PRIVACY POLICY

Version: 1.0

Date: 2 June 2025

This Privacy Policy (“Privacy Policy”) governs the manner in which Luckyzino (“Luckyzino”, “we”, “us”, or “our”), collects, uses, maintains, and discloses information collected from users of its website https://luckyzino.com and any subdomains, subpages, successor sites, or any applications, games, products and services offered through or in connection with the website (the “Website” and collectively the “Services”). “Luckyzino” refers to Luckyzino LTD and its “Affiliates”, which shall mean subsidiaries, parent companies, joint ventures, and other entities under common ownership or control.

This Privacy Policy applies to all users of the Services, including customers, visitors, and participants in promotions, and covers all personal information / data collected through the Services.

At Luckyzino, we are committed to maintaining transparency, protecting and respecting your privacy, and maintaining the confidence and trust of our customers. This Privacy Policy explains what personal information we collect, the purposes for which we process it, how we store and secure it, and your rights in relation to that data under applicable laws. We are committed to complying with our obligations under applicable data privacy laws.

By accessing or using the Services, you acknowledge and agree to the collection, use, and processing of your personal information as described in this Privacy Policy.

DATA CONTROLLER

The business responsible for managing data collected through your use of the Website or Services is Luckyzino LTD, a company duly incorporated and existing under the laws of the Republic of Cyprus, with its registered address at 2 Poreias, Limassol, 3011, the Republic of Cyprus.

TYPE OF INFORMATION WE COLLECT

We collect the following types of information:

• Personal Information / Personal Data, which means any information about you, whether it is true or not, that can reasonably be used to identify you or otherwise make you identifiable.
• Anonymous Information, which means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual.
• Aggregated Information, which means information about groups or categories of customers that does not identify and cannot reasonably be used to identify an individual customer.

The categories of Personal Information we may collect, use, or process depend on your interactions with the Services and the purposes for which the data is processed. This may include:

• User Information, such as your first name and last name, email address, residential or billing address, phone numbers, date of birth, gender, age or age range, your image, unique personal identifiers, account login details including your username, password and pictures associated with your profile.
• Transaction Information you provide when you make a purchase, request a redemption or otherwise use the Services, such as your postal address, phone number, purchase and redemption history, payment or redemption information including banking and financial details, credit card details and bank account statements (we do not store your full card details). Any purchases and redemptions you make will be processed by the respective third-party service providers and will be subject to those third-party providers’ terms of service and privacy policy. Our third-party payment providers collect the billing and financial information required to process your charges / redemptions.
• Geolocation Information, which refers to approximate location information provided by a mobile or other device interacting with the Services or associated with your IP address. We do not collect precise geolocation unless required by law or for fraud prevention.
• Device Information, which may include information relating to the device you are using when you access our Services, such as your device type and model, browser type, operating system, IP address, device identifiers (e.g. IDFA, Android Advertising ID), mobile network information, and other settings that may be used to deliver and optimize our Services.
• Usage Data, which may include data related to your use of the Services such as the pages you visit, your actions within the Services, the time and duration of your visit on our Website, how often you use our Services, the type of content you have accessed, seen, forwarded and/or clicked on, WiFi connections, general geolocation information, date and time stamps, log files, and diagnostic, crash, and performance logs and reports.
• Identification Information, which may include government issued identity (including driver’s licenses, passport and social security numbers) collected to fulfill our legal obligations.
• Communications Information, which may include inquiries, feedback, survey responses, product reviews you write, or correspondence with us via email, chat, social media, or other communication channels, as well as audio or video recordings of communications with us / our customer support team.
• Information We Obtain From a Third Party, such as a site or platform provider (including Facebook and Google), about your use of or interest in our Services.
• Sweepstakes, Contests, or Promotions Information, which may include information submitted as part of your entry, such as responses, photos, videos, or other materials, information about the gameplay that you participate in the promotion, information you share with our managers and other information required to facilitate the promotion.

