Date updated: June 3, 2020
At VGW, we are committed to protecting and respecting your privacy and maintaining the
how your personal information is collected, why it is collected and how it is kept
Inc (“Luckyland”), and other companies in the VGW Group (“VGW Group”) collect, use,
maintain and disclose information collected from users (each, a "User") of Luckyland
through https://luckylandslots.com/ and any subdomains, subpages, successor sites or
the website and all products and services offered through the Website.
2. The data controller responsible for processing data collected through your use of the Website (including any data you may provide through the Website when you purchase a product or service or take part in a promotion or competition) is VGW Luckyland Inc having its registered address at 1209 North Orange Street, Wilmington, DE 19801-1120 (the “Data Controller”).
TYPE OF INFORMATION WE COLLECT
1. We collect two basic types of information - personal information (as defined below) and anonymous information (as defined below) - and we may use personal and anonymous information to create a third type of information, aggregate information (also defined below). For example, we collect:
1.1 contact details, such as your first name and surname, email address, residential
address and mobile or other phone numbers;
1.2. personal information such as gender, age, age range or your image;
1.3. account login details, including your username, password and pictures associated with your profile;
1.4. transaction information you provide when you make a purchase, request a redemption
or otherwise use our Website or contact customer service, such as your postal address,
phone number and payment or redemption information including banking and financial
details, credit card details and bank account statements;
1.5. information sent bilaterally or within a small group using text message, live
chat, post or other similar methods of communication;
1.6. information we obtain from a third party, such as a site or platform provider
(including Facebook), about your use of or interest in our services;
1.7. location information, including location information provided by a mobile or other
device interacting with one of our Websites, or associated with your IP address, where
we are permitted by law to process this information;
1.8. activity, technical and device information about your use of our Website, such as
the content you view, the time and duration of your visit on our Website, how often you
use our services, how you first heard about our Website, your preferences and
information about your interaction with the content offered through our Website, your
hardware model, device type, other unique device identifiers, operating system version,
browser type and IP address; and
1.9. social security numbers where we are required to do so for tax or other legal
HOW WE COLLECT YOUR INFORMATION
1. We collect information that Users provide to us in a variety of ways when Users visit our Website, register on the Website purchase products on our Website, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Website.
You warrant any contact information you provide, included (but not limited to), your e-mail address and mobile phone number is true and accurate. You further warrant that you are the telephone subscriber and/or that you own any telephone numbers that you provide to Luckyland. You acknowledge that by voluntarily providing your telephone numbers to Luckyland, you expressly agree to be contacted at the telephone numbers you provide. You consent to receive pre-recorded voice messages and/or autodialed calls (including text messages) by or on behalf of Luckyland relating to:
2. any transaction with Luckyland related to your account; and
3. promotions from Luckyland.
The above communications may be made by or on behalf of Luckyland, even if your phone number is registered on any state or federal Do Not Call list. You acknowledge that you may incur a charge for these texts or calls by your telephone carrier and that Luckyland will not be responsible for these charges.
1. In addition to collecting information via our Website, we collect information from
Users by telephone, video or in correspondence (including email, live chat, mail, text
message or social media). All telephone or video calls between Users and VGW Group
representatives may be recorded for training, quality control and compliance purposes
and by continuing with any such call you consent to it being recorded.
2. We also collect information about your use of our products and services through a
variety of technologies that are present when you visit our Websites or use our
applications on third party sites or platforms (whether or not you are logged in or
registered) including cookies, flash cookies, pixels, tags and application program
interfaces (“API”). Please see the section entitled “Personal Data Collected via
Technology” below for further information.
3. Analytics tools are also used by us to collect information, including when you
visit our Website or use our applications or services on third party sites or
4. Finally, we also use trusted sources to update or supplement the information you
provided or we collected, including in order to verify or validate information (for
example, postal address, documentation and names).
HOW WE USE COLLECTED INFORMATION
2. In accordance with applicable law and any elections made available to you, VGW may collect and use the information of Users for the following specific purposes:
2.1. To provide and manage the services you request - This includes, for example, to
process your registration, to set up and look after your account, including checks
made to guard against fraud.
