Good Luck Games® Privacy Policy

Last updated: July 6, 2022

This privacy policy (this “Privacy Policy”) is designed to help you understand how we at Good Luck Games (“GLG”, “we” or “us”) collect, use, process, and share information we collect via our desktop and mobile game applications, forums, and websites (collectively, the “Services”) or when you otherwise interact with us.

We may amend and/or update this Privacy Policy from time to time by posting a new version. We encourage you to review the Privacy Policy whenever you access our Services to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.

Information we collect

We collect information you provide voluntarily to us, such as when you set up a user account for a game, respond to a survey, or request customer support. The types of information we may collect about you include, for example, your name, social networking screen names or IDs, email address and any other information you choose to provide.

When you access or use our Services, we may automatically collect certain information from you and/or your device, including for example:

• Log Information: about your use of our Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
• Device information: about the device you use to access our Services, including information about the device’s type, software and hardware, Media Access Control (“MAC”) address and other unique device identifiers (such as Device ID and Advertising ID), device token, mobile network information and time zone.
• Location information: about where the device you use to access our Services is located.
• Usage information: relating to your use of our Services, including which applications you use and your interactions with other users.
• Consumption information: about your consumption habits relating to your use of our Services, including which purchases you make.
• Other Information: collected by cookies and other tracking technologies: we use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your computer’s hard drive or in device memory that help us to improve our Services and your experience and see which areas and features of our Services are popular. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness.
• Information from third parties: We may also obtain information from other sources and combine that with information we collect through our Services. We may also collect information from game platforms or app stores when you download or update one of our applications. We may also receive personal information about you from other third-party service providers and advertising partners.
• Information from third party surveys: We may invite you to participate in surveys facilitated by third party survey partners. From these services we will collect the information you provide as well as your userID in order to be able to match it with your in-game information.

How we use your information

We may use information about you for variety of business purposes, including to:

• Provide, maintain and improve our current Services;
• Develop new Services;
• Provide and deliver the products and services you request and send you related information;
• Facilitate communications between users;
• Respond to your comments, questions and requests and provide customer service and support;
• Send you technical notices, updates, security alerts, push notifications and support and administrative messages;
• Communicate with you about products, services, offers, promotions and events offered by GLG and others, and provide news and information we think will be of interest to you;
• Personalize and improve our Services with the use of profiling to provide targeted advertisements, content or features;
• Process and deliver contest entries and rewards;
• Monitor and analyze trends, usage and activities in connection with our Services;
• Link or combine with information we get from others to help understand your needs and provide you with better service; and
• Carry out any other purpose for which the information was collected.

How we may share your information

We may share information about you for a variety of business purposes as follows or as otherwise described in this Privacy Policy:

• With other users of our Services;
• In response to a request for information if we believe disclosure is in accordance with any applicable legal requirement;
• With our service providers, vendors or partners that support or market our Services;
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of GLG or others;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
• With your consent or at your direction.

Security and electronic communications

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

We endeavor to safeguard your information consistent with the requirements of applicable laws. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services.

Your data protection rights

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications.

• “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies and Interest-Based Advertising. You may stop or restrict the placement of certain technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications.

  The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.

  Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. Depending upon applicable law in your jurisdiction, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the “right of data portability”).
• Request Correction of your personal information where it is inaccurate or incomplete.
• Request Deletion of your personal information.
• Request Restriction of or Object to our processing of your personal information.
• Withdraw your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will consider such requests in accordance with applicable laws.

Children’s Information

The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children younger than 13. If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account if applicable.

Third-Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. If you choose to enable in-game purchases, our third-party payment processor or platform may collect payment information from you in accordance with their privacy policies and terms.

Providing personal information to third-party websites or applications is at your own risk.

Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Supplemental California Privacy Notice

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information GLG has collected about them and whether GLG disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Information We Collect” and “How We Use Your Information” above, respectively.

Right to Know About Personal Information

You have the right to request that we disclose certain information to you about our collection, disclosure, sale and use of your personal information. Once we receive and verify your request, we will disclose to you the following (to the extent applicable to your request):

• The specific pieces of personal information we collected about you in the preceding 12 months;
• The categories of personal information that we have collected about you in the preceding 12 months;
• Categories of personal information that we disclosed or sold for a business purpose in the preceding 12 months;
• The categories of sources from which we have collected this personal information,
• The commercial or business reason(s) for having collected, used, disclosed, or sold that personal information; and
• The categories of third parties to whom we have disclosed or sold your personal information in the preceding 12 months.

You may exercise this right up to two times in any 12-month period.

Right to Request Deletion

You may also have the right to request deletion of your personal information. We will honor such request but might not be able to fulfill your request if we (or our service providers) are required to retain your personal information.

Disclosures of Personal Information under the CCPA

GLG does not sell your personal information and has not done so over the last 12 months. However, if you elect to do so, we may disclose your information to our partners. To the extent that such disclosure is, for legal purposes, deemed to be a “sale” under the CCPA, you may opt-out of having your information disclosed by not opting in to disclose your information, disabling third-party cookies on your device, or by contacting us as set forth in “Contact Us” below.

Opt-out. California residents may opt-out of the disclosure of their personal information to our partners by contacting us as set forth in “Contact Us” below.

Additional Privacy Rights for California Residents

Non-Discrimination. The CCPA prohibits businesses from discriminating against you for exercising your rights under the law.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take steps to verify your identity before fulfilling your request. We may charge a reasonable fee to process or respond to your verifiable consumer requests if they are excessive, repetitive, or manifestly unfounded.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: