PokerStars VR and Lucky VR Inc. Privacy Policies

PokerStars VR Privacy Policy

Overview

Below you will find our Privacy Policy which tells you about how we will process your personal data and about rights that you have under data protection. We strongly recommend that you familiarize yourself with this Privacy Policy. However, we understand that people have busy lives and so want to provide you with a quick overview of how we will use your personal data – please remember though that this first section is an overview only and should not be read instead of reading the full Privacy Policy below.

We process your personal data for the purposes discussed in detail below, but the two main purposes are to enable us to provide you with services and to comply with our regulatory obligations, specifically:

· On the first of these, in order for us to offer you with services we will need you to register a user account and provide bank details to deposit money.

· On the regulatory aspect, we are required to monitor our customers and to keep records of transactions to ensure that we are offering a fair, responsible and safe service – and this includes verifying your age and monitoring our customers to ensure that they are gambling within their means.

Introduction

This Privacy Policy applies to our websites, applications, goods and services that link to this policy or which do not have a separate privacy policy. The purpose of this Privacy Policy is to provide you with information about how we use your personal data. This Privacy Policy may be updated from time-to-time so we recommend that you review it regularly, however where we make material changes, we will make sure to alert you to this.

Who is the Controller?

The controller (formerly known as data controller) of your personal data is TSG Interactive Services (Ireland) Limited, Belfield Office Park, Beech Hill Road, Clonskeagh, Dublin 4, Ireland. This is who we refer to in this Privacy Policy when saying "TSG", "we", "our" and "us" etc.

And, what about the Data Protection Officer, or is it DPO?

Yes, we have appointed a Data Protection Officer (DPO). While our DPO can be reached at dpo@starsgroup.com, our Customer Service team will be your initial point of contact if you wish to exercise your rights. Please see the 'Your Rights' section below.

What is meant by the "Group"?

Reference to the Group within this Privacy Policy means Flutter Entertainment plc and all or any of its direct or indirect subsidiary undertakings, joint venture partners, and their related companies wherever located in the world as may exist from time to time including, but not limited to, Paddy Power, Betfair, Timeform, Sportsbet, BetEasy, FanDuel, TVG, Adjarabet, Sky Betting and Gaming, Full Tilt, PokerStars, Junglee, Singular and FOX Bet.

How we collect your personal data

In order to provide you services, you will need to create a user account. When creating this user account, you will need to submit certain personal data such as your name, age, address and email. Additional information will also be required for you to utilize some of our services, such as your bank card details.

We also collect information about the transactions you make, including your gambling activity. We may collect personal data through surveys which we, or companies engaged by us for such purpose, undertake. In addition, we collect information about your use of our websites, mobile applications and services. We will also collect other information necessary for us to process your personal data for the purposes set out in this Privacy Policy.

Where you contact us, we will process any personal data you provide in these communications.

We may also collect personal data from third party service providers, such as credit reference agencies and fraud prevention companies.

Finally, we also use "cookies" and similar technologies which may collect certain information about you, such as your devices' IP addresses and online activity, some of which will constitute your personal data. You can learn more about the cookies we use in the 'Cookies' section below.

How will we use your personal data

In accordance with data protection laws, we will only process your personal data when we have a lawful basis for doing so in respect of your personal data. We process your personal data if: (i) it is necessary to provide services to you under the performance of the contract we have with you; (ii) we are required to do so in accordance with legal or regulatory obligations; (iii) you have given your consent; or, (iv) it is in our legitimate interests to process your personal data, provided that none of these interests prejudice your own rights, freedoms and interests.

With the exception of limited circumstances, we do not process special categories of personal data about you (such as personal data relating to your health, ethnicity, religion, political persuasion, trade union membership or sexuality) or personal data relating to criminal offences or convictions. For the limited circumstances in which we process special categories of personal data, we have set out the additional lawful basis required in italics below.

