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Last Modified 10 January 2020

Super Lucky Casino Inc., its subsidiaries and affiliated companies (“Super Lucky” or “we”) provide this Privacy Policy to inform you of our policies and procedures regarding our collection, use and disclosure of information. Except as explicitly provided herein, this Privacy Policy applies only to information we receive from users of (i) the website located at https://superluckycasino.com (the “Site”), including any services, features and content accessible or downloadable from the Site, and (ii) any other Super Lucky application, service or product licensed, downloaded or otherwise accessed by such users through third party websites or sources ((i) and (ii) collectively, the “Service”).

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For purposes of data protection laws, Super Lucky Casino Inc., PO Box 84, San Francisco, CA 94104-9991, is the “data controller” of your information.

Acceptance and Consent:

Byregistering for a user account and/or accessing or using the Service, you agreeto the terms and conditions of this Privacy Policy, and you consent to thecollection, use and disclosure of your information by Super Lucky in accordancewith the terms and conditions of this Privacy Policy. If you do not agree tothe terms and conditions of this Privacy Policy, please do not provide us withany information and do not use the Service.

Changes to the Privacy Policy:

SuperLucky reserves the right to change, modify, add, or remove portions of thisPrivacy Policy at any time (for example to reflect updates to the Service or toreflect changes in the law). If we make a material change to the PrivacyPolicy, we will provide you with appropriate notice and will seek your consentto the updated Privacy Policy in accordance with applicable legal requirements.Please check this Privacy Policy periodically for those changes. Your continueduse of the Service after the posting of changes constitutes your bindingacceptance of such changes.

1. Information We Collect

Weobtain information about you when you use or otherwise access the Service.Please note that we need certain types of information so that we can providethe Service to you. If you do not provide us with such information, or ask usto delete it, you may no longer be able to access or use the Service.

InformationWe Collect From You

Wecollect information you provide directly to us. For example, you may provide uswith information through your:

• Registration for and use of an Account;
• Use of the Service, including mobile applications;
• Requests or questions you submit to us via online forms, email, or otherwise;
• Requests for customer support and/or technical assistance;
• Uploading or posting of user content, such as when you participate in player forums or message boards, post comments to other users’ profiles, send private messages or invitations to other users, chat with other users, or post photos;
• Donations or purchases through the Services;
• Registration for any contest, sweepstakes, or other promotions or events we may sponsor;
• Participation in surveys we may make available; or
• Provision of other information to us within or outside of the Service.

Thetypes of information we collect directly from you include:

• Account Registration Information. When you register for a Super Lucky account (“Account”), we may collect information including your email address and a username.
• Profile Information: You may provide additional information about yourself to create a user profile (“Profile”), including but not limited to a username and other information you elect to provide about yourself. We encourage you to consider carefully what information to share as part of your Profile and elsewhere in the Service, and we recommend that you guard your anonymity and sensitive information and not use your real name as your username, as that may allow other users of the Service to identify you. Any information you choose to share should reflect how much you want other users of the Service to know about you.
• Usage History. You may provide additional information by using our Service, including our mobile applications. For example, when you play our games, we also collect information about your play and interaction with other users and the Service.
• Information About Others. You may decide to provide us with another party’s email address to allow us to contact and invite that party to visit or join the Service or so that Super Lucky may facilitate your communication with such other party through methods of communication enabled by the Service (such as when you upload an address book). Such email addresses will be used only for the purpose of sending email communications to the addressee.

InformationWe Collect From Third Parties

Wemay collect information about you or others through our affiliates or throughnon-affiliated third parties. For example, you may be able to register for anAccount through a social networking account. If you access the Service througha social media account, you may allow us to have access to certain informationin your social media profile. This may include your user ID, name, email,gender, birthday, current city, profile picture URL and the user IDs of yourfriends who have also connected with our applications. We may also cache datawe receive from the Facebook APIs to improve our user experience. Socialnetworking sites have their own policies for handling your information. For adescription of how these sites may use and disclose your information, includingany information you make public, please consult the sites’ privacy policies. Wehave no control over how any third-party site uses or discloses the personalinformation it collects about you.

