This Privacy Policy explains how Lucky Play Mobile ("Lucky Play", "we", "us" or "our") works with information in relation to our mobile services, web site, and any software provided on or in connection with Lucky Play services (collectively, the "Service"), and your choices about the collection and use of your information.
By using our Service you understand and agree that we are providing a platform for you to play games, post comments and other content ("User Content"), to the Service and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the Service, consistent with the terms and conditions of this Privacy Policy and our Terms of Service (the “Terms”).
Our Policy applies to all visitors, users, and others who access the Service ("Users").
We collect and further process the following types of information.
Your username, password and e-mail address or phone number when you register for Lucky Play account.
Profile information that you provide for your user profile (e.g., first and last name, picture, birth day and gender). This information allows others to find you on Lucky Play.
User Content (e.g., comments) that you post to the Service.
Location - Lucky Play application may require location permission in order to access battles features. If you consent to the use of your location data, we use this information to display battles in your location. If you do not wish to give such permission, you can still use the service but battles feature will not be available.
Access to your phone contact list. Lucky Play may ask permission to access your devices contact list to help you find contacts that are already using the Service. If you do not wish to give this permission (i.e., if you do not agree with Lucky Play accessing your phone contact list), you may still use the service with limited features of finding friends.
Communications between you and Lucky Play. We may send you Service-related emails (e.g., news, changes/updates to features of the Service), you may opt out of Service-related e-mails.
If you choose to find your friends through your device's contacts list and give us consent hereto, then Lucky Play will access your contacts list to determine whether or not someone associated with your contact is using Lucky Play.
If you choose to find your friends through a third-party social media site (such as your Facebook friends), then you understand that any information that such service may provide to us will be governed by this Privacy Policy. We will ask you for your consent before we connect such a third-party social media site with your Lucky Play account.
If you choose to invite someone to the Service through our "Invite friends" feature, you may select a person directly from the contacts list on your device and send a text or email from your personal account. You understand and agree that you are responsible for any charges that apply to communications sent from your device, and because this invitation is coming directly from your personal account, Lucky Play does not initiate, control or have access to this communication.
We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service assist us in improving the Service.
When you access the Service, you disclose certain information related to your hardware and software that we automatically collect. For example, we may collect your IP (Internet Protocol) address, operating system, browser type, access times, pages visited, search terms, mobile carrier, device type, device IDs, and application IDs. We collect this information to generate statistics about use of the Service and use the results to customize as well as improve the overall quality of the Service.
In addition, in accordance with relevant laws and regulations and national standards, in the following circumstances, we may collect and process your relevant personal information without asking for your consent:
1) When it is directly related to national interests such as national security and national defense, or it is directly related to major public interests such as public safety, public health, and public knowledge;
2) When it is directly related to a criminal investigation, prosecution, trial or execution of judgments;
3) In order to protect vital legitimate interests of you or of other individuals, such as right of life, property, and reputation, while it’s hardly to obtain the consent of the individual;
4) When the personal information is disclosed to the public by yourself;
5) When the personal information is collected from legally publicly disclosed information, such as legitimate content reports, government information disclosure, etc.;
6) When it is necessary for entering into and/or performance of a contract to which you are the party;
7) When it is necessary for maintenance of the safe and stable operation of the products or services provided, such as discovering malfunctions and/or troubleshooting products or services;
8) When it is necessary for legitimate content reporting;
9) When it is necessary for conducting statistical or academic research which is for public interest, and when the results of academic research or description are provided externally, the personal information contained is de-identified.
10) Other circumstances as stipulated by laws and regulations.
Please understand that the functions and services we provide to you are constantly updated and developed. If a function or service is not in the above description and your information is collected, we will explain to you the type of information, the scope and the purpose of the information collection by means of page prompts, interactive processes, website announcements or other ways to obtain your consent.
In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive to:
help you efficiently access your information after you sign in>
provide personalized content and information to you and others, which could include online ads or other forms of marketing
provide, improve, test, and monitor the effectiveness of our Service
develop and test new products and features
monitor metrics such as total number of visitors, traffic, and demographic patterns
diagnose or fix technology problems
Upon your explicit consent, we may also use your personal information you give to us as well as other personal information we gain from your behaviour and use of the Service (such as log data) as specified in Section 1, for automated decisions, including profiling, in order to provide you with personalized content and/or advertising bespoke to your needs and preferences.