The following is a list of the purposes for which we may process your personal data, and the lawful basis on which it carries out such processing:

Purpose

Lawful Basis

To set-up, administer and manage your user account 

Necessary for the performance of a contract

To provide you with our services (including to allow you to play our games)

Necessary for the performance of a contract

To receive and respond to your communications and requests

Necessary for the performance of a contract if the communication relates specifically to our services, otherwise legitimate interests 

To notify you with important updates to our websites, mobile applications and services 

Necessary for the performance of a contract

To ensure that we are able to fulfil our regulatory obligations regarding your use of our services, including by verifying the accuracy of any information you provide us, verifying your identity and verifying your age (which may involve us disclosing your personal data to third parties or supplementing your personal data with information received from third parties (such as credit reference agencies)) 

Necessary to comply with a legal or regulatory obligation

To ascertain sources of funds and wealth, and to determine your ability to afford the amount you spend 

Necessary to comply with a legal or regulatory obligation 

To comply with our obligations under applicable laws (including gambling legislation, and regulatory and licensing requirements related to our gambling licenses) 

Necessary to comply with a legal or regulatory obligation

To identify and disclose any suspected unlawful, fraudulent, or other improper activity connected with our websites, mobile applications and services (including money laundering) 

Necessary to comply with a legal or regulatory obligation 

Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonesty / preventing fraud / suspicion of terrorist financing or money laundering  

To monitor gambling patterns and to identify possible responsible gambling concerns 

Necessary to comply with a legal or regulatory obligation 

Substantial Public Interest: Safeguarding of individuals at risk / safeguarding of economic well-being of certain individuals  

To prevent you from using our websites, mobile applications and services if you have requested that we do so (such as self-exclusion) 

Necessary to comply with a legal or regulatory obligation 

Substantial Public Interest: Safeguarding of individuals at risk / safeguarding of economic well-being of certain individuals  

To comply with any deposit, spend or loss limits that you have set or which have been applied to your user account 

Consent

To support any other purpose necessary for the performance of our contractual obligations or specifically stated at the time at which you provide your personal data 

Necessary for the performance of a contract

To identify any fraudulent use of our services

Necessary for a legal or regulatory obligation

To identify any breach of our terms of use 

Necessary for the performance of a contract

To carry out market research campaigns 

Legitimate interests of better understanding the products and services that our customers most enjoy 

To send out surveys to better understand our products and services 

Legitimate interests of better understanding the products and services that our customers most enjoy 

To review the results of surveys completed by you 

Consent

To prepare statistics relating to the use of our websites, mobile applications and services by you and our other customers 

Legitimate interests of understanding the use of, and therefore improving, our products and services

To send offers and promotions relating to our services that you may be interested in 

Consent

To record telephone calls to and from, and live chats with, our customer services representatives for training purposes  

Legitimate interests of improving our customer services

To record telephone calls to and from, and live chats with, our customer services for security and regulatory purposes 

Necessary for a legal or regulatory obligation

To use your name, image, username or location in publicity and marketing, but only when you have provided express and informed consent for us to do so 

Consent

Sharing: To share your personal information with other members of the Group who assist in providing the services to customers 

Legitimate interests to allow us to provide services

Sharing: To share your personal data with our professional advisors, such as lawyers and consultants 

Legitimate interests to allow us to seek advice

Sharing: To share personal data with other members of the Group to ensure that responsible gambling measures can be applied across the group 

Necessary for a legal or regulatory obligation

Sharing: To share your personal data with social media services to provide you with ads on social media sites, unless you have requested not to receive such ads via your social media account 

Legitimate interest of better advertising our products and services

Sharing: To share your personal information with third parties for identity and geolocation verification 

Necessary to comply with a legal or regulatory obligation

Sharing: To share your personal information with third parties for fraud and anti-money laundering detection purposes  

Necessary to comply with a legal or regulatory obligation 

Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonesty / preventing fraud / suspicion of terrorist financing or money laundering  

Sharing: To share your personal data with law enforcement agencies for the prevention and detection of crime 

Legitimate interests of helping to protect our services and our community 

Substantial Public Interest: Preventing or detecting unlawful acts / protecting the public against dishonesty / regulatory requirements relating to unlawful acts and dishonesty / preventing fraud / suspicion of terrorist financing or money laundering  

Sharing: To share your personal data with national self-exclusion databases if you have self-excluded

Necessary to comply with a legal or regulatory obligation 

Substantial Public Interest: Safeguarding of individuals at risk / safeguarding of economic well-being of certain individuals  

Sharing: To share your personal data with gambling regulators in order to assist and comply with any investigation 