2.2. To improve customer service and our services - Information you provide helps us
respond to your customer service requests more efficiently; we may use feedback you
provide to improve our products and services.
2.3. To process payments - We may use the information Users provide about themselves
when placing an order to service to that order (including to satisfy our customers due
diligence requirements and to establish the source of funds where necessary). We do
not share this information with third parties except to the extent necessary to provide
2.4. To personalize user experience - We may use information in the aggregate to
understand how our Users as a group use the services and resources provided on our
2.5. To contact you about our service - For example by email, live chat, telephone,
text message, mail, or social media; to manage promotions and competitions you choose
to enter. We may periodically contact you with offers and information about the
Services, including in connection with your accounts, promotions, contests, online
surveys, new features that you are entitled to access, and other important information.
As set out in clause 3.1, provision of telephone information will be deemed as your
consent to receive text messages sent by automatic telephone dialing systems. Consent
to receive direct advertising is not a condition of purchase
2.6. To send important notices to you - From time to time, we may send important
notices to you, such as communications about purchases you have made, or legal notices
regarding the changes to our terms and conditions or other policies. This information
is important to your interactions with us and you acknowledge that you may not opt-out
of receiving these communications.
2.7. To comply with our legal and regulatory obligations - We may use information we
collect about you to assess your social gaming activity for responsible social gaming
purposes, for taxation purposes, to comply with fraud and anti-money laundering laws
(including to establish the source of funds where a transaction is involved) or to
comply with any other legal or regulatory obligations (including the detection,
investigation and prevention of activity that violates our terms and conditions or
that may be illegal).
2.8. To offer alternative dispute resolution services. We may provide information we
collect about you to our third party partner for the specific purpose of resolving any
disputes that have not been satisfactorily resolved through our internal processes.
3. We do not use automated decision making within the meaning of European data protection laws.
PERSONAL DATA COLLECTED VIA TECHNOLOGY
1. When you interact with our Website or any application accessible via our Website, we try to make that experience simple and useful. We and our partners use industry standard identifiers, such as cookies or other similar technologies.
2. Our Website may use technologies to enhance User experience. These technologies are small files that are placed on your computer, tablet, mobile phone or other devices when you visit a website. They allow us to record certain pieces of information whenever you visit or interact with the website.
3. The following are examples of these type of technologies:
3.1. Cookies. These are small text files placed in your device browsers to store your
preferences. Most browsers allow you to block and delete cookies. However, if you do
that, the service may not work properly.
3.2. Pixel tags/web beacons. A pixel tag (also known as a web beacon) is a piece of
code embedded on the Scratch Carnival App that collects information about Users’
engagement on that web page. The use of a pixel allows us to record, for example, that
a user has visited a particular web page or clicked on a particular advertisement. We
may also include web beacons in e-mails to understand whether messages have been
opened, acted on or forwarded.
3.3. Mobile device identifiers. We may share the advertising identifier associated
with your mobile device or tablet (such as the Apple IDFA and Google Advertising ID)
with advertisers. It is used to identify your device for internet-based advertising.
For instructions for using the advertising choice mechanisms provided by the most
popular mobile operating systems, visit the NAI’s Mobile Choices page here.
3.4. Event tagging. Event tagging (including Facebook App Events and Playfab Events)
allows us to track actions that occur in the Scratch Carnival App such as application
installs and purchase events. By tracking these events we can view analytics, measure
ad performance, and build audiences for ad targeting.
1. We may partner with a third party to either display advertising on our Website or any application accessible via our Website or to manage our advertising on other websites (for example, using custom audiences on Facebook). Our third party partner may use technologies such as cookies to gather information about your activities on our Website and other websites in order to provide you advertising based on your browsing activities and interests.
2. If you wish to opt-out of interest-based advertising, click here (or if located in the European Union click here). Please note you will continue to receive generic advertisements.
YOUR RIGHTS OVER YOUR INFORMATION
1. We appreciate that by law and subject to certain conditions, you have a number of rights concerning the personal information we hold about you. If you wish to exercise these rights, you should contact our Data Protection Officer.