Wemay also collect information about you from non-affiliated third parties forfraud or safety protection purposes, or for marketing purposes. For example, wemay receive information about your use of products/services offered by ouradvertising partners. We may collect also collect information about you, suchas your name or email address, from third party websites or other sources fromwhich you download or access Super Lucky applications, services or productsthat also make up part of the Service.

Welikewise may combine information that we collect from you through the Service withinformation that we obtain from such third parties and information derived fromany other products or services we provide.

InformationWe Collect Automatically

Device/UsageInformation: We and our third-party service providers may use cookies, web beacons,and other tracking technologies to collect and store information about your useof the Service. As described further below, we may collect and analyzeinformation including, but not limited to: (1) device type; (2) operatingsystem and version; (3) carrier provider; (4) IP address; (5) Media AccessControl (MAC) address; (6) International Equipment Mobile ID (IMEI); (7)whether you are using a point package; (8) the game version; (9) the device’sgeo-location; (10) language settings; and (11) a unique device ID. In addition,we create a unique user ID to track your use of our Service. This unique userID is stored in connection with your Account profile information to enable usto move your information to a new device at your request. In addition, it maybe used to link a character with which you play our games to your username onthe Forums.

LogData, Cookies and Web Beacons

Whenyou browse certain portions of the Service, we automatically collect and recordstandard user information and clickstream data about your visit (through theuse of cookies and otherwise) as part of our analysis of the use of theService. For example, when you visit or request a web page from our server, werecord the IP address of your machine, the time, date and URL of the requestand information about the browser being used, and other information regardingthe visit, such as the pages visited on the Service, the time spent on eachpage, any advertisements clicked and any search terms used (collectively, “LogData”). Log Data may be aggregated and is used to monitor and analyze use ofthe Service and to enable us to analyze traffic and trends, administer andimprove the Service, identify and keep track of errors and bugs, and gatherbroad demographic information to become more familiar with where visits to theService originate, how often the Service is visited and what parts of theService are visited most often. We also share such information with third partyservice providers assisting us with the foregoing and with our advertisers. Forexample, some of this information is collected and used so that when you visitthe Service again, it will recognize you and serve advertisements and otherinformation appropriate to your interests. We also use this information toverify that visitors to the Service meet the criteria required to process theirrequests. We link Log Data to your information for tracking and analyzing ourcustomers’ use of the Service to help improve the Service, to tailor theService to their needs and to enforce our Terms of Service.

Acookie is a small data file that we transfer to your computer’s hard drive.Like many websites, we also use “cookie” technology to collect additionalwebsite usage data, to improve the Service and in some cases to enable you tomore easily log in to your Account. We may combine information collectedthrough the use of cookies we issue with other information that you provide tous. Super Lucky may use both session cookies and persistent cookies to betterunderstand how you interact with the Service, to monitor aggregate usage by ourusers and web traffic routing on the Service, and to improve the Service andour other products and services. A session cookie enables certain features ofthe Service and is deleted from your computer when you disconnect from or leavethe Service. A persistent cookie remains after you close your browser and maybe used by your browser on subsequent visits to the Service. Persistent cookiescan be removed by following your web browser help file directions. MostInternet browsers automatically accept cookies.

Wemay feature advertisements served by third party advertising companies whichdeliver cookies to your computer or device so the advertisements you see can betracked. These advertisers may use information about your visits to our Servicein order to provide advertisements about goods and services of interest to you.

Youcan instruct your web browser, by editing its options, to stop acceptingcookies or to prompt you before accepting a cookie from the websites you visit.If your browser is set to refuse all cookies, however, some features of theServices may not function properly.