HOW WE COLLECT YOUR INFORMATION

We collect Personal Information through several sources and methods, depending on how you interact with our Services**.**

Information you provide to us directly
We collect your information in a variety of ways, including when you visit our Website or use the Services, register or create an account, make purchases or redemptions, communicate with us through filling out a form, using our chats or other means of communications, subscribe to marketing communications, participate in promotions, contests, or other activities made available via the Services. We may also collect information from you by telephone, video or in correspondence (including email, live chat, mail, text message or social media). All telephone or video calls between you and our representatives may be recorded for training, quality control and compliance purposes. By continuing with any such call, you consent to its recording.

Information we collect as you use our Services
We collect certain information about your use of our Services both in the course of gameplay and software usage. We collect certain information automatically. This may include information collected through cookies and similar technologies, application programming interfaces (APIs), pixels, tags, and beacons, analytics and performance tools, third-party sites or platforms. This information helps us analyze usage patterns, improve the Services, prevent fraud, and personalize your experience. For more details, please refer to the section titled “Personal Information Collected via Technology”.

Information we receive from third party service providers
We may receive information about you from third-party service providers and partners, including social media and platform providers (e.g., Facebook, Google), advertising and marketing networks, payment processors, identity verification and fraud prevention services. We may also use these sources to supplement or validate the information you provide, such as verifying your postal address or identity documentation.

PERSONAL INFORMATION COLLECTED VIA TECHNOLOGY

We and our service providers use industry-standard technologies, such as cookies or other similar technologies, to enhance your experience and help us deliver, maintain, and improve the Services. These technologies allow us to record certain pieces of information whenever you visit, access or interact with the Services. Information may include, in part, browser type and settings, operating system, device type, device identifiers, an estimate of your geographic location associated with your IP address, the page served, the time, referring URLs and other information normally transmitted in HTTP requests. This statistical data provides us with information about your use of the Services, such as general engagement with a page, the type of content on that page and how long you stay on that page. This information is generally non-identifying but if we associate it with you as a specific and identifiable person, we will treat it as Personal Information.

The following are examples of these types of technologies:

1. APIs. Application programming interfaces (APIs) work by allowing different types of software to interact with each other. We use APIs to provide core functionality, improve integration with third-party platforms, and enhance your experience.
2. Cookies. These are small text files placed in your device browsers to store your preferences. They are used to enhance your experience by making websites work in a more efficient way. Cookies help us to better understand your behavior including for security and fraud prevention purposes, they tell us which websites you have visited and facilitate advertisements and web searches. Cookies may be either first party cookies set directly by us to your device, or third-party cookies set by a third-party provider, on our behalf. When you first access our Website, you will be given the option to enable or disable cookies through our cookie banner. You can revisit your choice at any time via your browser settings. Most browsers allow you to block and delete cookies. Please note that disabling cookies may impact your experience and certain features of the Services may not function properly.
3. Event tagging. Event tags (including Facebook App Events) allow us to track actions that occur on the Website / Services such as game installs and purchase events. By tracking these events we can view analytics, measure ad performance, and build audiences for ad targeting.
4. Mobile device identifiers. When you access the Services through a mobile device, we or our service providers may collect device-specific information such as IP address and general location, hardware type and operating system, advertising identifiers (e.g., Apple IDFA, Google Advertising ID), in-app interactions and usage data. We may share advertising identifiers with third parties to serve you relevant ads. When you download or access our games through your mobile device, we may ask permission to track your activity. If you initially consent to tracking, you may later disable that permission in your device settings or withdraw your consent. In addition, if you do not want to receive third-party tailored advertisements, you may opt-out by adjusting the ad tracking settings on your device (such as turning on “Limit Ad Tracking” (Apple) or opting out of Ads Personalization (Android)) and reset your advertising identifier to disassociate from previous tracking. Further, you may be able to download apps such as the Digital Advertising Alliance’s “AppChoices” app to provide you with control regarding the collection and use of your cross-app data for tailored advertising. For more information on the advertising choice mechanisms, visit the NAI’s Mobile Choices page here. These opt-out tools are provided by third parties, not us. We do not control or operate these tools or the choices that advertisers and others provide through these tools.
5. Pixel tags/web beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in web pages or emails. We may use them to track user engagement, such as page visits, ad interactions (e.g., impressions, clicks), email open and forward rates. This helps us understand which content or campaigns are effective and tailor future communications accordingly.

