Privacy Policy

Definitions

• "Account" refers to your user account created on the Website.
• "Covered Information" denotes data that enables the identification or contact of an individual, encompassing, but not limited to, first and last names, addresses, email addresses, phone numbers, and any identifier facilitating direct or indirect contact.
• "Confidentiality Incident" encompasses unauthorized access, use, loss, or transmission of a user's personal information, including any data enabling direct or indirect identification, as well as any breach of data protection.
• "Event Tagging" represents tags enabling the tracking of specific events carried out on our Website (e.g., purchases).
• "SweepCoins (SC, FICO or FC)" stands for the in-game currency used to enter and participate in \n Promotions as governed by our Rules and/or the Website's Terms and Conditions.
• "Gold Coin (GCO, TICO OR GC)" refers to the in-game currency utilized for Gold Coin Games as \n governed by our Rules and/or the Website's Terms and Conditions.
• "Marketing Pixels" are snippets of code that allow us to gather information about visitors and their interactions with our web pages.
• "Mobile Device Identifiers" represent unique identifiers on mobile devices used to differentiate one device from another, especially in internet-based advertising.
• "Participant" denotes a user acquiring, utilizing, or redeeming SweepCoins (SC, FICO or FC) in games.
• "Personal Information" denotes data that enables the identification or contact of an individual, encompassing, but not limited to, first and last names, addresses, email addresses, phone numbers, and any identifier facilitating direct or indirect contact.
• "Prize(s)" are SweepCoins (SC, FICO or FC) that are eligible for redemption by a Participant in \n accordance with our Rules and/or the Website's Terms and Conditions.
• "Service" signifies any service accessible through our Website or mobile applications.
• "Website" means the website available at turbostakes.com, including all associated domains, subdomains, and any related content, features, or services provided through or in connection with it.
• "User" represents an individual utilizing the Service.

Data Collection

We acquire information about Users through various methods. This includes directly identifiable information, such as:

• Contact details, encompassing your email address, physical mailing address, mobile phone number, and any additional phone number(s) provided.
• Personal information like your first name, last name, date of birth, and likeness.
• Account login details, including your unique username, password, and associated account images.
• Transactional details provided by you, such as mailing address, phone number, payment and/or other information for redemption and/or verification purposes (e.g., financial institution details, credit card information, and bank account statements).
• Information shared via live chat, email, or any other customer support method.
• Data obtained from third-party sources (e.g., Facebook) regarding your interaction with the Services.
• Location information, which is provided by devices interacting with our platform.
• Activity and device data related to your use of our Service, including content viewed/used, duration and frequency of access, source of learning about our Service, specific hardware model, device type, unique device identifiers, operating system, browser type, and IP address.
• Any documentation required to verify your eligibility for an account and payouts.

Additionally, we may collect non-directly identifying information, as well as data related to groups of customers that doesn't directly identify you, such as usage patterns of the Website or the device's zip code/postal code.

Upon providing any information to or via the Website, you affirm that the details furnished are accurate, complete, and up-to-date as is necessary for the purposes for which it is used. This includes acknowledging the accuracy of your contact information, like phone numbers and email addresses. It shall be your sole responsibility to update any and all information provided for use of the Website.

By providing your phone number(s) to us, you consent to being contacted using the provided number. Possible communication methods include pre-recorded voice messages, autodialed calls, SMS messages, and emails regarding:

• The Documentation.
• Account-related purchases or redemptions.
• Promotional content from or on behalf of us, given that we have your opt-in consent for certain types of messages.

To opt out of these messages, contact us at turbostakes.com or use the unsubscribe feature in the message.

Collection of Information

User information is gathered through various avenues, such as when a User accesses our Service, creates an Account, makes a purchase, responds to surveys (including those from related third parties), and interacts with any other service or feature offered by the Website.

We may also gather information from Users through various channels such as telephone, video, and correspondence via email, instant messaging, physical mail, SMS, and social media platforms. Telephone and video calls may be recorded for training, quality control, and compliance purposes. Participation in such calls implies consent to the call being recorded.

Technology Usage

We employ diverse technologies within our Website and applications on third-party sites, including cookies, pixels, tags, and application program interfaces (APIs). For instance:

• Cookies: Small text files stored on your device distinguish it uniquely.
• Similar Identifying Technologies: Such as Marketing Pixels, Mobile Device Identifiers, and Event Tagging. At times, Mobile Device Identifiers might be shared with advertisers.
• Analytical Tools: Utilized to gather information during your visits to our Website or when using our applications or services on third-party platforms.