Weand third party advertising companies may collect information using Webbeacons. Web beacons or “gifs”, are electronic images that may be used on ourSite, in our Service or in our emails. We use Web beacons to deliver cookies,count visits and to tell if an email has been opened and acted upon.Advertisers may use web beacons in connection with our Service in order tocollect and use data regarding advertisement performance and your interests forthe purpose of delivering relevant advertising to you.

2. How We Use Information We Collect

Wemay use the information we collect, alone or in combination, for variousbusiness and commercial purposes, including, but not limited to providing theService as well as the following:

• To fulfill the purposes for which you provided it (such as providing you with the games you seek to play);
• To deliver products or advertisements to you according to your preferences or restrictions, to retarget content, and to otherwise personalize your experiences while using our Service;
• For customer support and to respond to your inquiries;
• For internal record-keeping purposes;
• To communicate with you, including to send you updates, newsletters and other information that may be of interest to you;
• To send push notifications to your wireless device or computer to provide updates and other relevant messages (you can manage push notifications from the “options” or “settings” function in your mobile app);
• To send you SMS notifications (with your consent);
• To improve the Service and to research and develop new services;
• To create or maintain aggregated, anonymized or de-identified information, which we may use and disclose without restriction;
• To investigate, prevent, or take action regarding unlawful or harmful activities, including potential threats to physical safety, potential fraud, and violations of our Terms of Service;
• To safeguard our and others’ rights or property;
• To process any job applications you submit; and
• To otherwise administer and troubleshoot the Service.

Wemay combine any of the information that we collect from you with otherinformation, including information that we obtain from third parties, or withinformation derived from any other products or services we provide. Forexample, we may combine personal information you provide us, such as an emailaddress, with information automatically collected about your device. We may usethis combined information to, among other things, provide you with personalizedrecommendations.

3. How We Share the Information We Collect

• Advertising Partners

Weshare your information with third parties with whom we have a businessrelationship such as advertisers, ad networks and analytics providers. Theinformation shared with these third parties may be used for industry analysis,ad targeting, tracking ad conversions or demographic profiling, or otherpurposes related to providing the Services to you.

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• Service Providers

Wemay employ third party companies and individuals to facilitate the Service, toprovide the Service on our behalf, or to assist us in analyzing how the Serviceis used. These third parties have access to your information to perform thesetasks on our behalf and we use good faith efforts to obtain their commitmentnot to use your information for any other purpose.

• Business Partners

Wemay also provide your information to our business partners or other trustedentities for the purpose of providing you with information on goods or serviceswe believe will be of interest to you.

• Legal Requirements and Protection of Rights

Wewill disclose any information about you to government or law enforcementofficials or private parties as we, in our sole discretion, believe necessaryor appropriate to respond to claims and legal process (including but notlimited to subpoenas), to protect the property and rights of Super Lucky or anythird party, to protect the safety of the public or any person, or to preventor stop activity we may consider to be, or to pose a risk of being, illegal,unethical or legally actionable.

• Business Transfers

Wemay transfer your information in connection with a change or transfer of SuperLucky’s ownership, or a merger, acquisition, reorganization or sale of assetsor in the event of bankruptcy, including in the course of diligence.

• Consent or At Your Direction

Wemay share your information with your consent, including where you postinformation to be shared publicly or with other users. For example, you maypost content to a blog, message board, chat room or within Super Lucky’applications or other forums (“Forums”). Certain of your information, such asyour username and other information, will always be publicly visible by otherusers of the Forums, including when such users view your Account profile page.Your email address will not be publicly visible unless you choose to make itvisible in your Account profile page. You may also direct us to shareinformation when you participate in player forums or message boards post commentsto other users’ profiles, send private messages or invitations to other users,chat with other users, and post photos in your public Profile.

• Aggregated or Anonymous Information

Thesharing scenarios identified above apply to personally identifiableinformation, not aggregated or anonymous information. We may share aggregatedor anonymous information about you and other users with advertisers,publishers, business partners, sponsors, and other third parties, in which casesuch information may be disclosed and used for a broad range of commercialpurposes without limitation.