WHY WE COLLECT INFORMATION. HOW WE USE COLLECTED INFORMATION

We collect and use the information collected for various purposes, including to operate and improve our Website / Services, to provide our products and Services, to facilitate your transactions, to respond to your questions, to provide customer and technical support and to fulfill all applicable regulatory requirements such as anti-fraud checks, and other checks required by applicable anti-money laundering and other requirements.

We will only collect and use your Personal Information when we are satisfied that we have an appropriate legal basis to do this. These legal bases may include:

• Our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you, including the terms and conditions that apply to your use of the Services, or to take steps at your request, such as completing transactions with you and allowing you to play our games.
• You have provided your consent to us.
• Our use of your Personal Information is in our legitimate interest as a business. In these cases we will handle your Personal Information at all times in a manner that is proportionate and respects your privacy rights, and you have the right to object to processing as explained in the "Your Privacy Rights" section below.
• Our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation.
• Our use of your Personal Information is necessary to protect your vital interests or those of another person (for example, another player).

We may collect and use your information for the following specific purposes:

To provide and manage the Services you request. This includes, for example, processing your registration, setting up your account, including checks made to guard against fraud.	Performance of a Contract; Legitimate Interest (fraud prevention).
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.	Legitimate Interest (Services efficiency and enhancement).
To process payments or redemptions, including verification of source of funds if required.	Performance of a Contract; Compliance with a Legal Obligation.
To personalize user experience. We may use information which has been aggregated to understand how our users as a group use the Services.	Legitimate Interest (personalization and improvement).
To contact you about our Services including marketing. We may contact you by email, live chat, telephone, text message, mail or social media for communications related to your use of our Services and products, including in connection with your accounts, offers and information about our products and Services, promotions and competitions you choose to enter, online surveys, new features that you are entitled to access, and other important information.	Where permitted by law, Legitimate interest in promoting our Services subject to providing users with the ability to opt-out; otherwise, Consent.
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.	Legitimate Interest (to keep users informed of essential service-related information).
To conduct market research and analysis. We may use information we collect about you to analyze how you interact with our products and Services, to monitor and analyze usage (including Usage Data) and activity trends, and for other research, analytical and statistical purposes.	Legitimate Interest (business intelligence and product development).
To provide customer / technical support.	Performance of a Contract; Legitimate Interest (user assistance).
To facilitate and personalize your gameplay experience.	Legitimate Interest (user engagement and experience optimization).
To provide you with advertising, including offering you relevant promotions and third-party products or services on our Services.	Legitimate Interest (to promote our Services and offering relevant third-party products and services).
To detect fraud, protect the security or integrity of the Services, users and our business and defend against security threats.	Legitimate Interest (security and fraud mitigation).
To handle data subject requests.	Comply with a Legal Obligation.
To establish, exercise or defend our legal rights.	Legitimate Interest (protection of business interests).
To comply with our legal and regulatory obligations. We may use information we collect about you to assess your social gameplay activity for responsible social gameplay purposes, 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 other policies or that may be illegal).	Comply with a Legal Obligation.

THIRD-PARTY ADVERTISING. BEHAVIORAL ADVERTISING

We may partner with third-party service providers to: (a) display advertising on our Website / Services; and (b) manage and optimize our advertising on other websites and applications. This helps us deliver more relevant advertisements and improve the effectiveness of our marketing efforts.

