Big Win - Lucky 9 games has adopted this privacy policy (“Privacy Policy”) to explain how LUCKY9 games collects, stores, and uses the information collected in connection with LUCKY9 PLAY games’s Services.
BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES.
Where applicable, this Privacy Policy should be read in conjunction with the Country-Specific Riders for your jurisdiction as set out in Section 13 below.
1.1. In the course of providing you with the Services or access to the Service (as defined in the Terms of Use), we will be collecting, using, disclosing, storing and/or processing data, including your personal data. In this Privacy Policy, Service shall also refer to the relevant seller Service(s).
1.2. This Privacy Policy exists to keep you in the know about how we collect, use, disclose, store and/or process the data we collect and receive during the course of providing the Services or access to the Service to you, our user, whether you are using our Service as a buyer or a seller. We will only collect, use, disclose, store and/or process your personal data in accordance with this Privacy Policy.
1.3. It is important that you read this Privacy Policy together with any other applicable notices we may provide on specific occasions when we are collecting, using, disclosing and/or processing personal data about you, so that you are fully aware of how and why we are using your personal data.
1.4. We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be reflected on this page and material changes will be notified to you. Where permissible under local laws, your continued use of the Services, access to the Service or use of the Services, including placing Orders (as defined in the Terms of Use) on the Service, or express consent thereto, shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Policy. You agree that it is your responsibility to check back frequently to see any updates or changes to this Privacy Policy.
1.5. This Privacy Policy applies in conjunction with other notices, contractual clauses and consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override them unless we state expressly otherwise.
2.1. Personal data means personally identifiable information that specifically identifies you as an individual. Personal information collected by LUCKY9 games is information voluntarily provided to us by you when you create your account or change your account information.
2.2. Non-personal data means information that does not directly identify you. LUCKY9 games may use and disclose to LUCKY9 games’s partners and contractors the collected non-personal data for purposes of analyzing usage of the Services, advertisement serving, managing and providing the Services and to further develop the Services and other LUCKY9 games services and products.
2.3. During the course of your use of the Service and the provision of the Services, we may collect personal data about you, as follows:
(i) Identity data, such as your name, gender, and profile picture;
(ii) Transaction data, such as details about orders and payments, and other details of products and Services related to you;
(iii) Technical data, such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and Service, international mobile equipment identity, device identifier, IMEI, MAC address, cookies (where applicable) and other information and technology on the devices you use to access the Service;
(iv) Profile data, such as your username and password, orders related to you, your interests, preferences, feedback and survey responses;
(v) Usage data, such as information on how you use the Service, products and Services or view any content on the Service, including the time spent on the Service, items and data searched for on the Service, access times and dates, as well as websites you were visiting before you came to the Service and other similar statistics;
(vi) Third-party access data, such as information that you agree to share from third-party Service, i.e. Facebook, to be able to use our Services.
(vii) Additional information we may request you to submit for due diligence checks as required for identity verification (such as copies of government issued identification, e.g. passport, ID cards, etc.) or if we believe you are violating our Privacy Policy or our Terms of Use.
2.4. During the course of your use of the Service and the provision of the Services, we may collect non-personal data about you, as follows:
(i) Application properties, including, but not limited to application name, package name and icon installed on your device;
(ii) Your application activities, such as your check in (including likes, recommendations) of a game will be disclosed to all LUCKY9 games users;
How we receive your personal data2.5. During the course of your use of the Service and our provision of the Services, we may receive personal data from you in the situations, as follows:
(a) When you create an account with us;
(b) When you apply for, subscribe to or otherwise use any of the Services;
(d) When you participate in any activity or campaign with our Services;
(e) When you log in to your account on the Service or otherwise interact with us via an external service or application, such as Facebook or Google;
(f) When you interact with us offline, including when you interact with our outsourced customer service agents.
2.6. We may collect personal data from you, third parties (including but not limited to agents, vendors, contractors, partners and any others who provide services to us, who collect your personal information and/or perform functions on our behalf, or with whom we collaborate, including but not limited to payment service providers, government sources of data, financial providers, credit bureaus, delivery, marketing and other service partners), our affiliates, or such data may be collected automatically when you use the Service or the Services, as set out in this section. See also section 10 below on the collection of computer data.
