Privacy
Policy
This Privacy Policy describes Lucky Tycoon¡¯s
practices for collecting, using, disclosing, maintaining and protecting your
personal information on the media platforms we operate, including the Lucky
Goal app on the IOS platforms (the¡°App¡±),
our Website, or any other platform on which you see this Privacy Policy
(collectively, the ¡°Services¡±). We will refer to our users as ¡°you¡± in this
Privacy Policy. This Privacy Policy is incorporated into, and part of,
the Terms of Use (the ¡°Terms of Use¡±), which governs your use of our Services.
Please read this notice carefully to understand
our policies and practices for processing and storing your personal
information. By accessing and utilizing our Services, you accept and
consent to the practices described in this Privacy Policy. This Privacy
Policy may change from time to time (see Changes to our Privacy Policy).
Your continued access and/or use of our Services after any such revisions
indicates that you accept and consent to them. Please check periodically for
updates.
1.
Who We Are
We are Lucky Tycoon Studio Limited (¡°Lucky Tycoon¡±,
¡°we¡±, ¡°our¡±, ¡°us¡±)
Third-Party Links
The platforms on which our services run may include links to third-party
services, plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party services and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the
Privacy Policy of every other website or app you visit.
2.
The Data We Collect About You
We collect several different types of personal
information from you depending on how you interact with our Services. Personal
information means any information about an individual from which that person
can be identified. It does not include information where the identity has
been removed or is not able to be associated with an individual.
Most of the information we collect is given to us
by you through filling out forms, registering for an account, or otherwise
providing information when asked. Occasionally, we collect information
from your device which helps us better provide our services to you.
Because we may change our website and the services we offer from time to time,
the means and methods to provide us with personal information may also
change. Depending on how you interact with us and use our services, the
personal information we collect may vary.
We may process the following types of personal
data about you, which we have grouped together as follows:
Identifiers |
This may
include your name (first and last), a username (or similar identifier), data
of birth, gender, and profile photo if you upload it. |
Contact Information |
This may
include your email address, mailing address, telephone number. |
Virtual Gifts Transaction Information |
This may
include information you provide for the purposes of sending virtual gifts to
you, such as the email address associated with your account. It also includes
the records, amounts and other information associated with virtual gifts
transactions. |
Technical Information |
This may
include your IP address (which may identify your general geographic
location), device identifier data, the type of device you use, your operating
system and version, the URL¡¯s of our web pages that you visit, the URL¡¯s of
referring and exiting pages, the pages you view, the time spent on a page,
the number of clicks made, the platform type, and generalized, non-specific
location data. |
Usage Information |
This may
include information about the game features you use, your game preferences,
the types of games you play, how long you use our Services, and how you use
our Services. |
Account Information |
This may
include your username and password, your preferences, feedback and survey
responses. |
Marketing and Communications Information |
This may
include your communications preferences in receiving marketing from us and/or
third parties. |
Geolocation Data |
We collect
your geolocation data whenever you choose to access the rewards or wallet
features and play our games. We use this data to determine our legal
obligations in that jurisdiction. |
3.
How We Collect Your Personal Information
We collect information about you in many
different ways. Most of the time we collect through your direct
interactions with our services, but we may also automatically collect personal
information from your devices, and occasionally from third parties or publicly
available sources.
We collect information about you in the following
ways:
Direct Interactions: When you interact with our services, you may provide us your personal
information by filling in forms, communicating with us by email, text/SMS,
post, or otherwise. This may include personal information you provide when
you:
1, Subscribe for our Services/Register for an Account;
2, Request that
the App be texted to you;
3, Enter a game, competition, promotion, or survey,
4, Provide
us feedback, requests support, or communicate with us.
Automated Collection: As
you interact with our Services, we may automatically collect Technical
Information and Usage Information. We collect these categories of Personal
Information by using cookies, SDK¡¯s, web beacons, and other similar
technologies. Please see our Cookie Policy for
additional details.
