——PRIVACY POLICY——

Luckjoy Limited ("Luckjoy") is committed to protecting the privacy of its users ("users" or "you"). This Privacy Policy has been created to inform you about how Luckjoy manages, collects, stores, uses and protects the information you provide in connection with any Luckjoy game or application ("Service"). Also, this Privacy Policy describes how you can access and update that information. Please note that the scope of this Privacy Policy is limited only to the information collected by Luckjoy through your use of a Service. By using the Service, you agree to the collection and use of your personal information as outlined in this Privacy Policy. Luckjoy may amend the Privacy Policy from time to time, and Luckjoy encourages you to consult the Privacy Policy regularly for changes.

INFORMATION COLLECTED

Luckjoy's primary objective in collecting user information is to provide and enhance its Services and to enable users to enjoy its Services. When you install any of its Services, Luckjoy may collect and record the information you provide, whether through the Services themselves or through social networks, or other third party services ("Account Information"). We may collect information about you directly from you and from third parties, as well as automatically through your use of our Site, Applications or Services. Information We Collect Directly From You and As You Play Our Games and Information We Collect About You From Facebook When you log into our mobile application through your Facebook account, you will be asked to enter your Facebook email address and password. Facebook controls the information collected from you during the log-in process; Luckjoy does not control the information that Facebook collects from you. When you use any of our Applications (whether our mobile application or if you access our Facebook application), we will collect the following information: (i) access and collect your Facebook basic information (this includes your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other information you have you have set to public on your Facebook account); (ii) send you email; (iii) post to your Wall; (iv) access posts in your news feed; and (v) access your Facebook data at any time even if you are not using Facebook. Please note, if you allow Luckjoy to have access to this information, then Luckjoy will have access to this information even if you have chosen not to make that information public. For information about how Facebook may disclose your information, including any information you make public, please consult the Facebook Privacy Policy. We have no control over how Facebook uses or discloses the personal information you provide to it. We store the information that we receive from Facebook along with and other information that we collect from you or receive about you. Information We Collect Automatically. Cookies Like many websites, Luckjoy may use "cookies" to collect information. A cookie is a small data file that is transferred to your computer’s hard disk or your mobile device for record-keeping purposes. The Service may send cookies to a computer or a mobile device when a user accesses or views a Service. Information contained in a cookie may be linked to personal information for purposes such as improving the quality of Luckjoy' service, tailoring recommendations to interests, and making the Service easier to use. Third party advertisers on the Services may also place or read cookies on your browser. Cookies can be disabled at any time by changing your web browser’s options to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or functionalities of a Service.

Personal Information

“Personal information” means information about you that can be used to contact or identify you. The personal information types collected in accordance with a Service may vary depending on the activity and may include:

Your name; your social network or third party service user identification number; your mobile device’s unique identifier (UDID); transaction identifiers for purchases; your email address; your profile picture; your SDK/API/JS code version, browser, Internet service provider, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent deice identifier, iOS ad identifier (IDFA), Android ad master identifier, network card (MAC) address, and international mobile device identification code (IMEI) The equipment model, the terminal manufacturer, the terminal device operating system version, the session start / stop time, the location of the language, the time zone and the network state (WiFi and so on), the hard disk, the CPU, and the battery use, or any other relevant information included in your application, social network or other online profile.

Additionally, Luckjoy may acquire information from you through:

Your access and participation in message boards on a Service;

The contents of your Customer Support requests; or

Your purchase of a virtual product of any type. Please note that because a third party site manages the purchases of virtual goods offered by the Service, Luckjoy does not have access to your credit card details or any other billing information.

Non-Personal Information

“Non-personal information” is information that, when taken alone, cannot be used to identify or contact you. Luckjoy may collect non-personal information about your use of its Service both in the course of game play and software usage. Luckjoy may also invite you to share non-personal information about yourself, which may include but is not limited to:

Your age or date of birth;

Your gender;

Information about the hardware you may own;

Your favorite websites, friend information and fan pages; or

Any other information included in your application, social network or other online profile.

If non-Personal Information is collected for an activity that also requires personal information, Luckjoy may combine your non-personal information with your personal information in an attempt to provide you with a better user experience, to improve the value and quality of the Services and to analyze how its Services are used. The Service may also record game play information such as your game session duration or your high scores. In addition to information collected as described above, you may choose to share additional information about yourself throughout the Service, such as on message boards and in games. Any actions you perform with other players are considered public, and are solely at your discretion. Other information Luckjoy may collect includes your occupation, language, zip code, area code, location, and the time zone where a Service is used, as well as information about your computer, mobile device, software, platform, incident data, Internet Protocol (IP) address, network Media Access Control (MAC) address and connection, browser type, browser language, referring pages, exit pages and URLs, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity, so that Luckjoy can better understand customer behavior and improve its products, services, and advertising. Luckjoy may also receive either non-personal or public information from third parties in connection with market and demographic studies and/or data that Luckjoy may use to supplement personal information provided directly by you.