Utilization of Your Information

Your information is employed for purposes outlined in this Privacy Policy. Additionally, it may be accessed by other companies within our group as data processors. Information collected is retained as required by this policy or permitted by law. We might share this information with our group companies or third-party service providers, adhering to applicable law, for an enhanced user experience or additional services.

Reasons for Collection and Use of Information

We collect and utilize your information for the following purposes:

• Identification and Verification: To identify you as a User and/or collect location information for the purpose of verifying whether you are eligible to access the Website.
• Transactions: To process transactions (including, without limitation, purchases and/or redemption requests). In the processing of payments, the information provided by you may be utilized to fulfill due diligence requirements related to anti-money laundering and payment verification. We do not disclose payment information to third-party processors except as necessary for transactional services.
• Service Provision: Establishing and maintaining your Account, conducting routine security checks, and addressing customer service requests.
• Customer Service Enhancement: Your information helps in providing optimal customer service.
• Legitimate Business Interests: When it is necessary for our legitimate business interests (or those of a third party), and your interests and fundamental rights do not override those interests.

Use of Aggregated Information

We may also conduct research on our user demographics, interests, and behaviour. We aggregate, anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. We may share this aggregated and/or de-identified data with our affiliates, agents, and business partners. We may also disclose aggregated and/or de-identified user statistics and other metrics related to our Website in order to describe our products or services to current and prospective business partners and to other third parties for other lawful purposes. Aggregated information assists in comprehending our users better, ensuring a more tailored user experience.

Communication and Notices

We may contact you via email, live chat, telephone, SMS, physical mail, or social media to manage Promotions and competitions you choose to participate in. This also includes sending important notifications concerning your purchases or any policy changes.

Compliance and Legal Obligations

The information collected is used to comply with legal and regulatory obligations, ensuring compliance with Documentation and other regulatory requirements.

Your Rights Regarding Information

You have specific rights concerning the securely stored information about you. Contact our representative to exercise these rights, which include accessing stored personal information, objecting to processing, and withdrawing consent provided in this Privacy Policy.

Information Security Measures

Safeguarding your personal information is of utmost importance to us. We utilize physical, electronic, and operational protocols to secure your data, employing industry-standard practices for collection, storage, and processing. Although we consistently standard practices for collection, storage, and processing. Although we consistently review and update our security protocols to meet industry standards, no system is entirely immune to unauthorized access. If you suspect a compromise of your information, notify us immediately at [email protected].

Information Retention

We retain your information for the duration necessary to fulfil the practices outlined in this Privacy Policy, as per our business needs, and in compliance with applicable laws. In case of Account closure, we may retain Account details for dispute resolution or clarification purposes.

Information Sharing

• Your information may be shared within our group of companies or with third parties providing services on our behalf, including, but not limited to, processing payments, conducting quality assurance testing, geo-locating users, personalizing and improving your use and experience of the Website, sending email and push notifications, enabling security support and technical maintenance, and preventing harmful and/or unlawful uses of the Website. Additionally, information may be shared with other third parties to ensure compliance with legal obligations. We share only the minimum necessary information to fulfil these purposes.
• We reserve the right to disclose to third parties information about users for marketing analysis and/or to our advertisers and advertising networks; however, any information disclosed will be in the form of aggregate data that does not describe or identify an individual user.

THIRD PARTY SERVICES AND COLLECTION OF INFORMATION

• Third parties may provide materials to the Website that use cookies, web beacons, or other tracking technologies to collect your information, including information about your online activities over time and across different websites and other online services. Those third parties may use this information to provide you with interest-based advertising or other targeted content. We do not control third-party tracking technologies or how third parties use them. Your use of third-party applications or services is governed by the user terms and Privacy Policy of the third party that provided that application or service. This Privacy Policy does not apply to any third party's websites, services, or applications, even if they are accessible, downloadable, or otherwise distributed through the Services.
• When you initiate a payment transaction through the Website, we may process your payments through a third-party Website, including, without limitation, third-party payment processers. The third-party Website may collect certain financial information from you in order to process a payment, including your name, email address, address, and other billing information.
• If you decide to use, click on, access, or provide any personal information to a third-party Website, you acknowledge that you are doing so at your own risk. websites that may be linked on the Website or the Services, nor are we responsible for the content or privacy practices of third-party websites. We disclaim any responsibility for your personal information on third party websites, and we do not make any warranties or representations that any third party Website will function without error or interruption, that defects will be corrected, or that any third party websites or their servers are free of viruses or other problems that may harm your computer.