2. These rights include the right to access the personal information we hold about you, the right to object to the processing of your data and the right to withdraw any consent provided. In some circumstances, you can ask us to delete the personal information we hold about you.
Right to complain to a supervisory authority
1. You also have the right to complain to the relevant data protection supervisory authority about our processing of your personally identifiable information.
Rights in direct advertising
1. If we process your personally identifiable information for the purpose of direct advertising, you have the right to object at any time to the processing of personally identifiable information relating to you for the purpose of such advertising; this also applies to profiling, where appropriate, insofar as it is associated with such direct advertising.
2. You may opt-out of receiving commercial messages from us by following the instructions contained in those messages or by contacting Customer Support. In the event of your objection to processing for the purpose of direct advertising, we will no longer process your personally identifiable information for these purposes.
HOW WE PROTECT YOUR INFORMATION
1. We have in place physical, electronic and operational procedures to protect the personal information that we collect. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Website. Our security measures are reviewed regularly and updated in keeping with technological advances.
HOW LONG WILL WE RETAIN YOUR INFORMATION
SHARING YOUR INFORMATION
1. We do not sell, trade, or rent the personal identification information of Users to others. However, there are circumstances when we share your personal data with other companies in the VGW Group, with third parties that provide services to you on our behalf, and with other third parties in the course of complying with our legal obligations.
With other companies within VGW Group
1. Please see Transfers below for further information on how we share information within the VGW Group.
With Third Parties
1. We only share information with third parties in limited circumstances including the following:
1.1. when you allow us to share your information with third parties;
1.2. when providing you with products and services and notifying you about either
important changes or developments to the features and operation of those products and
1.3. with our service providers to enable us to provide our services, such as
companies that help us with technology services, storing and combining data, and
processing payments and redemptions or providing relevant marketing and advertising
for our products and services. The partner companies will have access to your personal
information only to perform services on our behalf and are prohibited from using your
personal information for purposes other than those requested by us or required by law.
Where service providers use personal information for their own purposes, where
permitted by law, such service provider will act as data controller;
1.4. in response to lawful requests by public authorities, including to meet national
security or law enforcement requirements, when ordered to do so by any regulatory body
and/or under any legal provision contained in the governing law of a particular
1.5. when instructing and authorizing the financial institution with which a User’s
account is held to disclose any information as may be requested by a regulator in
respect of the User’s account;
1.6. when we share your personal information with third parties to enforce our terms
and conditions set out on our Website, to protect our rights and property and the
rights and property of our customers and third parties, to detect fraud or other
illegal activities and to comply with law or legal processes; and
1.7. to perform customer due diligence including ID verification.
4. We may also share generic aggregated demographic information not linked to any personal identification information regarding visitors and Users with our business partners, trusted affiliates and advertisers for the purposes outlined above.
1. VGW Group operates in several international jurisdictions and personal information we collect may be transferred to, and stored and processed by, the European Union, the United States, Canada, Australia, the Philippines or any other country in which we or our third party processors maintain facilities. We will ensure that transfers of personal data to any country or organization are subject to appropriate safeguards. Additionally, without limitation and where applicable, when transferring personal information from the European Union, we may use standard contractual clauses approved by the European Commission or otherwise in accordance with European data protection laws for ensuring adequate safeguards.
OTHER IMPORTANT INFORMATION
Compliance with Children’s Online Privacy Protection Act
1. Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our Website from those we actually know are under 18, and no part of our website is structured to attract anyone under 18.
Your California Privacy Rights
1. California residents may learn more about their rights, including how to exercise their rights under the California Consumer Privacy Act of 2018, by clicking here.
Do-Not-Track Signals and Similar Mechanisms
1. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, our Website currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.
2. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.
1. Personal information means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address, and telephone number. When anonymous information is directly or indirectly associated with personal information, the resulting information is also treated as personal information.
2. Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual.
3. Aggregate information means information about groups or categories of customers, which does not identify and cannot reasonably be used to identify an individual customer.
If you have specific questions regarding your personal information or how we use it, please contact our Data Protection Officer directly by email at the following email address firstname.lastname@example.org and specify your place of residence and the nature of your question. LuckyLand is located at 1209 Orange St. Wilmington, DE 19801.