Third Parties or Public Sources: We may share and receive personal information about you from various
third parties as follows:
¡¤ Technical Information and Usage Information from the following parties:
¡¤ Advertising Networks
¡¤ Contact
Information, Transaction Information, and Technical Information from providers
of technical, communications, and service providers;
¡¤
Social Networking Posting Tools and Share features: When you visit a page that includes one of these sharing tools, the
third-party company that operates the tool may be collecting information about
your browser, device, and other online activity through its own technology not
controlled by us. Please read their privacy policies.
¡¤ Identifiers
and Technical Information from Social Networks: when you grant us permission to access data on one or more of those
services.
¡¤ Publicly visible data: such as
your social media and other information submitted to social media or other
publicly available media.
4.
How We Use Your Personal information
We will only use your personal information when
allowed by law. Generally, we will use your personal information: (a) where we
need to perform the contract we are about to enter into or have entered into
with you; (b) where it is necessary for our legitimate interests and your
interests and fundamental rights do not override those interests; and (c) where
we need to comply with a legal or regulatory obligation.
Purposes
for which we will use your personal information
Below is a chart of some of the common ways in
which we process your personal information. We have identified what our
legitimate interests are where appropriate. Note that we may process your
personal information for more than one lawful ground depending on the specific
purpose for which we are using your data. Please contact us if you need details
about the specific legal ground we are relying on to process your personal
information where more than one ground has been set out in the table below.
Purpose/Activity |
Type of data (varies depending on circumstances) |
Lawful basis for processing including basis of legitimate interest |
To
register you as a user of our Services. |
Contact
Information Account
Information |
Performance
of a contract with you. |
Notifying
you about changes to our terms or Privacy Policy. |
Contact
Information |
Necessary
to comply with a legal obligation |
To enable
you to participate in a game, contest, competition, survey, or similar event. |
Identifiers Contact
Information Technical
Information Usage Information |
Performance
of a contract with you. Legitimate
Interests (to learn how our users use our Services, to improve our Services,
to grow our business). |
To
administer and protect our business and this website (including
troubleshooting, data analysis, testing, system maintenance, support,
reporting and hosting of data). |
Identifiers Contact
Information Technical
Information Usage
Information |
Necessary
for our legitimate interests (for running our business, provision of
administration and IT services, network security, to prevent fraud and in the
context of a business reorganization or group restructuring exercise) |
To provide
you with information and marketing communications about our products and
services. |
Identifiers Contact
Information Marketing
and Communications Information |
Consent Legitimate
Interests (in marketing goods or services in which you may have a personal
interest based on our ongoing business relationship). |
To provide
you with third party offers that may be relevant to you. |
Identifiers Contact
Information Marketing
and Communications Information |
Consent |
To respond
to customer service requests including order status and chat communications. |
Identifiers
Contact Information Technical
Information |
Legitimate
Interest (for running our business, provision of administration and IT
services, network security, to prevent fraud and in the context of a business
reorganization or group restructuring exercise) Consent |
Social
Media Advertising. Lucky
Goal also runs other kinds of online ad campaigns on social networking websites
and other non-Lucky Tycoon websites and apps. Some of these ads may be based on
information we have about users. If Lucky Tycoon provides information to a
website or app for these advertising purposes, the information may only be used
to display the Lucky Tycoon ad. Please see the privacy policy of the website or
app where a Lucky Tycoon ad is shown for more information about its privacy
practices and privacy choices it may offer.
6.
Disclosures Of Your Personal information
From time to time, we may need to share your
personal information with others, including in the following circumstances.
Disclosures
to the Public. Some
of your personal information will be shared with the general public, including
your first name and last name initial. When information is made publicly
available it may be accessed by anyone with access to the platform to which the
information is posted. It may also be indexed by third-party search engines,
and be imported, exported, distributed, aggregated, and redistributed by others
without our knowledge.
Third
Party Service Providers. We may
share your personal information with third party service providers who perform
various functions to enable us to provide our services and help us operate our
business, such as website design, sending email communications, fraud detection
and prevention, customer care or performing analytics. Our contracts with these
third parties require them to maintain the confidentiality of the personal
information we provide to them, only act on our behalf and under our
instructions, and not use personal information for purposes other than the
product or service they¡¯re providing to us or on our behalf.
