Privacy Policy

1.Overview

This Privacy Policy explains how Lucky Winner Ltd( or “we”, “us”, “our”) collect your
information through our Lucky Winner Ltd Service. We fully respect and protect users’
personal privacy. While providing you with quality services, we will collect, use, disclose,
store and protect your personal data in accordance with this Privacy Policy (hereinafter
referred to as “this Policy”).

We hope that through this policy we will introduce you to how we handle your personal data
and provide you with access to and control over your personal data.

Please read and fully understand this policy before using this product. If you have any
questions about this policy, or have any complaints or suggestions, please contact us
through the contact information shown in this policy.

This policy aims to explain to you the following:

The Data We Collect About You

How We Collect Your Personal Information
How We Collect Your Personal Information
How We Use Your Personal information
Marketing and Advertising Practices
Disclosures Of Your Personal information
Data Security
Data Retention
International Data Transfers
EU Data Subjects Privacy Rights
Children’s Privacy
Changes to our Privacy Policy
How to Contact Us

2.The Data We Collect About You

A) Demographic Information.
For some activities, your handset may transmit certain geographic information or information
regarding you, your mobile device or location to the Company. The Company may use that
information to generate aggregate statistics about our user community and may provide that
information to advertisers and other parties with whom we have a business relationship. In
addition, the Company may use any such information for security, system integrity (the
prevention of hacking, cheating and other improper or unlawful activities), or enforcement
purposes.

When you use this App, we may, at our option, automatically collect and store the following
types of non-personally identifiable information received from you:

(i) click-through statistics.

(ii) behavioral usage of the App

(iii) your country.

(iv) the type of mobile operating system you are using.

(v) the date and time you access this App and the duration of your visit.

(vi) mobile page views.

(vii) the type of handset device and mobile operating system you are using

(e.g. Android, iPhone, etc…). The Company only uses this data in aggregate form, for
statistical purposes, and not in a manner that would give the Company sufficient information
to identify you personally. Automatically collected information of that kind typically provides
us with a greater understanding regarding the use of this App, including which features are
the most popular with our visitors, what types of content, games, offers and products our
users are interested in, where they are generally located 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 on the App,
and improve the App, our offers and promotional content so that they are more relevant to
our users. We collect that information and track it for statistical purposes; we do not use it to
identify or to market to a particular user. This information may be shared with advertisers,
fulfillment partners and other third parties on an aggregated basis, but it does not include the
Personal Information of individual users (defined below).

B) Personal Information.

The Company may also, at its option, collect personally identifiable information from you
when you use some of the features on the App. The Company stores your Personal
Information on its servers and/or may share and store such Personal Information with third
party subcontractors, affiliates of the Company, retailers, fulfillment partners and marketing
partners.
"Personal Information" may include, without limitation: your first and last name, gender, your
email address, your cell phone number, date of birth and account name, geographic location,
game feature uses and preferences, and other demographic information that could help
identify you. We may obtain some Personal Information through your Facebook account if
you register through your Facebook credentials. If you have set up an account that is
password protected in order to use any feature on the App or for any other purpose for which
a password is needed, that password is also part of your Personal Information. It may be
possible to use portions of this App without providing any Personal Information, but it may be
necessary to provide Personal Information to utilize all features of this App, including,
without limitation, receiving payments if you win.

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, telephone, text/SMS, post, or
otherwise. This may include personal information you provide when you:

Subscribe for our Services/Register for an Account;

Request that the App be texted to you;
Request marketing be sent to you;
Enter a game, competition, promotion, or survey,
Provide us feedback, requests support, or otherwise 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.

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 may use information collected from you in any one or more of the following ways:

To create game accounts and allow users to play our games;

To identify and suggest connections with other Lucky Winner Ltd users;
To solicit input and feedback to improve Lucky Winner Ltd products and services and
customize your user experience;
To send you related information, including confirmations, invoices, technical notices,
updates, security alerts, and support and administrative messages;
To communicate with you about promotions, rewards, upcoming events, and other news
about products and services offered by Lucky Winner Ltd and our selected partners;
To prevent fraud or potentially illegal activities, and enforce our Terms of Service;
To link or combine it with other information we get from third parties, to help understand your
preferences and provide you with better services;
To enable you to communicate with other users;
To give you opportunity to invite your contacts from a SN Service (such as your Facebook
friends) so that those contacts can be located in Lucky Winner Ltd games or you can invite
them to join you in Lucky Winner Ltd games.
5.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 Winner Ltd. 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 Winner Ltd uses advertising to help fund our services and
we utilize and numerous advertising technology platforms to help deliver relevant advertising
to you. Lucky Winner Ltd 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”). To learn
more about the information collection practices of NAI members and your related opt-out
choices, please visit the NAI’s website here. For more on EU online choices, please visit the
EU online choices website here. You can opt out of interest-based advertising from Google
by visiting the About Google Ads page or opt out of the DoubleClick cookie by installing the
DoubleClick opt out extension. For information about how Google uses data from
DoubleClick for Publishers, click here.

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:

MoPub: https://www.mopub.com/legal/privacy/
AppLovin: https://www.applovin.com/privacy/
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 Winner Ltd, 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 Winner Ltd also runs other kinds of online ad campaigns on
social networking websites and other non-Lucky Winner Ltd websites and apps. Some of
these ads may be based on information we have about users. If Lucky Winner Ltd provides
information to a website or app for these advertising purposes, the information may only be
used to display the Lucky Winner Ltd ad. Please see the privacy policy of the website or app
where a Lucky Winner Ltd 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, 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.

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 Winner Ltd 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 Winner Ltd, 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

If you are located in the EEA, personal information collected from you via the Software and
Services, will be transferred to recipients in countries located outside the EEAwhich do not
provide a similar or adequate level of protection to that provided by countries in the EEA.
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.

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 comply with the Children’s Online Privacy Protection Act (COPPA) and the General Data
Protection Regulation (GDPR).We do not intend to collect any personal identification
information of children under the age of thirteen (13), but there may be errors during the
process of collection of data. 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 would take action to ensure that such information is deleted from our server.

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
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:
luckywinnerltd@gmail.com