been compromised, or if you do not have an Account, we may request additional verification information from you.
• You have the right to designate an agent to exercise your rights on your behalf. Your agent must verify authorization to make a request on your behalf by providing us with a signed written authorization or a copy of a power of attorney.
• You have the right to request, up to two times in a 12 month period, that we disclose what categories of your personal information that we collect, use, and share, including the specific pieces of personal information we have collected from you and which information is shared with third parties for direct marketing purposes.
• You have the right to request that we delete personal information that we collect from you. Some information may be exempt from such requests under California law.
• You will not be denied access to the Services or provided with a modified version of the Services if you choose to exercise these rights.
• We may sell information that directly identifies you such as your name, telephone number, mailing address or email address. You may opt out of the sale of your personal information. If you would like to opt-out, please contact the Data Protection Officer by opening a ticket on our customer support portal at support.fortunecoins.com.
• If you are a California resident under the age of 19, you may view, correct, or delete information provided by you or publicly posted by you by sending us an email asking us to delete certain posted content. Please note that our Services are restricted to individuals who have attained the age of majority in their jurisdictions. Accordingly, we will never knowingly collect or maintain information from minors.
• You have the right to be informed as to how we respond to “Do Not Track” settings. We do not currently take actions to respond to “Do Not Track” settings and instead we adhere to the standards set out in this Privacy Policy.
• California Collection Notice. We may share information described below with third parties for the following purposes: (i) with our group companies for the purposes described in this Privacy Policy; (ii) with vendors and partners we engage in order to provide you with the Services; (iii) if required to do so by appliable law or legal process; (iv) if necessary to exercise, establish, or defend our legal rights; (v) if necessary to protect the vital interests of any person; and (vi) in connection with the sale of our business. We may collect categories of information. The table below describes how we collect and use such categories of information:

• Categories of information collected
• Purposes of use
• Sources of personal information

• Identifiers and Contact or Registration Information, e.g., name, email address, postal address, phone number

• Perform the services, and personalizing your experience on our Properties

  Commercial purposes, such as providing information about our press releases, SEC filings, events, and stock information and providing advertising selected by us

  Interact with Investor Relations

  Undertaking activities to verify and maintain the quality of our service

  Detect security incidents and secure our Properties

• You, both directly and through your use of the Properties

  Our vendors

  Our affiliates and business partners

  Social Media or other third-party accounts

• Demographic Information, e.g., interests, gender, age, etc.

• Perform the services, and personalizing your experience on our Properties

  Commercial purposes, such as providing information about our press releases, SEC filings, events, and stock information and providing advertising selected by us

  Interact with Investor Relations

  Undertaking activities to verify and maintain the quality of our service

  Detect security incidents and secure our Properties

• You, both directly and through your use of the Properties

  Our vendors

  Our affiliates and business partners

  Social Media or other third-party accounts

• Investor Relations Inquiries, e.g., questions and other messages you address to us directly through online forms

• Perform the services, and personalizing your experience on our Properties

  Commercial purposes, such as providing information about our press releases, SEC filings, events, and stock information and providing advertising selected by us

  Interact with Investor Relations

  Undertaking activities to verify and maintain the quality of our service

  Detect security incidents and secure our Properties

• You, both directly and through your use of the Properties

  Our vendors

  Our affiliates and business partners

• Device Information and Device Identifiers, e.g., IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers

• Perform the services, and personalizing your experience on our Properties

  Interact with Investor Relations

  Undertaking activities to verify and maintain the quality of our service

  Detect security incidents and secure our Properties

• You, both directly and through your use of the Properties

  Our vendors

  Our affiliates and business partners

  Social Media or other third-party accounts

• Connection and usage data, e.g., interactions with our websites, files you download, domain names, landing pages, usage activity, content viewed and accessed, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, whether you open an email and your interaction with email content, access times, error logs, and other similar information

• Perform the services, and personalizing your experience on our Properties

  Commercial purposes, such as providing information about our press releases, SEC filings, events, and stock information and providing advertising selected by us

  Interact with Investor Relations

  Undertaking activities to verify and maintain the quality of our service

  Detect security incidents and secure our Properties

• You, both directly and through your use of the Properties

  Our vendors

  Our affiliates and business partners

• Geolocation, e.g., city, state and ZIP code associated with your IP address

• Perform the services, and personalizing your experience on our Properties

  Commercial purposes, such as providing information about our press releases, SEC filings, events, and stock information and providing advertising selected by us

  Interact with Investor Relations

  Undertaking activities to verify and maintain the quality of our service

  Detect security incidents and secure our Properties

• You, both directly and through your use of the Properties

  Our vendors

  Our affiliates and business partners

  Social Media or other third-party accounts

• Other Information, e.g., any other information you choose to directly provide to us in connection with your use of the services

• Perform the services, and personalizing your experience on our Properties

  Commercial purposes, such as providing information about our press releases, SEC filings, events, and stock information and providing advertising selected by us

  Interact with Investor Relations

  Undertaking activities to verify and maintain the quality of our service

  Detect security incidents and secure our Properties

• You, both directly and through your use of the Properties

  Our vendors

  Our affiliates and business partners

  Social Media or other third-party accounts