USE OF YOUR INFORMATION

Luckjoy uses your information to fulfill your specific requests, purchase orders and to send you purchase confirmation and other account-related information. In addition, the personal information you provide will allow Luckjoy to send you messages regarding, among other things, new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest. You may also later opt out of certain of these communications. Luckjoy may also use personal and non-personal information, both individually and combined together, to better understand the behavior and preferences of its customers, to troubleshoot technical problems, to serve static and dynamic advertising, to enforce its Terms of Service, to ensure proper functioning of its products and services as well as to help improve Services and their content. In addition, Luckjoy may combine non-personal information with personal information, such as an email address, to administer loyalty programs, tailor its offerings, web pages or game play experience to you. By use of friend finder tools whether directly through the Service or through a social network or gaming service, you acknowledge that use of these friend finder tools will help you find your contacts and will also allow your contacts to associate your Service account (and related gaming entitlements, including games played, spins and coins) with your social networking profile and/or email address. Your resulting friends’ list will be subject to this privacy policy. If you choose to use a referral service to "tell a friend" about a Service, Luckjoy may ask you for your friend’s name and email address. Luckjoy will send your friend an email on your behalf or a text message inviting him or her to visit the relevant site or check out the Service. Luckjoy stores your friend's name and email for a short period for the sole purpose of sending this email and for redundancy checking, to be sure that your friend does not receive multiple copies of the same email message. Luckjoy does not keep or use this information for any other purpose. If you enter into a sweepstake, contest, or similar promotion, Luckjoy may use the information you provide to administer those programs. Your participation in tournaments or other online gaming events is conditional upon you granting Luckjoy permission to collect, use, store, transmit and publicly display statistical data, such as your scores, rankings and achievements, generated through your participation. In all cases of data access and collection, the information you provide will not be disclosed, rented, loaned, leased, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used solely for the purpose of providing you with and improving the Service and for any other purpose stated herein. Luckjoy will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that Luckjoy no longer use your information contact Luckjoy at the email address provided in the Contact Us section below. Note that there may be instances where Luckjoy is legally required to retain your information.

Social Network Services or Mobile Devices

By accessing the Service through a social network, mobile device or other third party platform or service or by connecting to such a third party network, platform or service via a Service, you are authorizing Luckjoy to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed that the social network, mobile device or other third party platform could provide to Luckjoy through the social network/mobile device/third party platform Application Programming Interface (API) based on your settings on the third party social network, mobile device or platform. Your agreement takes place when you connect with the third party network, platform or service via the Service, and/or when you connect with a Service, or “accept” or “allow” (or similar terms) a Service to access your information through a social network, mobile device or other third party platform or service. Luckjoy may also collect or receive information about you from other Service users who choose to upload their email contacts. This information will be stored by Luckjoy and used primarily to help you and your friends connect. If you play Luckjoy’s games on your mobile device, in addition to your device identifiers, we may also collect:

the name you have associated with your device;

your telephone number;

your country;

your specific geolocation;

your mobile contacts;

information about Luckjoy and other third-party apps you have on your device.

If you want to remove your contacts stored by us, follow the instructions provided in the game to request that we remove them from our systems. If you need to enter a password to allow us to access your address book, we will not store that password.

Third Party Service Providers

Luckjoy may employ third party companies and individuals to facilitate its Services, to provide the Services on its behalf, to perform tasks (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services) or to assist Luckjoy in analyzing how its Services are used. From time to time, Luckjoy employs third party contractors to collect personal information on its behalf to provide email delivery, product, prize or promotional fulfillment, contest administration, credit card processing or other services through the Service. When requesting these services, you may be asked to supply your name, mailing address, telephone number and email address to its contractors. Luckjoy may ask some third party contractors, such as credit agencies, data analytics or market research firms, to supplement personal information that you provide to Luckjoy for its own marketing and demographic studies, so that Luckjoy can consistently improve its sites and related advertising to better meet its visitors' needs and preferences. To enrich its understanding of individual customers, Luckjoy may tie this information to the information you provide to it. If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Policy.