Necessary for a legal or regulatory obligation

Cookies: To operate our websites and mobile applications, including allowing you to interact with our websites and mobile applications and to recall selections as you move between pages 

Legitimate interest of using a website with at least standard functionality to provide our services

Cookies: To analyze your use of our website, monitor our web audience and populate certain content on our website in line with your usage 

Consent

Cookies: To track your journey to and from our website so we can understand how customers come to and from our website and give effect to any commercial arrangements 

Consent 

Cookies: To comply with regulations, including identifying multiple user accounts, attempts to login to an unauthorized user account or potential fraud 

Necessary to comply with a legal or regulatory obligation

 

Performance of a Contact  

In addition to the purposes set out above, we may also process your personal data for other purposes that we deem compatible with those listed above. We will update this Privacy Policy accordingly, when we do this.

Please note that the lawful bases set out above are those which will primarily apply although it is possible that a change in circumstance may result in a change in lawful basis – for example, if you close your user account with us we will no longer process your personal data to perform a contract with you but will continue to do so in order to comply with legal requirements.

Intra-Group Sharing

We are part of the Group and there will be instances where your personal data is shared with other members of the Group. This will occur in the following circumstances:

· to enable us to identify and replicate responsible gambling measures (such as self-exclusion) to players across the Group (necessary to comply with a legal/regulatory requirement);

· to assist with account management, identification and verification of our customers as well as other regulatory checks (necessary to comply with a legal/regulatory requirement);

· to help ensure that customer information is up-to-date and accurate (necessary to comply with a legal/regulatory obligation);

· to identify customers who have committed or are suspected of fraud, money-laundering or other criminal acts (necessary to comply with a legal/regulatory requirement);

· to identify customers who have breached our Terms of Service or other terms and conditions related to our services (legitimate interests);

· to send cross-brand marketing materials where customer has requested this (consent); and

· to analyze and better understand our business, customers, products and services across the group (legitimate interests).

We may also in the future share personal data with other members of our Group for purposes that are related to and compatible with those set out above. Finally, where we are required by law or regulation to share personal data throughout our Group for reasons beyond those set out above we will be required to do this.

Please check this Privacy Policy frequently to learn of any updates to our intra-group sharing.

Disclosing your personal data

In addition to the purposes involving the sharing of your personal data listed above, we will also disclose your personal data to processors we engage, specifically Lucky VR. We will have a contract in place with each such processor to ensure your personal data is kept secure.

In addition to Lucky VR, Pokerstars VR (or Lucky VR on our behalf) will also use processors to provide other services such as email and support services, game support services, analytics providers and server providers.  Pokerstars VR also uses ToxMod for the purposes of chat moderation.  In each case, contracts will be in place to ensure that these providers process your personal data only on our behalf.  

 

We may also disclose your personal data in the following circumstances:

· when required by applicable law or regulation (disclosure to a governmental, regulatory or enforcement authority);

· in order to defend ourselves legally and/or in relation to legal proceedings; and

· whilst negotiating a takeover, purchase or merger, and pursuant to the same.

Transferring your personal data outside of the EEA

We store your personal data in the Isle of Man, a territory that has received an Adequacy Decision from the European Commission regarding its suitable data protection laws. Your personal data may also be accessed by members of the Group who are located outside of the European Union and in such cases we have implemented standard contractual clauses to ensure adequate protection of your personal data.

We may also share your personal data with third parties outside of the European Union and in all such cases we will ensure that standard contractual clauses or an Adequacy Decision is in place to protect your personal data.

Security

We will take appropriate security, technical and organizational measures to ensure that your personal data is kept secure and to prevent the theft, loss or unauthorized access to your personal data. It is important to understand however that security can never be guaranteed and you will not hold us liable save where the security of your personal data is compromised due to our negligence.

Marketing

If you have signed up to services offered by us we may send you direct marketing in relation to other services offered by us or our Group provided that you have given your consent to receive such marketing.

At any time you can manage your marketing consents via your user account. You can also unsubscribe by using the tools in any marketing communication you receive. Please note that if you unsubscribe from marketing it may take up to five working days for this to take effect.

Social Media Marketing

We may also use information you provide to us to show you relevant advertising and personalized content about our Group's services on certain third party social media platforms (Social Media Sites) made available to us through relevant service providers (e.g. Facebook, Twitter). If you do not wish to see these advertisements, you can change your settings on the Social Media Sites. If you do not want us to share this information with Social Media Sites you can contact us directly.

