Privacy Policy

Information You Provide

When you participate in the Spin & Win promotion or request a promotional bonus, we may collect:

• Name;
• Email address;
• WhatsApp number, if provided;
• Information relating to your participation;
• Promotional bonus or redemption information; and
• Any information you voluntarily provide when contacting us.

Please do not provide sensitive personal information unless specifically requested and necessary.

Information Collected Automatically

When you visit the Website, certain technical information may be collected automatically, including:

• IP address;
• Approximate location derived from IP address;
• Browser type and version;
• Device type;
• Operating system;
• Referring website or URL;
• Pages visited;
• Date and time of access;
• Interaction with the Website;
• Game interaction information; and
• Technical and diagnostic information.

We may use personal information to:

• Provide and operate the Spin & Win game;
• Record participation in promotional activities;
• Determine and manage promotional bonus eligibility;
• Deliver bonus or redemption instructions;
• Respond to customer support requests;
• Prevent fraud, abuse, manipulation, and unauthorized activity;
• Maintain Website security;
• Improve the Website and user experience;
• Measure advertising and campaign performance;
• Understand how visitors interact with the Website;
• Send promotional communications where permitted and where you have provided the appropriate consent or other lawful basis;
• Comply with legal and regulatory obligations; and
• Protect our legal rights and interests.

Where applicable data-protection laws require a lawful basis for processing personal information, we may rely on one or more of the following:

• Your consent;
• Performance of a requested service or participation in a promotion;
• Our legitimate interests, such as security, fraud prevention, service improvement, and marketing where permitted;
• Compliance with legal obligations; or
• Another lawful basis available under applicable law.

Where processing is based on consent, you may withdraw your consent as permitted by applicable law.

Withdrawal of consent does not affect processing that was lawfully carried out before withdrawal.

If you provide your email address or WhatsApp number to receive promotional information, bonus instructions, or offers, we may use that information for those purposes where permitted by law.

You can opt out of marketing communications at any time.

For email communications, you can use the unsubscribe link included in the relevant message.

For WhatsApp communications, you may request that we stop promotional messages by contacting us or using any available opt-out instruction.

Service-related messages necessary to provide a requested promotional bonus or respond to your request may continue where legally permitted.

We may use cookies, pixels, local storage, tags, analytics technologies, and similar technologies to operate and improve the Website.

These technologies may be used for purposes including:

• Keeping the Website functioning;
• Remembering preferences;
• Measuring Website performance;
• Understanding visitor behavior;
• Measuring advertising campaigns;
• Attributing visits and conversions to advertising sources;
• Detecting fraud or abuse; and
• Improving our marketing and user experience.

Some third-party advertising or analytics providers may also use cookies or similar technologies when you visit the Website.

You may be able to control cookies through your browser settings and, where applicable, through our cookie-consent mechanism.

Disabling certain cookies may affect Website functionality.

We may use third-party advertising networks, analytics providers, attribution services, and similar technology providers.

These providers may process technical information such as IP address, device information, browser information, referral information, and interaction or conversion information for purposes such as advertising measurement, attribution, fraud prevention, and campaign optimization.

If you arrive at our Website through an advertising campaign, advertising partners may use tracking technologies to measure whether an advertisement resulted in a visit, game interaction, lead submission, or other conversion.

We do not authorize third parties to collect personal information for purposes prohibited by applicable law.

We may use TrafficStars and/or other advertising platforms to promote the Website.

When you visit the Website through an advertisement, advertising or tracking technologies may be used to measure the performance of the advertising campaign and attribute conversions.

Information processed through such technologies may include technical and device information, IP address, referral information, and interaction or conversion data, subject to the applicable policies and agreements of the relevant providers.

We may share personal information with trusted service providers where necessary to operate the Website and provide requested services.

These may include:

• Website hosting providers;
• Cloud storage providers;
• Email delivery providers;
• WhatsApp or messaging service providers;
• Analytics providers;
• Advertising and attribution providers;
• Fraud-prevention and security providers;
• Customer-support providers;
• Providers of eligible courses, tools, or products where necessary to process a requested redemption; and
• Professional advisers where necessary.

We may also disclose information where required by law, legal process, court order, governmental request, or to protect our rights, users, property, or security.

We do not sell personal information in exchange for money unless clearly disclosed and permitted by applicable law.

Some service providers we use may process or store information in countries outside the country where you live.

Where required by applicable law, we will use appropriate safeguards for international transfers of personal information.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing requested services, maintaining business records, resolving disputes, preventing fraud, enforcing agreements, and complying with legal obligations.

Actual retention periods may vary depending on the type of information and the reason it was collected.

We use reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no internet transmission or electronic storage system can be guaranteed to be completely secure.

Depending on your location and applicable law, you may have rights relating to your personal information, which may include:

• The right to access personal information we hold about you;
• The right to request correction of inaccurate information;
• The right to request deletion;
• The right to restrict certain processing;
• The right to object to certain processing;
• The right to withdraw consent where processing relies on consent;
• The right to receive certain information in a portable format; and
• The right to lodge a complaint with an applicable data-protection authority.

These rights are subject to applicable legal limitations and exceptions.

To exercise a privacy right, contact: [PRIVACY EMAIL]

We may need to verify your identity before completing certain requests.

The Website is not intended for individuals who are not legally permitted to participate in the promotion under applicable law.

We do not knowingly collect personal information from individuals who are prohibited from using the Service.

If you believe that a minor has provided personal information to us improperly, please contact us so that we can investigate and take appropriate action.

The Website may contain links to third-party websites, products, tools, courses, or services.

We are not responsible for the privacy practices of third-party websites.

We encourage you to review the privacy policy of any third-party service before providing personal information.

We may update this Privacy Policy from time to time.

When we make changes, we will update the “Last Updated” date at the top of this page.

Where required by applicable law, we will provide additional notice or obtain consent for material changes.