Message Boards and Chat Rooms

Note that certain information you post and communicate through a Service or a third party site or service is public information for which you have no expectation of privacy. You may choose to disclose information about yourself in the course of contributing user generated content to Luckjoy sites or Services or in its chat rooms, blogs, message boards, user “profiles” for public view or in similar forums on its sites through mobile services and/or through third party sites or services. Information that you disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality. You should be aware that any personally identifiable information you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. Luckjoy is not responsible for the personally identifiable information you choose to make public in any of these forums. If you post a video, image or photo through a Service for public view, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent. Luckjoy is not responsible for the videos, images or photos that you choose to post through a Service. Please see Luckjoy’s Terms of Service or the Application End User License Agreement at Terms of Service (as applicable) on this point and for other guidelines about posting content through any Service.

Browser Use

Note that in the ordinary course of Internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. Luckjoy has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would not like to share.

SHARING AND DISCLOSURE OF PERSONAL DATA

To improve our product and provide you with better service, we also share personal data with vendors or agents working on our behalf for the purposes described in this privacy policy. For example, companies we've hired to provide data analytical services and advertisement may need collect and access to personal data to provide specific functions. In such cases, these companies must abide by our data privacy and security requirements.

You understand and agree that Luckjoy may be required to disclose any personal information if required to do so by law or in the belief that such disclosure is reasonably necessary to avoid liability, to comply with legal process, including, but not limited to a subpoena, statute, search warrant, or court order, or to protect the property and rights of Luckjoy or a third party, to protect the safety of the public or any person, or to prevent or stop activity Luckjoy may consider to be, or to pose a risk of being, illegal, unethical or legally actionable. Note that Luckjoy is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that it may receive.

Luckjoy may also disclose information about you if it determines that such disclosure is reasonably necessary to enforce the terms and conditions of the Service or to protect its operations or users. We will share your information with third party companies to perform services on our behalf, like processing payments, analyzing data, optimizing game play, e-mail delivery, hosting services, customer service and to help us in our marketing efforts, including managing and delivering contextual and tailored advertisements. We contractually require these third party service providers to maintain the confidentiality of the information we share with them, and we contractually require them not use your information for anything other than to provide services on our behalf.

Additionally, Luckjoy may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. In the event that Luckjoy undergoes a business transition, like a merger, acquisition by another company, or sale of all or part its assets (like selling a game), we may transfer all of your information, including personal information, to the successor organization in the transition. We will make reasonable efforts to let you and other players know of the business transition before transferring your personal information.

We do not actively share personal information with third party advertisers for their direct marketing purposes unless you give us your consent. When advertisers or ad networks place ads in our Services, they may collect or we may share the following types of information from within our Services:

performance data (e.g. number of clicks on an advertisement);

certain technical information (for example, IP addresses);

your social network ID;

and other contextual data about your game play (for instance, your level).

The information collected may be used to:

offer targeted advertising (behavioral advertising), and/or

undertake web analytics.

Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time. Please note, after clicking on a third party advertisement, you may no longer be on a site hosted by Luckjoy or the social network through which you are playing Luckjoy’s games. If you do not want to receive tailored in-application advertisements from third parties, please see section Changing or Deleting Your Information of Privacy Policy.

Links

The Service may contain links to other websites or applications. The fact that the Service links to a website or application or presents a banner ad or other types of advertisement does not mean that Luckjoy endorses or authorizes that third party, nor is it a representation of any affiliation with that third party. If you click on a link to a third party site or application, including on an advertisement, you will leave the Luckjoy site you are visiting or application you are running and will go to the site or application linked to. These third party websites and applications may place their own cookies or other files on your computer or mobile device, and may collect data or solicit personal information from you. Other sites and applications follow different rules regarding the use or disclosure of the personal information you submit to them. Because Luckjoy cannot control the activities of third parties, it cannot accept responsibility for any use of your personal information by such third parties, and it cannot guarantee that they will adhere to the same privacy and security practices as Luckjoy. You are therefore encouraged to read the privacy policies or statements of other websites and applications you visit before providing any personal information.

Changing or Deleting Your Information

You may review, update, correct or delete any personal information by changing the applicable information in your profile page. If you completely delete all of this information, your account may be deactivated. If you would like Luckjoy to delete your record in its system, please contact Luckjoy and it will attempt to accommodate your request if it is not legally obligated to retain the record. You can request the deletion of your Account Information by dissociating or removing the Luckjoy application from your social network or third party service account in accordance with the instructions provided by the social network or third party service.