ANNOUNCEMENT OF PRIZE WINNERS AND INFORMATION SHARING

We reserve the right to use a User's information to announce Prize winners through our Service, including details such as their name, the amount of SweepCoins (SC, FICO or FC) or Gold Coin (SC, FICO or FC), their city, state, country, profile picture, or any other collected personal information as described in this Privacy Policy for marketing purposes. This may include social media platforms, affiliated marketing channels, and physical media channels (such as radio, television, or print media).

Information Sharing in Business Transactions

Your information may be shared in association with the sale, merger, acquisition, or similar transaction involving the company to a third party or in the transfer of substantial company assets to a third party.

Changes to the Privacy Policy

Updates to this Privacy Policy will occur periodically to reflect legal changes and adjustments to our policies. Users will be notified of any significant changes, and when required by law, consent will be obtained. Changes become effective upon posting the updated Privacy Policy on our Website. Users are responsible for staying updated on these changes posted on our Website.

Contact Information

For inquiries, please reach out to our representative at [email protected].

INFORMATION FOR SPECIFIC GROUPS IN THE UNITED STATES

Our Services are available to individuals who have reached the age of majority in their respective jurisdictions. We will not knowingly collect or maintain information from minors. If you suspect that a minor has provided us with personal information and wishes for it to be deleted, contact us at [email protected].

FOR NEVADA RESIDENTS

Nevada residents who have made purchases related to the Services may opt out of the "sale" of "Covered Information" under Nevada law. While we may share your information with third parties for offers and promotions, we do not believe this sharing constitutes a sale under Nevada law. Nevada residents can request to opt out by contacting the representative at [email protected]. Reasonable steps will be taken to verify your identity and the authenticity of your request.

FOR CALIFORNIA RESIDENTS

• As a California resident, you hold the right to request disclosure of the personal information collected from you, to have that information deleted, and, subject to specific constraints, to opt out of the sale of your personal information.
• To exercise your California privacy rights, contact the representative by creating a ticket via our customer support portal. We will verify your identity when you request to exercise these rights. While logging into your Account might suffice, additional verification information may be requested if there are suspicions of Account compromise or if you do not have an Account.
• You also have the right to appoint an agent to act on your behalf. To verify authorization, your agent must provide a signed written authorization or a copy of a power of attorney.
• Twice within a 12-month period, you can request disclosure of the categories of personal information collected, used, and shared, including specific pieces collected and shared with third parties for direct marketing.
• You can also request the deletion of personal information collected from you, although certain information may be exempt under California law. Your choice to exercise these rights won't impact your access to or the quality of our Services.
• We might sell directly identifying information like name, telephone number, mailing address, or email address. Opting out of the sale of personal information is possible by contacting the representative via the customer support portal at [email protected].
• If you're a California resident under 19 years old, you can request to view, correct, or delete information provided by you or posted publicly. However, our Services are limited to individuals of legal age, and we will not knowingly collect or maintain information from minors.
• Regarding "Do Not Track" settings, we presently do not take actions to respond to these settings. Instead, we adhere to the standards outlined in this Privacy Policy.
• We might share the information described below with third parties for various purposes:
• With our group companies in line with this Privacy Policy.
• With vendors and partners to deliver our Services.
• If obligated by applicable law or legal process.
• To exercise, establish, or defend our legal rights.
• To safeguard vital interests.
• In connection with business sales.
• We collect various categories of information. The table below delineates how we collect and use such categories:

International Users

This Privacy Policy is intended to cover the collection of information within our home jurisdiction. Some countries may require stricter privacy policies than those described herein. If you are accessing the Website and/or Services from a foreign country, you understand and agree that your information may be transferred to, stored, and processed in our home jurisdiction or the jurisdiction of the third parties described herein, and that the data protection and other laws of our home jurisdiction or the jurisdiction of such third parties might not be as comprehensive as those in your home country

Governing Law

This Privacy Policy shall be construed and enforced in accordance with the laws of Florida, without regard to any conflict of law provisions. Notwithstanding the foregoing, this Privacy Policy and the collection of information hereunder shall comply with all applicable data protection laws and regulations.

Any dispute over privacy is subject to this notice's provisions and our Terms and Conditions.

This Privacy Policy is effective as of the date indicated at the top of this document (the “Effective Date”) and will remain in effect until amended or replaced in accordance with its terms. We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. Any updates will become effective immediately upon being published on the Website, unless otherwise specified. By continuing to access or use the Website after the Effective Date of any revisions, you acknowledge and agree to the updated Privacy Policy.