We will not rent or sell your information to third parties outside Lucky Play without your consent, except as noted in this Policy.
Other users of the Service that may see your results, challenge you or otherwise see your use of the Service as described in our Terms.
We may share your information as well as information from tools like log files, and device identifiers and location data, with third-party organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms. Currently, the third parties to whom data relating to you and your use of the Service may be transferred, and the purposes of such transfers include:
Amazon Web Services, Inc, United States of America, used for storage of your profile pictures and stream of the Service;
Data collected from you may be transferred to, and stored and processed in, the United States (US), any other country in which Lucky Play, its affiliates, subcontractors, suppliers or other third party vendors maintain facilities. While we reserve the right to change our business partners and/or data locations, when we transfer any personal information to the USA or any other country outside the EU or EEA in which Lucky Play, its affiliates, subcontractors, suppliers or vendors maintain facilities, we will implement such appropriate legal mechanism as are required by EU law to ensure an adequate level of personal data protection by such third parties receiving your personal data (for example, European Commission’s Standard Contractual Clauses).
As described above, the Service data is currently transferred to and stored and processed by Amazon Web Services, The specific AWS Data Processing Addendum incorporating these model clauses has been approved and validated on EU level by Article 29 Working Party in 2015 as ensuring an adequate level of protection. We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine any anonymized information with other information in a way that it is no longer associated with you and share that aggregated information.
We may access, preserve and share your information to comply with legal requirements. We may also access, preserve and share information when it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
Our policy is to not to share, sell, or rent your personal information to third parties for our own personal benefit, however there may be situations where we are required to share your personal details with third parties, such as relevant law enforcement agencies. If we believe that it is reasonably necessary to comply with law enforcement or other regulatory bodies, we may do so without your prior consent or notice.
We may also share your personal information if we believe it is necessary to investigate, prevent, or act regarding situations that pose a threat to the security, rights and assets of the company, or violations to our policies or terms of service. We may also share your personal information if necessary in cases of fraud, such as credit card fraud on offers.
The disclosure of sensitive information to relevant organizations or authorities is up to the sole discretion of the management of the company.
Taking into account the state of the art, scope, context and purposes of processing of your personal information as well as the risk of varying likelihood and severity for your rights and freedoms, we take reasonable steps to protect and secure your personal information against unauthorized access or disclosure. We use security software to protect the confidentiality of your personal information. We review our business practices periodically for compliance with policies and procedures governing the security of our information.
To register with the Service, you will be required to select a password to protect your account unless you login with your account on a third-party service. You must keep your password confidential.
Update your account at any time by logging in and changing your profile settings.
Unsubscribe from email communications from us by clicking on the "unsubscribe link" provided in such communications.
We store and process your personal information for the period of your use of the Service. Following termination or deactivation of your account, Lucky Play or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, and/or audit purposes; such information will not be retained for more than 2 years after your termination or deactivation of your account and will not be used for any other purposes.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
TikTok Authentication is a registration and authentication service provided by TikTok Inc., or TikTok Technology Limited, or TikTok Information Technologies UK Limited or TikTok Pte. Ltd., depending on the location this Application is accessed from, and is connected to the TikTok network. Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing - Privacy Policy
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on the location this Application is accessed from, and is connected to the Facebook social network.Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing - Privacy Policy
We take reasonable measures to ensure that you are able to keep your personal information accurate and up-to-date. You can always ask us to confirm whether or not we process your personal information and if we do, to what extent, and require access to it.
In accordance with applicable laws and as further detailed below, you have the right to request access to, rectification, erasure or portability (e.g. to another service provider) of your personal information we process, as well as to request restriction of such processing. You can also withdraw your consent that you have given to us at any time. Please note that withdrawal of your consent does not affect lawfulness of any processing done on the understanding that you had given the consent before.