4. Analytics and Tailored Advertising

Wemay use third-party web analytics services (such as those of Google Analyticsand Amplitude) on our Site to collect and analyze usage information throughcookies and similar tools; engage in auditing, research, or reporting; assistwith fraud prevention; and provide certain features to you. To prevent GoogleAnalytics from using your information for analytics, you may install the GoogleAnalytics Opt-out Browser Add-on by clicking here.

Ifyou receive email from us, we may use certain analytics tools, such as clearGIFs to capture data such as when you open our message or click on any links orbanners our email contains. This data allows us to gauge the effectiveness ofour communications and marketing campaigns.

TheService may integrate third-party advertising technologies that allow for thedelivery of relevant content and advertising on the Service, as well as onother websites you visit and other applications you use. The ads may be basedon various factors such as the content of the page you are visiting,information you enter such as your age and gender, your searches, demographicdata, user-generated content, and other information we collect from you. Theseads may be based on your current activity or your activity over time and acrossother websites and online services and may be tailored to your interests.

Thirdparties, whose products or services are accessible or advertised via theService, may also place cookies or other tracking technologies on your computer,mobile phone, or other device to collect information about you as discussedabove. We also allow other third parties (e.g., ad networks and ad servers suchas Google Analytics and others) to serve tailored ads to you on the Service,other sites, and in other applications, and to access their own cookies orother tracking technologies on your computer, mobile phone, or other device youuse to access the Service. We sometimes provide our customer information (suchas email addresses) to service providers, who may “match” this information inde-identified form to cookies (or mobile ad identifiers) and other proprietaryIDs, in order to provide you with more relevant ads when you visit otherwebsites and mobile applications.

Weneither have access to, nor does this Privacy Policy govern, the use of cookiesor other tracking technologies that may be placed on your device you use toaccess the Services by such non-affiliated third parties. If you are interestedin more information about tailored browser advertising and how you cangenerally control cookies from being put on your computer to deliver tailoredadvertising, you may visit the NetworkAdvertising Initiative’s Consumer Opt-Out link, the DigitalAdvertising Alliance’s Consumer Opt-Out link, or Your OnlineChoices to opt-out of receiving tailored advertising fromcompanies that participate in those programs. To opt out of Google Analyticsfor display advertising or customize Google display network ads, visitthe Google Ads Settings page. We do not control theseopt-out links or whether any particular company chooses to participate in theseopt-out programs. We are not responsible for any choices you make using thesemechanisms or the continued availability or accuracy of these mechanisms.

Pleasenote that if you exercise the opt out choices above, you will still seeadvertising when you use the Service, but it will not be tailored to you basedon your online behavior over time.

5. EEA Data Subjects

Thelaws in some jurisdictions require companies to tell you about the legal groundthey rely on to use or disclose your “personal data” (as defined in suchapplicable laws). To the extent those laws apply, our legal grounds areas follows:

• To honor our contractual commitments to you: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to allow you to play our games.
• Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
• Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes: operating our business and the Service; providing security for our websites, products, software, or applications; marketing; receiving payments; preventing fraud; and knowing the customer to whom we are providing the Service.
• Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations (such as our obligation to share data with tax authorities).

6. Retention of Your Information

Wegenerally retain information for so long as it may be relevant to the purposesabove and in compliance with applicable law. The length of time for which weretain information depends on the purposes for which we collected and use itand/or as required to comply with applicable laws.

7. Security

SuperLucky takes reasonable measures to protect your information from unauthorizedaccess or against loss, misuse or alteration by third parties. Although we makegood faith efforts to store the information collected on the Service in asecure operating environment that is not available to the public, we cannotguarantee the absolute security of that information during its transmission orits storage on our systems. Further, while we attempt to ensure the integrityand security of our network and systems, we cannot guarantee that our securitymeasures will prevent third-party “hackers” from illegally obtaining access tothis information. We do not warrant or represent that your Account or any ofyour information will be protected against, loss, misuse, or alteration bythird parties.