2.7. Where we collect personal data from third parties and/or our affiliates, we will only collect your personal data, where permitted by law, for or in connection with the purposes for which those third parties or our affiliates are engaged, for the purposes of our collaboration with the third parties or affiliates, or for the requirement to carry out verification or due diligence checks. During the course of your use of the Service and our provision of the Services, you agree that you have provided your consent (whether to us, the third party or our affiliates) to the transfer of your personal data from third parties and/or our affiliates for the purposes set out in this Privacy Policy or any other terms.
2.8. You must only submit personal data which is accurate and not misleading and you must keep it up to date and inform us of any changes to the personal data you have provided to us. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.
2.9. We will only be able to collect certain categories of personal data if you voluntarily provide the personal data to us or as otherwise provided for under this Privacy Policy. If you choose not to provide your personal data to us or subsequently withdraw your consent to our use of your personal data, we may not be able to provide you with certain features or functionality on the Services or access to the Service.
2.10. If you sign up to be a user on our Service using your social media account or link your account to your social media account or use certain other social media features, we may access personal data about you which you have voluntarily provided to your social media provider in accordance with the provider's policies and we will manage your personal data in accordance with this Privacy Policy.
Purpose of Use
3.1. The personal data we collect from you or via third parties may be used for certain purposes, as follows:
(i) Providing Services
• To facilitate your use of the Services or access to the Service;
• To administer your account (if any) with us;
• To display your name, username or profile on the Service (including on any reviews you may post);
• To respond to your queries, feedback, claims or disputes, whether directly or through our third party service providers;
• To display on scoreboards on the Service in relation to campaigns, mobile games or any other activity;
• To facilitate the integration of third party’s loyalty membership programmes with our Service.
(ii) Legal and operational purposes
• To ascertain your identity in connection with fraud detection purposes;
• To compare information, and verify with third parties in order to ensure that the information is accurate;
• To process any complaints, feedback, enforcement action and take-down requests in relation to any content you have uploaded to the Service;
• To produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
• To store, host, back up your personal data;
• To prevent or investigate any actual or suspected violations of our Terms of Use, Privacy Policy, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
• To perform due diligence checks;
• To comply with legal and regulatory requirements (including, where applicable, the display of your name, contact details and company details), including any law enforcement requests, in connection with any legal proceedings, or otherwise deemed necessary by us; and
• Where necessary to prevent a threat to life, health or safety.
(iii) Analytics, research, business and development
• To understand your user experience with the Services and the Service;
• To improve the layout or content of the pages of the Service and customise them for users;
• To identify visitors on the Service;
• To conduct surveys, including carrying out research on our users’ demographics and behaviour;
• To improve our current technology (e.g. voice recognition tech, etc) via machine learning or other means;
• To derive further attributes relating to you based on personal data provided by you (whether to us or third parties), in order to provide you with more targeted and/or relevant information;
• To conduct data analysis, testing and research, monitoring and analysing usage and activity trends;
• To further develop our products and services; and
(iv) Other
• Any other purpose to which your consent has been obtained; and
• To conduct automated decision-making processes in accordance with any of the above purposes.
Who we disclose your personal data to
3.2. We may share (or permit the sharing of) your data with and/or transfer your data to third parties and/or our affiliates for the above-mentioned purposes. These third parties and affiliates, which may be located inside or outside your jurisdiction, include but are not limited to:
(i) Service providers (such as agents, vendors, contractors and partners) in areas such as payment services, logistics and shipping, marketing, data analytics, market or consumer research, survey, social media, customer service, installation services, information technology and website hosting;
(ii) Their service providers and related companies; and
(iii) Other users of the Service or Services.
3.3. In disclosing your personal data to them, we endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed to achieve the above-mentioned purposes.
3.4. We may also share personal data in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we satisfy the requirements of applicable data protection law when disclosing your personal data.
International data transfer
3.5. We may transfer or permit the transfer of your personal data outside of your jurisdiction for any of the purposes set out in this Privacy Policy. However, we will not transfer or permit any of your personal data to be transferred outside of such jurisdiction unless the transfer is in compliance with applicable laws.
Third party services
3.6. We may share your personal data with our third party service providers or affiliates (e.g. payment service providers) in order for them to offer services to you other than those related to your use of the Service or our Services. Your acceptance and use of the third party service provider’s or our affiliate’s services shall be subject to terms and conditions as may be agreed between you and the third party service provider or our affiliate. Upon your acceptance of the third party service provider’s or our affiliate’s service offering, the collection, use, disclosure, storage, transfer and processing of your data (including your personal data and any data disclosed by us to such third party service provider or affiliate) shall be subject to the applicable privacy policy of the third party service provider or our affiliate, which shall be the data controller of such data. You agree that any queries or complaints relating to your acceptance or use of the third party service provider’s or our affiliate’s services shall be directed to the party named in the applicable privacy policy.
4.1. You may communicate the withdrawal of your consent to the continued use, disclosure, storing and/or processing of your personal data by contacting us using the contact details below, subject to the conditions and/or limitations imposed by applicable laws or regulations.
Contact email address: przroldan@gmail.com4.2. Please note that if you communicate your withdrawal of your consent to our use, disclosure, storing or processing of your personal data for the purposes and in the manner as stated above or exercise your other rights as available under applicable local laws, we may not be in a position to continue to provide the Services to you or perform any contract we have with you, and we will not be liable in the event that we do not continue to provide the Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.
5.1. It is important that the personal data you provide to us is accurate and complete for you to continue using the Service and for us to provide the Services. You are responsible for informing us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date.
5.2. You can update your personal data anytime by accessing your account on the Service.
5.3. We take steps to share the updates to your personal data with third parties and our affiliates with whom we have shared your personal data if your personal data is still necessary for the above-stated purposes.
6.1. You may request information about your personal data which we have collected, or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us via the personal account information setting on our Service or by contacting us using the contact details below. You may also request correction of any error or omission in your personal data which we have collected in the same way. In order to facilitate processing of your request, it may be necessary for us to request further information relating to your request. Where permissible under law, we may refuse such correction requests if deemed vexatious or unreasonable.
6.2. Where permitted by applicable data protection laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request.
7.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, loss, misuse, modification or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
(a) Restricting access to personal data to individuals who require access;
(b) Maintaining technology products to prevent unauthorised computer access;
(c) implementing other security measures as required by applicable law.
7.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
8.1. We will only retain your personal data for as long as we are either required or permitted to by law or as relevant for the purposes for which it was collected.
8.2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or business purpose.
9.1. We or our authorised service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Services or access of the Service.
9.2. When you visit the Service through your computer, mobile device, or any other device with Internet connectivity, our company servers will automatically record data that your browser sends whenever you visit a website, such as the technical data and usage data outlined in Section 2 above.
9.3. This data is collected for analysis and evaluation in order to help us improve our website and the services and products we provide, as well as to help us to personalise the content to match your preferred interests more quickly. The data is also collected to make the Services and the Service more convenient and useful to you, and to provide more relevant advertising related to market products, services and features to you.
9.4. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognise a particular device or browser. Web beacons are small graphic images that may be included on our Services and the Service. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.
9.5. You may be able to manage and delete cookies through your browser or device settings. However, certain cookies are required to enable core functionality (such as adding items to your shopping basket), so please note that changing and deleting cookies may affect the functionality available on the Service or through our Services.
10.1. The Service may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.
11.1. If you have any questions on personal data protection or data privacy, please refer to our list of frequently asked questions on data protection / privacy.
11.2. If your queries are not covered in our FAQs, or if you have any queries or complaints about this Privacy Policy or how we handle your personal data, please feel free to contact us via our email address at przroldan@gmail.com
12.1. Please be aware of the open nature of certain social networking and other open features of the Services LUCKY9 games may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. LUCKY9 games is not responsible for any personal data you choose to make public in any of these forums.
12.2. Minors: If you are under 15 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access the Services. LUCKY9 games takes children’s privacy seriously, and encourages parents and/or guardians to play an active role in their children's online experience at all times. LUCKY9 games does not knowingly collect any personal information from children below the aforementioned age and if LUCKY9 games learns that LUCKY9 games has inadvertently gathered personal data from children under the aforementioned age, LUCKY9 games will take reasonable measures to promptly erase such personal data from LUCKY9 PLAY games’s records.
12.3. LUCKY9 games may store and/or transfer your personal data to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy. LUCKY9 games may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of LUCKY9 PLAY games’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal data.
12.3. LUCKY9 games regularly reviews its compliance with this Privacy Policy. If LUCKY9 games receives a formal written complaint from you, it is LUCKY9 games’s policy to attempt to contact you directly to address any of your concerns. LUCKY9 PLAY games will cooperate with the appropriate governmental authorities, including data protection authorities, to resolve any complaints regarding the collection, use, transfer or disclosure of personal data that cannot be amicably resolved between you and LUCKY9 games.
Version dated 22 October 2021. Our privacy policy may change from time to time. If we make any material changes to our policies, we will place a prominent notice on our website or application. If the change materially affects registered users, we will send a notice to you by email, push notification or text.