Security

Luckjoy has made reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, Luckjoy cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so Luckjoy discourages you from sending Luckjoy personal information through these media.

LEGAL BASIS FOR DATA PROCESSING

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you so you may use the Sites); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes).

In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Sites.

INTERNATIONAL OPERATIONS AND TRANSFER OUT OF THE EEA

Our business may require us to transfer your Personal Data to countries outside of the European Economic Area (“EEA”), including to countries such as the People’s Republic of China or Singapore. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as standard contractual clauses. A copy of those clauses can be obtained by contacting our Help Center.

IMPORTANT: When you use Our Services, your data may be sent to the United States and possibly other countries.

If you don’t live in the United States, Luckjoy will control your personal data. As part of our international operations, we may transfer data to our Affiliates (which means subsidiaries, parent companies, joint ventures and other corporate entities under common ownership with Luckjoy Limited from time to time for our legitimate business purposes. For example, Luckjoy Limited provides certain services to its Affiliates. We store information about players and visitors to its sites on servers located in the United States, and we may also store this information on servers and equipment in other countries. Personal data collected within the European Economic Area (“EEA”) may be transferred to, and stored at, a destination outside of the EEA. The data we hold may also be processed by employees operating outside of the EEA who work for us or one of our Affiliates or for one of our vendors. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. When we transfer your personal information internationally we will take reasonable steps to ensure that your personal information is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.

Policy Regarding Persons Under 21

This product is intended for use by those 21 or older for amusement purposes only. Without derogating from the foregoing, Luckjoy does not knowingly collect personal information from people under the age of 13. If you are under 13, you may not register for an account or provide any personal information to us. Luckjoy respects the privacy of parents and children and is committed to complying with in the Children’s Online Privacy Protection Act ("COPPA"). If a parent believes that his or her child has submitted personal information to Luckjoy, he or she can contact us via email privacy@luckjoy.com. If Luckjoy learns that a person under the age of 13 has provided it with personal information, Luckjoy will take steps to delete such information as soon as possible. We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children's use of online activities regularly.

Payments

For Luckjoy's policy regarding the purchase of “coins” or other virtual currency, please see Luckjoy's Terms of Service.

YOUR RIGHTS

Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data.

Where the use of your information is based on consent, you can withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Requests should be submitted by contacting us through privacy@luckjoy.com .

If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.

We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

Restrictions and Rules of Use

As a condition of your use of the Service, and without limiting your other obligations under these Terms of Use, you agree to comply with the restrictions and rules of use set forth in this Section as well as any additional restrictions or rules (such as application-specific rules) set forth in the Service. The Service is for your personal and noncommercial use only. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, reverse engineer, transfer or sell for any commercial purposes any portion of the Service, use of the Service or access to the Service, except for limited reverse engineering activities that may be, and only to the extent, permitted by applicable law. You agree to not use the Service to transmit, make available or otherwise promote or support: (a) any User Content that is unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, pornographic, sexual, libelous, invasive of others’ privacy, hateful, discriminatory or disparaging or otherwise objectionable or inappropriate; (b) any User Content that promotes illegal activity, such as drug use; (c) any User Content that you do not have a right to make available under any law or under contractual or fiduciary relationships; (d) any User Content that infringes any patent, trademark, trade secret, copyright or other intellectual property, proprietary or other rights of any party; (e) any unsolicited or unauthorized advertising, promotional materials, “junk mail,” “spam,” “chain letters,” “pyramid schemes,” or any other form of solicitation; (f) any spyware, passive collection mechanism or any other code or material that acts as a passive or active information collection or transmission mechanism; (g) cheats, hacks, cracks, malicious programs, viruses or any other computer code, files or programs that have the effect of or are intended to modify, impair, disrupt, destroy, interfere with or limit the functionality of the Service or any portion thereof, take control of any computer software, hardware or telecommunications equipment or interrupt any user’s uninterrupted use and enjoyment of the Service; or (h) unreleased Service content (such as in-game items or equipment), areas that have been unlocked by hacking into client data files, or data not available through normal operation or game play on any portion of the Service.

You are solely responsible for your interaction with other users of the Service and other parties that you come in contact with through the Service. Luckjoy hereby disclaims any and all liability to you or any third party relating to your use of the Service. You will cooperate fully with Luckjoy to investigate any suspected unlawful, fraudulent or improper activity, including, without limitation, granting Luckjoy access to any password-protected portions of your Account. Luckjoy reserves the right, but has no obligation, to monitor and manage disputes between you and other users of the Service.

CONTACT US

If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to privacy@luckjoy.com