With
our Affiliates and Partners. When
participating in events or activities that we offer along with our partners
and/or affiliates, you may be asked to share personal information with those
affiliates and/or partners. For example, a game, contest, competition,
contest, sweepstake or other offering may be co-sponsored by another company or
companies. In such a situation, the information we obtain from you in
connection with such contest, sweepstake or offering may be shared with our
co-sponsor, unless you instruct us not to (which may result in you not being
able to participate). In some of those cases, we may act as co-controllers of
your personal information, depending on the circumstances.
With
Unaffiliated Controllers. In
some cases we may transfer personal information to
unaffiliated third-party data controllers. These third parties do not act as
agents or service providers and are not performing functions on our behalf. We
may transfer your personal information to third-party data controllers for the
following purposes: 1) to provide you with third-party offers; 2) to provide us
information about the quality of our services offerings. We will only provide
your personal information to third-party data controllers where you have not
opted-out of such disclosures, or in the case of sensitive personal
information, where you have opted-in if the disclosure requires consent. We
enter into written contracts with any unaffiliated third-party data controllers
requiring them to provide the same level of protection for your personal
information that is required of us. We also limit their use of your personal
information so that it is consistent with any consent you have provided and
with the notices you have received.
Protection
of Lucky Tycoon and Others. We may
share personal information when we believe it is appropriate to enforce or
apply our Terms of Service and other agreements; or protect the rights,
property, or safety of Lucky Tycoon, our products and services, our users, or
others. This includes exchanging information with other companies and
organizations for fraud protection and risk reduction. This does not
include selling, renting, sharing, or otherwise disclosing personal information
of our customers for commercial purposes in violation of the commitments set
forth in this Privacy Policy.
Response
to Subpoenas and Other Legal Requests. We
may share your information with courts, law enforcement agencies, or other
government bodies when we have a good faith belief we¡¯re required or permitted
to do so by law, including to meet national security or law enforcement
requirements, to protect our company, or to respond to a court order, subpoena,
search warrant, or other law enforcement request.
Sale
of Our Business. If we
sell, merge, or transfer any part of our business, we may be required to share
your information. If so, you will be asked if you¡¯d like to stop receiving
promotional information following any change of control.
With your Consent. Other than as set out above,
we will provide you with notice and the opportunity to choose when your
personal information may be shared with other third parties.
7.
Data Security
We have put in place appropriate security
measures to prevent your personal information from being accidentally lost,
used or accessed in an unauthorized way, altered or disclosed. In addition, we
limit access to your personal information to those employees, agents,
contractors and other third parties who have a business need to know. They will
only process your personal information on our instructions and they are subject
to a duty of confidentiality. We have put in place procedures to deal
with any suspected personal information breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.
8.
Data Retention
We will only retain your personal information for
as long as necessary to fulfil the purposes we collected it for, including for
the purposes of satisfying any legal, accounting, or reporting requirements. To
determine the appropriate retention period for personal information, we
consider the amount, nature, and sensitivity of the personal information, the
potential risk of harm from unauthorized use or disclosure of your personal
information, the purposes for which we process your personal information and
whether we can achieve those purposes through other means, and the applicable
legal requirements. In some circumstances you can ask
us to delete your data (see ¡°EU Data Subjects Legal Rights¡±). In some circumstances we may anonymize your personal information (so
that it can no longer be associated with you) for research or statistical
purposes in which case we may use this information indefinitely without further
notice to you.
9.
International Data Transfers
Lucky Tycoon has its headquarters in Hongkong.
Information we collect from you will be processed in Hongkong.
Where we transfer EU data subject¡¯s personal information to third parties
outside of the European Economic Area (EEA), we rely on appropriate suitable
safeguards or specific derogations recognized under data protections law,
including the GDPR. The European Commission has adopted standard data
protection clauses, which provide safeguards for Personal information
transferred outside of the EEA. We may use Standard Contractual Clauses
when transferring Personal information from a country in the EEA to a country
outside the EEA.
10.