Inaccurate information. If you find out that your personal information is inaccurate or incomplete and you are unable to update this information according to Section 5 of this Privacy Policy, you may request us to update such personal information. We will verify your information accordingly without undue delay.
Erasure of your personal information. You can request that we erase your personal information at any time. If you approach us with such a request, we will delete (and ensure deletion by the processors that we engage) your personal information we have without undue delay. We will also delete all your personal information in case you withdraw your consent or under the circumstances that applicable laws require us to do so. Your personal information will be deleted accordingly, provided that it is no longer necessary for provision of the Service or there is no other legal ground for the processing.
Restriction of processing. If you request to restrict the processing of your personal information, e.g. in circumstances when you contest the accuracy of your personal information, or lawfulness of our need to process your personal information, we will limit processing of your personal information to the necessary minimum (storage). In such case, if applicable, we will process your personal information only for the establishment, exercise or defence of legal claims or, where necessary, for protection of rights of another natural or legal person, or other limited reasons dictated by the applicable law. In case the restriction is lifted and we continue processing your personal information, we will inform you accordingly without undue delay.
Portability of your personal information. You have the right to receive personal data which relate to you and you have provided to us. If you approach us with such request, we will provide your personal information in a commonly used and machine readable format to you within 2 weeks from receipt of your request. If you request so, we may also send your personal information to a third party (another data controller) which you may identify in your request, unless such request would adversely affect rights or freedoms of others or would not be technically feasible.
Objections to direct marketing. If you no longer wish to receive marketing or promotional materials from us or you do not wish that your personal information is used for profiling as related to such marketing or promotional activities, you can request that we cease the use of your personal information for these purposes. In such case, you will no longer be able to benefit from some of the Service or specific features for which this category of processing is essential (i.e. the receipt of (personalised) marketing and promotional materials).
If you exercise any of your rights according to this Section or applicable laws, we will communicate any rectification or erasure of your personal data or restriction of processing in accordance with your request to each recipient to whom the personal information has been disclosed pursuant to Section 3, unless such communication proves impossible or involves disproportionate effort.
If you wish to exercise these rights and/or obtain all relevant information, please contact hello@luckyplay.com. You will be asked to provide your email address or mobile phone number, depending on the form of your registration; this is necessary to verify that the request has been sent by you. We will respond within 1 month after receipt of your request, but we retain the right to extend this period up to 2 months if necessary. We will in any event inform you within 1 month after receipt of your request whether it is necessary to extend the period to respond.
You have the right to submit a complaint concerning our data processing activities to the competent supervisory authority, which is, for Lucky Play being subject to Czech jurisdiction, the Office for Protection of Personal Information (link).
Lucky Play does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register for the Service. The Service and its content are not directed at children under the age of 18. If you believe that we might have any information from or about a child under 18, please contact us.
We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them.
If you have any questions about this Privacy Policy or the Service, please find contact us at contact@luckyplay.com, or write to us with airmail to: LuckyPlay, ROOM 1201, 12/F TAI SANG BANK BUILDING, 130-132 DES VOEUX ROADs, CENTRAL, Hong Kong
Lucky Play reserves right to modify or update this Privacy Policy from time to time, so please review it periodically. Your continued use of the Service after any modification to this Privacy Policy will constitute your acceptance of such modifications made by us from time to time. Should any of the modifications of the Privacy Policy require your consent, we will contact you in order to obtain your consent herewith.
The Services are hosted in the United States and European Union(hereinafter referred to as EU) and are intended only for users located within the United States and EU. Luck Play’s Terms of Use restrict use of the Services to the United States and EU. If you violate the Terms of Use and use the Services from the other regions of the world with laws governing data collection and use that may differ from U.S. and EU law, then please note that you are transferring your information outside of those regions to the United States and EU for storage and processing, and by providing your information on the Services you consent to that transfer, storage, and processing.
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
Versions distributed in the United States are subject to United States law. This Policy is provided in accordance with and subject to applicable U.S. law. If you are a California resident you may request a notice from us describing what categories of personal information (if any) we have shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. As of January 1, 2020, California residents also have the following rights provided to them under the California Consumer Privacy Act of 2018, Civil Code §1798.100 et seq. (CCPA)