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Lucky VR Inc. 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 [email protected].
This Privacy Policy is provided in a layered format so you can click through to the specific areas set 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
This version was last updated on Oct 26th, 2018.
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.
Purpose/Activity
Type of Data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Identity
Contact
Performance of a contract with you
To enable use of the Service
Identity
Contact
Financial
Transaction
Usage
a. Performance of a contract with you
b. Necessary for our legitimate interests
To process and deliver your order including:
Manage payments, fees and charges
Collect and recover money owed to us
Identity
Contact
Financial
Transaction
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
Notifying you about changes to our terms or Privacy Policy
Asking you to leave a review or take a survey
Identity
Contact
Profile
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To enable you to partake in a prize draw, competition or complete a survey
Identity
Contact
Profile
Usage
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
To administer and protect our business and this Website and Service (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity
Contact
Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Identity
Contact
Profile
Usage
Marketing and Communications
Technical
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiences
Technical
Usage
Necessary for our legitimate interests (to define types of customers for our services, to keep our Website and Service updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you
Identity
Contact
Technical
Usage
Profile
Necessary for our legitimate interests (to develop our services and grow our business)
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 [email protected].
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 [email protected] 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: Oct 26th, 2018