Privacy Policy
1. Introduction
ThirtyNine Interactive Limited (in the following referred to as “ThirtyNine Interactive” ,“We”, “us” or “our”) is committed to respect the privacy choices of our users（“you”）.
This Privacy Policy is intended to help you better understand how we collect, use and store your personal information when you use the mobile application “Lucky Chest – Win Real Money” or jointly referred to as the “Luck Chest” (the “App”) on Android or iOS platforms (the “Service”). Please read the policy carefully to understand our views and practices regarding your privacy. By downloading the App or using any of our Service, you are agreeing to the terms of this Privacy Policy.
we may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. we will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page. By continuing to use the Service or our website, you agree to the revised policy.
2. What information we collect
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.
1) Non-personal information: When you use the App, we may collect non-personally identifiable information from you and it may include, without limitation: (a) the type of handset device and mobile operating system you are using (e.g. Android, iPhone, etc.) (b) the date and time you access this App and the duration of your visit. (c) mobile page views. (d) click-through statistics. (e) behavioral usage of the App. (f) IP address (which may identify your general geographic location). (g) generalized, non-specific location data.
We only use this information for statistical purposes, and not in a manner that would give us sufficient information to identify you personally. This information helps us better understand regarding the use of this App, including where users are generally located, which features are the most popular with our users and what are their general mobile usage behavioral patterns. That information also allows us to determine if this App is working properly, make changes to the App that allows users to have better experiences and improve the App, our offers and promotional content so that they are more relevant to our users. In addition, we may use any such information for security, system integrity (the prevention of hacking, cheating and other improper or unlawful activities), or enforcement purposes.
2) Personal information: We also collect personal information about you when you access or use the App and it may include, without limitation:(a) first and last name (b) date of birth (c) gender (d) profile photo if you upload it (e) email address (f) account Information, this may include your username and password, your preferences, feedback and survey responses. (g) mailing address (h) telephone number
(h) transaction Information, this may include information you provide for the purposes of sending payments to you, such as the email address associated with your PayPal account. It also includes the records of payments made to you, the amounts paid to you, and other information associated with payment transactions. (i) geolocation data, we collect your geolocation data whenever you choose to access the rewards or wallet features and play our raffle and lottery scratcher games. We use this data to determine which currency to pay you in, which rewards to offer, and our legal obligations in that jurisdiction. (j) If you register or login through your Facebook or Google credentials, we may collect some personal information through your Facebook or Google account.
If you object to providing any personal
information, it may be possible for you to use portions of the App or abandon
to use the App. However, if you continue to utilize all features of the App,
including without limitation, receiving payments if you win, it may be
necessary to provide the personal information. We use this information to
provide you with our Services; for example, to confirm your identity, contact
you, provide you with advertising. We also use this information to make sure
that we comply with applicable legal requirements.
3. Marketing and Advertising Practices
We may reach out to you in different ways, for example, to tell you about new features, games, or sweepstakes on the App we think you’d be interested in, or to show you how to use a particular feature we think you may enjoy. However, you can also let us know that you’d rather not hear from us with this type of communication.
Promotional Offers from Lucky Chest. We may use any of the categories of personal information we collect to make decisions about what we think you may desire or need as our consumer. We will only make these marketing decisions if you agree to receive email marketing from us. In all cases, we allow you to opt-out of receiving marketing communications from us.
Interest Based Advertising. Lucky Chest uses advertising to help fund our services and we utilize and numerous advertising technology platforms to help deliver relevant advertising to you. Lucky Chest and the technology service provider may collect, receive, or use your personal data in connection with our use of the platform in order to provide interest-based advertising to you. In such cases the advertiser is acting as a controller of the data for its own purposes.
Most of the third-party advertising and data companies we work with, including subscribe to the DAA Principles and/or are members of the Network Advertising Initiative (“NAI”).