Certain types of Personal Information may be collected or shared when you use our Services, including:

• Device identifiers and technical information (such as IP address, device ID, browser type, operating system).
• Performance metrics (such as the number of views or clicks on an advertisement).
• Social media identifiers, associated with your accounts on platforms.
• Aggregated or de-identified demographic data (such as age range or general location).
• Gameplay and contextual gameplay data (such as your level or activity in the Services).

Our advertising partners, ad networks, and analytics providers may collect this information directly or may receive it from us. These third parties may use cookies, web beacons, APIs, and similar tracking technologies to:

• Display relevant ads on our Services or on third-party websites and applications.
• Measure the effectiveness of advertising campaigns.
• Analyze the use of our Services and identify usage trends.
• Avoid showing the same advertisements repeatedly.
• Select and display tailored ads.

These third parties may combine the information collected via our Services with information they collect from other sources to infer your preferences and serve you personalized content and advertisements.

Under applicable privacy laws, including the California Consumer Privacy Act (CCPA/CPRA) and similar U.S. state privacy laws (if they apply), you may have the right to opt out of the sale or sharing of your Personal Information with third parties for targeted advertising (also known as cross-context behavioral advertising). For more details, please refer to “Your Privacy Rights” section below.

HOW WE PROTECT YOUR INFORMATION

We implement appropriate technical and organizational measures designed to protect your Personal Information, taking into account the nature of the data, the context of processing, and the potential risks to the rights and freedoms of individuals. These measures include physical, administrative, and technological safeguards intended to protect against unauthorized access, alteration, disclosure, or destruction of your Personal Information.

We also follow industry-standard practices for collecting, storing, and handling data, and we regularly review and update our security controls to stay current with evolving technologies and threats. However, while we strive to use commercially acceptable means to protect your Personal Information, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

If we believe that a notifiable data breach has occurred, we will comply with all applicable legal obligations to notify you and/or relevant supervisory authorities, and we will take appropriate steps to contain, investigate, and mitigate the breach.

HOW LONG WILL WE RETAIN YOUR INFORMATION

We will retain the categories of Personal Information for various periods of time to reasonably fulfill the purposes specified in this Privacy Policy which will be determined based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained; (2) any legal, accounting, reporting or regulatory requirements applicable to such information; (3) internal operational needs, including to resolve disputes or enforce our agreements, to maintain appropriate business and financial records, etc.; and (4) any need for the information based on any actual or anticipated investigation, dispute or litigation. We will take reasonable steps to destroy or permanently de-identify any Personal Information where: a) we no longer need the Personal Information for any purpose for which the Personal Information was collected; and b) we are not required by law, a regulator or a court/tribunal order, to retain the Personal Information.

YOUR PRIVACY RIGHTS

We recognize that, depending on your location and applicable privacy laws, you may have a number of rights concerning the Personal Information we hold about you. Further information and advice about your rights can be obtained from the data protection authority in your country, state, or jurisdiction.

Your rights may include, but are not limited to, the following:

• Right to access. You have the right to request access to the Personal Information we process about you and to obtain a copy of that data.
• Right to rectification or correction. You have the right to request the correction of inaccurate or incomplete Personal Information that we hold about you.
• Right to restriction of processing. You may request that we restrict the processing of your Personal Information under certain circumstances.
• Right to be informed. You have the right to be informed about how your Personal Information is collected, used, and shared.
• Right to object. You have the right to object to certain types of processing, including processing for direct marketing.
• Right to deletion (erasure). You have the right to request the deletion or removal of your Personal Information, subject to certain exceptions permitted by law.
• Right to withdraw consent. Where we rely on your consent to process your Personal Information, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to data portability. You have the right to receive a copy of your Personal Information in a structured, commonly used, machine-readable format.
• Right to opt-out of sharing. You may have the right to opt out of the sharing of your Personal Information to a third party for cross-context behavioral advertising (also known as targeted advertising).
• Right to complain to a supervisory authority. You have the right to lodge a complaint with a data protection authority or other relevant regulator if you believe your rights have been violated.