EU Data Subjects Privacy Rights
EU data subjects have certain rights with respect
to your personal information that we collect and process. We respond to all
requests we receive from individuals in the EEA wishing to exercise their data protection
rights in accordance with applicable data protection laws.
¡¤ Access, Correction or Deletion. You may request access to, correction of, or deletion of your
personal information. You can often go directly into the Service under Account
Settings to take these actions. Please note that even if you request for your
personal information to be deleted, certain aspects may be retained for us to:
meet our legal or regulatory compliance (e.g. maintaining records of
transactions you have made with us); exercise, establish or defend legal
claims; and to protect against fraudulent or abusive activity on our Service.
Data retained for these purposes will be handled as described in Section 9
¡°Data Retention¡±, above.
¡¤ Objection. You
may object to processing of your personal information where we are relying on a
legitimate interest (or those of a third party) and there is something about
your particular situation which makes you want to object to processing on this
ground as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal information for
direct marketing purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which override your
rights and freedoms.
¡¤ Restriction. You
have the right to ask us to suspend the processing of your personal information
in the following scenarios: (a) if you want us to
establish the data¡¯s accuracy; (b) where our use of the data is unlawful but
you do not want us to erase it; (c) where you need us to hold the data even if
we no longer require it as you need it to establish, exercise or defend legal
claims; or (d) you have objected to our use of your
data but we need to verify whether we have overriding legitimate grounds to use
it.
¡¤ Portability. You
have the right to request the transfer of your personal information to you or
to a third party. We will provide to you, or a third party you have chosen,
your personal information in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information which you
initially provided consent for us to use or where we used the information to
perform a contract with you.
¡¤ Withdraw Consent. If we have collected and processed your personal information with
your consent, you can withdraw your consent at any time. Withdrawing your
consent will not affect the lawfulness of any processing we conducted prior to
your withdrawal, nor will it affect processing of your personal information
conducted in reliance on lawful processing grounds other than consent.
¡¤ File a complaint. You have the right to file a complaint with a supervisory authority
about our collection and processing of your personal information.
To file a request or take action on one of your
rights, please contact us at the contact details provided. You will not have to
pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with
your request in these circumstances.
We may need to request specific information from
you to help us confirm your identity and ensure your right to access your
personal information (or to exercise any of your other rights). This is a
security measure to ensure that personal information is not disclosed to any
person who has no right to receive it. We may also contact you to ask you for
further information in relation to your request to speed up our response. We
try to respond to all legitimate requests within one month. Occasionally it may
take us longer than a month if your request is particularly complex or you have
made a number of requests. In this case, we will notify you and keep you
updated.
11.
Children¡¯s Privacy
We are committed to complying with the laws
protecting the privacy of children, including the United States¡¯ Children¡¯s
Online Privacy Protection Act (COPPA). Our Services are not directed to
children under the age of 16. We do not knowingly collect personal information
from children under the age of 16. If we receive personal information that we
discover was provided by a child under the age of 16, we will promptly c such
information. If you would like to learn more about COPPA, visit the Federal
Trade Commission home page at http://www.ftc.gov.
12.
Changes to our Privacy Policy
By using this website, you agree to the terms and
conditions contained in this Privacy Policy and Conditions of Use and/or any
other agreement that we might have with you. If you do not agree to any of
these terms and conditions, you should not use this website. You agree that any
dispute over privacy or the terms contained in this Privacy Policy will be
governed by the laws of the State of California. You also agree to arbitrate
such disputes in California, and to abide by any limitation on damages
contained in any agreement we may have with you.
This Policy is expected to change from time to
time. We reserve the right to amend this Privacy Policy at any time and provide
notice to you by posting of the amended Privacy Policy on the website. We may
also email you to give you notice of material changes to this Privacy Policy.
The provisions contained herein supersede all previous notices or statements
regarding our privacy practices and the terms and conditions that govern the
use of this Services.
13.
How to Contact Us
If you have any questions or wish to register a
complaint in relation to this Privacy Policy or the manner in which your
personal information is used by us, please contact us: support@luckygo.life