Please refer to the privacy policies of our advertising partners for more information on how to exercise your rights and control your advertising choices. Our advertisers include the following:
· AdColony: https://www.adcolony.com/privacy-policy/
· Google’s AdMob: https://policies.google.com/privacy
· AppLovin: https://www.applovin.com/privacy/
· Facebook: https://www.facebook.com/about/basics/advertising
· Unity: https://unity3d.com/legal/cookie-policy#cookies
· Vungle: http://vungle.com/privacy
· Fyber: https://www.fyber.com/privacy-policy/
Mobile App Advertising and Tracking. Lucky Chest, our authorized service providers and/or other third-party partners (listed above) involved in the delivery of advertising you receive through our App may collect information about your mobile device, including your mobile device’s advertising identifiers and the names and IDs of apps you have installed, as well as information about how you use our mobile applications and other unaffiliated applications. We and our partners use this information to enable interest-based advertising you receive through our Services and within third-party apps and other marketing channels. Depending on your device and operating system, you may be able to reset your mobile device’s advertising identifier to limit this data collection or prevent the collection of usage data across unaffiliated applications for interest-based advertising purposes by accessing the privacy settings on your mobile device. Each operating system, iOS for Apple devices, Android for Android devices and Windows for Microsoft devices, provides its own instructions. Visit the privacy settings for your mobile device for more information.
In addition, you may see our services advertised in other services. After clicking on one of these advertisements and installing our app, you will become a user of our Service. In order to verify the installs, a device identifier may be shared with the advertiser.
Social Media Advertising. Lucky Chest also runs other kinds of online ad campaigns on social networking websites and other non-Lucky Chest websites and apps. Some of these ads may be based on information we have about users. If Lucky Chest provides information to a website or app for these advertising purposes, the information may only be used to display the Lucky Chest ad. Please see the privacy policy of the website or app where a Lucky Chest ad is shown for more information about its privacy practices and privacy choices it may offer.
3. Who we share information with
(a) Third Party Service Providers, affiliates and partners. We do not sell, trade or rent your information to others. We work with a variety of third parties and service providers such as third-party subcontractors, affiliates of us, retailers, fulfillment partners and marketing partner to help provide you with our Services and we may share information with them to support these efforts. For example, companies we've hired to provide data analytic services may need to collect and access personal information to provide those functions. In such cases, these companies must abide by our data privacy and security requirements.
(b) Disclosures to the Public. Some of your personal information will be shared with the general public, including your first name and last name initial, city, state, and country. 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.
(c) Protection of Lucky Chest 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 Chest, 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.
(d) 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.
4. How we protect your information
In order to protect your personal information held with we and third parties we work with, we use industry-standard physical, procedural and electronic security measures, including encryption where deemed appropriate. We take reasonable measures to help protect your information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
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 “Your Information 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.
6. Your Information Rights
You have rights to restrict us to collect and use your personal information.
These may include the rights：
1) To request access to and a copy of your personal information;
2) To request erasure of your personal information. 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.
3) To restrict or object to collection and using of your personal information;
4) To withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
5) To exercise any of your rights, please contact us. We may ask you to verify your identity, and act upon your requests in accordance with applicable laws.
7. Applicable Provisions for EU residents
When you are located in the European Economic Area (EEA), you will have following additional rights:
1) To ask for a copy of your personal information to be provided to them, or a third party;
2) To lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.
When you are located in the European Economic Area (EEA), your personal information will be transferred to recipients in countries located outside the EEA, which do not provide a similar or adequate level of protection to that provided by countries in the EEA. We rely on appropriate suitable safeguards or specific derogations recognized under data protections law, including the GDPR.
You hereby expressly consent to the transfer of your personal information to recipients, as described in this Privacy Policy, which are located outside the EEA. You may withdraw your consent at any time.
9. Updating Information
You can use your accounts of the App to update and correct your personal information. You can also contact us by "Contact" and ask us to update or correct your information.
10. Protection of Children
We do not knowingly collect personal information about children under the age of 13 (in EEA is under the age of 16). If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.
11. Contact
If you have any questions about your personal information or this policy, please contact us by email at support@luckychest.io