8. Your Choices

Whenyou register for an Account or later access your Account, you will able toadjust settings and preferences within your Account to choose whether to shareand make publicly visible other pieces of your information, and the Servicewill display your information based on the settings and preferences you choose.You can review and revise your Profile information at any time.

Youmay “opt-out” of receiving certain types of communications at any time bycontacting Super Lucky at support@SuperLucky.com.

ForResidents of the European Union and EEA Countries:

Residentsof the European Economic Area (“EEA”), can exercise certain data subject rightsavailable to them under applicable data protection laws. Where such rightsapply, we will comply with requests to exercise these rights in accordance withapplicable law. Please note, however, that certain information may beexempt from such requests in some circumstances, which may include if we needto keep processing your information for our legitimate interests or to complywith a legal obligation. If these rights apply to you, they may permit youto request that we:

• provide access to and/or a copy of certain information we hold about you
• prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
• update information which is out of date or incorrect
• delete certain information which we are holding about you
• restrict the way that we process and disclose certain of your information
• transfer your information to a third party provider of services
• revoke your consent for the processing of your information

Formore information on how to exercise these rights, please contact us using theinformation in the “Contacting Us” section below. If applicable, you maymake a complaint to the data protection supervisory authority in the countrywhere you are based. Alternatively, you may seek a remedy through local courtsif you believe your rights have been breached.

ForResidents of Nevada:

UnderNevada law, certain Nevada consumers may opt out of the sale of “personallyidentifiable information” for monetary consideration to a person for thatperson to license or sell such information to additional persons. “Personallyidentifiable information” includes first and last name, address, email address,phone number, Social Security Number, or an identifier that allows a specificperson to be contacted either physically or online. We do not engage in suchactivity; however, if you are a Nevada resident who has purchased or leasedgoods or services from us, you may submit a request to opt out of any potentialfuture sales under Nevada law by NevadaPII@superlucky.com. Please note we willtake reasonable steps to verify your identity and the authenticity of therequest. Once verified, we will maintain your request in the event ourpractices change.

ForResidents of California:

Pleaseclick https://www.superluckycasino.com/CAsupplementalto view details on rights for California residents.

9. International Users

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Theinformation discussed in this Privacy Policy is collected and controlled bySuper Lucky in the United States. If you are located outside the United Statesand choose to provide information to us, you agree that such information willbe processed in the United States for the purposes described herein. Asdescribed above, Super Lucky also may subcontract the processing of your datato, or otherwise share your data with, Super Lucky subsidiaries, service providers,and business partners in the United States or countries other than your countryof residence. The data-protection laws in these countries may be differentfrom, and less stringent than, those in your country of residence. Youexpressly consent to such transfer and processing.

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10. Third Party Links

TheService may contain links to other websites and online services (“LinkedSites”). The fact that we link to a third party website or service is not anendorsement or representation of our affiliation with that third party, nor isit an endorsement of their privacy policies or practices. You acknowledge andagree that we are not responsible for the privacy practices of such LinkedSites, and this Privacy Policy does not apply to such Linked Sites. The operatorsof Linked Sites may collect information about you, and may use and disclosethat information. We encourage you to review the privacy policies of the LinkedSites that you use.

11. Our Policy Regarding Children

TheService is not directed to children under the age of 13. We do not knowinglycollect or solicit personally identifiable information from children under 13.If you are under 13, please do not attempt to register for an Account on theService or send any information about yourself to Super Lucky. If we becomeaware that a child under 13 has provided us with personal information (asdefined by the United States Children’s Online Privacy Protection Act), we willdelete such information from our files as required by applicable law.

Wedo not knowingly process data of EU residents under the age of 16 withoutparental consent. If we become aware that we have collected data from an EUresident under the age of 16 without parental consent, we will take reasonablesteps to delete it as soon as possible. We also comply with other agerestrictions and requirements in accordance with applicable local laws.

12. Contacting Us

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Ifyou have any questions about this Privacy Policy, please contact usat support@SuperLucky.com.