Cookies

In this Privacy Policy, we use the expression 'cookie' to refer to cookies and similar technologies we use to store information (such as web beacons). A cookie is a simple text file that is stored on your computer or mobile (or other) device by a website's server, and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information, such as a unique identifier and the website name and some digits and characters.

Almost all websites and applications you visit, including our websites, will use cookies in order to improve your user experience by enabling that website and/or application to 'remember' you, either for the duration of your visit (using a 'session cookie') or for repeat visits (using a 'persistent cookie').

Cookies are used to improve your use of a website or application, for example through letting you navigate between pages efficiently and storing your preferences. Cookies make the interaction between you and the website faster and easier. If a website or application doesn't use cookies, it will think you are a new visitor every time you move to a new page on the website. Cookies can also be used to enable targeted advertising and analyzing your browsing of a website.

You can learn more about cookies generally and how to disable them on your browser here.  

You can learn more about what advertising cookies exist on your device and you can disable them directly by clicking here.

Retention of your personal data

We retain your personal data for six years. Six years is calculated from the closure of your user account or where your user account has been dormant for this period. There are some exceptions to this retention period, namely:

· If you self-exclude from any of our services, we will retain this information indefinitely.

· If you are under investigation or we have identified possible fraud, money-laundering, criminal activity we may retain your personal data for longer.

· If there is a legal dispute, we will retain your personal data for the duration of the dispute and for six years thereafter.

Updating your personal data

You can update some of your personal data at any time via your user account. We request that when your personal data changes you update your user account as soon as possible.  If you are unable to change your information via the PokerStars VR Help Center or  email at support@getluckyvr.com

Your rights

You have the following rights in relation to your personal data:

· a right to access your personal data held by us (also known as a subject access request);

· a right to receive certain personal data in machine-readable format;

· a right to have inaccurate or out-of-date personal data rectified;

· where we have specifically requested your consent to process your personal data and have no other lawful conditions to rely on, you have the right to withdraw this consent;

· a right to have certain personal data erased/deleted where it is no longer necessary for us to process it, if you have withdrawn your consent pursuant to the paragraph above, where you have objected pursuant to the paragraph below, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;

· a right to object to the processing if the lawful basis is that it is in our legitimate interests to process your personal data, but please note that we may still process your personal data if there are other relevant lawful bases or if we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;

· a right to request an explanation of the logic involved if we make decisions about you solely through automated means; and

· a right to object to direct marketing, which can be done by opting-out of direct marketing either through your user account or by opting out via the communication itself. You also have a right to object to any profiling to the extent that it relates to direct marketing only.

If you are unsure about your rights or are concerned about how your personal data may be processed, contact our Data Protection Officer at dpo@starsgroup.com or the PokerStars VR Help Center or email at support@getluckyvr.com, or contact your national data protection supervisory authority.

If you would like to exercise any of your rights then you can do so by contacting our Data Protection Officer at dpo@starsgroup.com or the PokerStars VR Help Center or email at support@getluckyvr.com. Your rights request will then be addressed. Please be aware that while we will try to accommodate any request you make in respect of your rights, this right is not absolute. Please see section "Retention of your personal data" for more information.

When you make a request in respect of your rights, we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity, but it may take longer (we will notify you if this is the case). If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

Supervisory authorities

If you have any complaints you have the right to contact your own national data protection supervisory authority however we do ask that you contact us in the first instance to allow us the opportunity to address your concerns.

Contact us

If you have any questions regarding our use of your personal data, or you would like to exercise any of your rights, please navigate to settings in the App and click on either Facebook Messenger or Twitter. You can also contact our Data Protection Officer at dpo@starsgroup.com.

Privacy Policy last revised: March 3, 2022

Lucky VR Privacy Policy

LuckyVR Inc. ("LuckyVR"/"we"/"us"/"our") is committed to protecting your privacy. We make the website, www.getLuckyVR.com (the "Website") available together with the LuckyVR virtual reality online casino games (the "Service").‍

As you use our services, we want you to be clear how we’re using information and the ways in which you can protect your privacy.‍

Our Privacy Policy explains:

·   What information we collect and why we collect it.