Please note that these rights are subject to certain conditions and limitations under applicable law.

ADDITIONAL RIGHTS FOR U.S. RESIDENTS

Residents of California and other applicable U.S. states (where such laws apply to you and to us) may have the following additional rights: (1) Request to know more about the categories and specific pieces of Personal Information we collect, use, and disclose, including accessing the Personal Information we have collected about you during the past 12 months; (2) Request deletion of Personal Information, subject to certain exceptions permitted by law; (3) Opt out of the sale or sharing of Personal Information, opt out of targeted advertising; (4) Not be discriminated against for exercising your privacy rights; and (5) Limit the use and disclosure of your sensitive Personal Information, where applicable. We do not use sensitive Personal Information to infer characteristics about you. We do not use or disclose sensitive Personal Information for purposes other than those permitted under applicable law, such as providing Services you requested, ensuring security and integrity, and verifying your identity. Also note that we do not sell Personal Information for money or monetary consideration, however, we may use some services for purposes of serving ads that are more relevant to you, for ad campaign measurement and analytics. Some U.S. state privacy laws (in case they apply to us) may classify our use of some of these services as "selling" or "sharing" your Personal Information.
Please note that not all rights listed above may be afforded to all users.

HOW TO EXERCISE YOUR RIGHTS

To exercise your rights, please submit a verifiable consumer request to us at support@luckyzino.com or via the Support section within the Services.

For your request to be considered verifiable, you must provide sufficient information that allows us to reasonably verify that you are the individual to whom the information relates (or an authorized representative). This typically includes:

• Full name associated with your account
• Email address linked to your account
• Any other relevant information.

Please describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

If you would like to use an agent authorized in accordance with applicable law to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to exercise those rights on your behalf. We may follow up with you to verify your identity before processing your authorized agent’s request.

We will respond to verifiable requests within the timeframes required by applicable law. If we require more time, we will inform you of the reason and extension period.

We may deny your request if we are unable to verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a request does not require you to create an account with us. We will only use Personal Information provided in a request to verify the requestor's identity or authority to make the request.

We will not charge a fee to process your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Opting Out of Promotional Emails. You may opt out of receiving promotional emails by clicking the "unsubscribe" link at the bottom of our promotional emails. Please note that it may take some time to process your opt-out request, and you may still receive transactional or service-related communications.

Opting Out of Behavioral and Targeted Advertising. To opt out of behavioral or cross-context targeted advertising, you may:

• Visit the following industry-standard opt-out tools:
  • optout.aboutads.info
  • optout.networkadvertising.org
• Use your mobile device settings to adjust ad tracking preferences or reset your advertising ID (e.g., IDFA for Apple, GAID for Android).
• Download third-party opt-out apps such as the Digital Advertising Alliance's AppChoices**.**

These tools are operated by third parties, not us, and we are not responsible for their operation or accuracy. You may still see ads after opting out, but they will not be based on your behavior across unrelated websites or services.

Opting Out of Cookie Tracking. You can manage your cookie preferences through your browser settings, including the ability to block or delete cookies. Please note that disabling cookies may affect the functionality and performance of the Services. For more information, visit aboutcookies.org.

SHARING YOUR INFORMATION

We may share Personal Information with the following categories of third parties:

• Affiliates, meaning other companies within our corporate group;
• Service providers, meaning companies who provide services to you on our behalf or help us operate the Services or our business;
• Third parties that interact with us in connection with the services we perform;
• Professional advisors, meaning auditors, legal counsel, and other advisors who assist us in operating our business;
• Business transferees;
• Payment processors. Any payment card / financial information you use to make a purchase / redemption on the Services is collected and processed directly by our payment processors. These parties may use your payment data in accordance with their privacy policy.

If we share your Personal Information with a third party, we will take reasonable steps to ensure your information is protected to the same standards as we protect our own information, and we require them to use the Personal Information solely for the purposes requested by us or as required by law.

We may share Personal Information with third parties in limited circumstances including the following:

1. when you allow us to share your information with third parties;
2. when providing you with products and Services and notifying you about important changes or developments to the features and operation of those products and Services;
3. when such information is required by our service providers to enable us to provide our Services, such as companies that help us with technology services, storing and combining data, processing payments and redemptions or providing relevant marketing and advertising for our products and Services;
4. in response to lawful requests by public authorities, including to meet national security, law enforcement, or regulatory requirements;
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;
6. to enforce our Terms and Conditions or other policies, protect our rights and property and the rights and property of our customers and third parties, detect and prevent fraud or other illegal activities, and comply with law or legal processes;
7. when conducting web analytics to analyze traffic and player activity;
8. to carry out customer due diligence, including identity and age verification;
9. to satisfy any applicable laws, regulations, or mandatory codes of conduct that require us to disclose details about the information we collect; and
10. in connection with a restructuring, sale, merger, or acquisition of all or part of Luckyzino or its assets. We will take reasonable steps to notify affected individuals where required by law and explain how the transaction impacts their Personal Information.

We may also ask you to provide your image to assist with identity verification using facial recognition technology provided by a third-party service provider. This technology analyzes whether the image you provide matches your government-issued ID. These service providers collect information from your image capture on our behalf and may share this confirmation information with us. We do not collect or store biometric information. The third-party service providers store your biometric data in accordance with their privacy policy. They will store it until they have achieved the original purpose for collecting it, or until 3 years after your last interaction with us, whichever happens first, provided we have no other legal obligation to retain such information for any longer period.

We may also share aggregated information that is not linked to any Personal Information regarding visitors and users of our Services with our service providers, affiliates and partners for analytical or marketing purposes as outlined herein.

TRANSFER OF DATA

Luckyzino operates in several international jurisdictions, and Personal Information we collect may be transferred to, stored, and processed by, affiliates within our group or service providers in the European Union, the United States, or any other country where we or our service providers maintain facilities. We will ensure that transfers of Personal Information to any country or organization are subject to appropriate safeguards designed to protect your information and to comply with applicable data protection laws. Without limitation and where required, when transferring Personal Information from the European Union, we may rely on standard contractual clauses approved by the European Commission or adopt other lawful transfer mechanisms recognized under applicable data protection laws. Please note that data protection laws in some of these countries may differ from those in your jurisdiction and may not provide the same level of protection. However, we will take reasonable steps to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

MINORS

Protecting the privacy of children is especially important to us. Our Services are not directed to or intended for individuals under the age of 18. We do not knowingly collect or maintain Personal Information from individuals under 18. No part of our Website and the Services is structured to attract anyone under the age of 18. If we become aware that we have collected Personal Information from an individual under the age of 18, we will take reasonable steps to delete such information from our records.

THIRD-PARTY LINKS AND SERVICES

Our Services may contain links to third-party websites, applications, or services that are not owned, controlled or operated by us. We are not responsible for the privacy practices or content of such third parties. We encourage you to review their privacy policies before interacting with them or providing your Personal Information.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes to our practices or for other operational, legal, or regulatory reasons. Any changes to this Privacy Policy will become effective when the updated version is posted on our Website, unless otherwise specified.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your Personal Information. Your continued use of the Website / Services after any changes are made constitutes your acceptance of the updated Privacy Policy.

This Privacy Policy, in effect as of the last modified date stated below, supersedes and replaces any and all Privacy Policies previously in effect.

GOVERNING LAW AND JURISDICTION

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Cyprus, without regard to its conflict of law principles. Any disputes arising out of or relating to this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Republic of Cyprus. However, Luckyzino reserves the right to initiate proceedings against you in your country of residence or any other relevant jurisdiction, where appropriate.

CONTACTING US

If you have any specific questions regarding your Personal Information, how we process or use it, or to exercise your rights, please contact us at support@luckyzino.com.