·   How we use that information and when we disclose it.

·   How to access and update your personal information.

‍Your privacy matters to us so please take the time to familiarize yourself with our policies, and if you have any questions please contact us at Support@GetLuckyVR.com.

‍This Privacy Policy is provided in a layered format so you can click through to the specific areas et out below.

1.  IMPORTANT INFORMATION AND WHO WE ARE

‍Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how LuckyVR collects and processes your personal information through your use of the Website and the Services, including any information you may provide when you sign up for a demo of our Services, when you create an account and a profile with us, when you purchase or use our Services, when you submit a recording or video, when you search our Website, when you subscribe to our email alerts, when you contact our customer service, when you participate in surveys, public forums, chats, or when you respond to one of our requests for suggestions and other content.

‍Please note that neither the Website nor the Service is intended for minors (this varies by jurisdiction, but is typically those under 21 years of age). No one who is a minor in their country of use may provide any information to or on this Website or through our Services. We do not knowingly collect personal information from minors. If you are a minor (or, if you are unsure, if you are under 21 years of age), do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a minor without verification of parental consent, we will delete that information.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.

‍Changes to the Privacy Policy and your duty to inform us of changes

‍We reserve the right to change the terms of this Privacy Policy at any time. When we do, we will post the revised Privacy Policy to our Website and the last revision date of revision will be updated so that you will always be able to understand what information we collect, how we use your information, and under what circumstances we may share your information with others.

‍It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Third-party Links

This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

2.  THE INFORMATION WE COLLECT ABOUT YOU

Personal data, or personal information, means any information relating to an identifiable person who can be directly or indirectly identified. It does not include data which cannot be related to an identifiable person (anonymous data).

We may collect, use, store and transfer different kinds of personal information about users of the Website or Service (“you” or “your”) which we have grouped together follows:

·   Identity Data includes first name, last name, username or similar identifier.

· Contact Data includes billing address, delivery address, email address and telephone numbers.

·   Financial Data includes payment card details.

·   Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

·   Technical Data includes internet protocol (IP) address, your mobile device’s unique ID number, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website.

·   Profile Data includes your username and password, purchases or orders made by you, your location,  preferences, feedback and survey responses.

·   Usage Data includes information about how you use our Website, app(s) and Services, such as voice chat, the buttons, controls, products and ads you click on, pages of our application or Website that you visit, the time spent on those pages, your search queries, the dates and times of your visits, but also about the webpage you were visiting before you came to our Website app(s) and the webpage, app(s) you go to next

·   Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this information does not directly or indirectly reveal your identity. 

For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. 

While you may include such information in your recordings, we do not intentionally store, access or classify any such information and you are solely responsible for the inclusion of any such information. We encourage you not to include any unnecessary personal information, including in particular any Special Categories of Personal Information, in any recordings that you submit through the Services.

If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3.  HOW IS YOUR PERSONAL INFORMATION COLLECTED

We use different methods to collect data from and about you including through:

·   Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

‍This includes personal data you provide when you:

· sign up for a demo of our services

· create an account and profile with us

· purchase one of services

· subscribe to our email alerts

· complete one of our online forms to receive our reports and case studies

· contact our customer service

· request marketing to be sent to you or give us some feedback.

‍·   Automated technologies or interactions. As you interact with our Site or Service, we may automatically collect

Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies.

‍·   Information from Third Party Platforms. We may automatically receive your personal information from the platform through which you downloaded and play the Game (e.g. Oculus, Steam). Personal Information collected by the third-party platform that you use to access the Game is subject to the applicable third-party terms of use and/or privacy policy (for more information, please see the Oculus Privacy Policy, Steam Privacy Policy Agreement as applicable, which Third party platforms privacy policies will contain provisions detailing data transmissions to us). For instance, when you first play the Game using the Oculus store, your Oculus ID will automatically be transmitted to us, with no action on your part.  Our use of your personal information collected through the Game is limited to the purposes described in the “How We Use Your Information” section below.

‍·   Revealing personal information in the VR Casino. You may choose to reveal personal information in the game through multiplayer chat or other public functions, including through your username. In addition to being accessible to other users of the game with whom you are interacting, we may also capture this information using recording functions that we use to monitor users’ activity in the game. We cannot control how other users will use personal information that you reveal using multiplayer chat or other public functions, so, if you reveal personal information through multiplayer chat or other public functions, you are doing so at your own risk. Similarly, users must not create a username that reflects their own real name or reveals personal information. If you include personal information in your display name, you are doing so at your own risk.

‍·   Third parties or publicly available sources. We may receive personal information about you from various third parties and public sources as set out below :

‍·   Technical Data from the following parties:

‍a. analytics providers such as Google Analytics based outside the EU;

b. search information providers such as Google based inside or outside the EU.

‍·   Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the EU.

·   Identity and Contact Data from our partners, data brokers or aggregators based inside or outside the EU.

·   Identity and Contact Data from publicly available sources such as LinkedIn, Instagram, and other social networking sites based outside the EU.

4.  HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

The types of lawful basis that we will rely on to process your personal data are:

Legitimate Interest  - this means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

‍Performance of Contract – this means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

‍Comply with a legal or regulatory obligation -this means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

‍Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

‍Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also 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 information. 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.

Marketing

‍We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. You may elect to opt out of receiving any further marketing or advertising emails from us through the mechanism provided in those emails.

‍Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

‍You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal information with any company outside our company for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.

‍Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a service purchase, service experience or other transactions.

‍Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at Support@GetLuckyVR.com.

‍If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

‍Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 5.  DISCLOSURES OF YOUR PERSONAL INFORMATION

Purposes described above. We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above:

  • Service providers who provide IT and system administration services.
  • Social networking sites to which you have linked your account.
  • Professional advisers including lawyers, bankers, auditors and insurers based in Canada and the United States who provide consultancy, banking, legal, insurance and accounting services.
  • Regulators and other government authorities based in Canada, the United States, the EEA or other jurisdictions who require      reporting of processing activities in certain circumstances, or where otherwise required required to do so by law or legal process.

Publishers. Our services are frequently published or otherwise made available by third parties (“Publishers”). These publishers include, without limitation, the publisher of the game Stars Mobile Limited. Where our services are made available through a Publisher, we will share your personal information with that Publisher for the purpose of allowing you to use the Service. You should consult the privacy policy of such Publishers in addition to our Privacy Policy, as we do not control how they use your Personal Information.

Acquisitions. We may share your personal information with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

Other. We may also share your personal information:

·   With your consent;

·   As may be necessary to protect your safety or the safety of other users;

·   To our affiliates and subsidiaries, to the extent consistent with this privacy policy, and who treat the information in confidentiality;

·   To enable us to take precautions against liability; or

·   To protect the safety and security of the Services.

 

6.  INTERNATIONAL TRANSFERS

We share your personal information within our company. This will involve, if you are based in the European Union, transferring your data outside the European Economic Area (EEA).

Many of our external third parties (as described in this policy) are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.

If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION

How long will you use my personal information for?

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other legally required purposes.

In some circumstances you can ask us to delete your information: see Request erasure below for further information.

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.  Data Subject Rights

We aspire to respect the privacy rights of all users, regardless of where they live. Accordingly, except as otherwise provided in this privacy policy, we will promptly act on users’ requests that we:

·   Confirm that we have their personal data;

·   Provide them with access to their personal data that we possess, including in portable format;

·   Correct, update or amend their personal data;

·   Delete and “forget” their personal data;

·   Object to our use or disclosure of their personal data; and

·   Limit our processing of their personal information.

Users may withdraw any consent they have provided us to process their personal information. Exercise of any of the rights listed in this section usually doesn’t apply retroactively from the date of the request and doesn’t affect our ability to continue processing information lawfully. Note that the rights enumerated in this section have certain limitations and exceptions under applicable law.

‍If you’d like to exercise any of the data subject rights described in this section, please reach out to us by email at  Support@GetLuckyVR.com We may use your personal information to verify your identity before acting on your request.

Lastly, users will always have the right to lodge a complaint about our privacy practices with the appropriate supervisory authority. However, we’d much rather you contact us first, so we can try to address any concerns that you have about our privacy practices. As a Canadian corporation with its primary offices in Ontario, our primary supervising authority is Office of the Privacy Commissioner of Canada, 30, Victoria Street, Gatineau, Quebec, K1A 1H3, Canada.

 Effective date: Mar 17, 2022