Privacy Policy

Contents

 About this Privacy Policy

 Information We May Collect

 How We Collect Your Information

 How We Use Information

 How We share Information

 Third-Party Services

 Data Security

 Data Retention

 Your Rights

 Cookies

 California Consumer Privacy Act (CCPA)

 Virginia Consumer Data Protection Act (VCDPA) Rights

 GDPR Rights for EU Residents

 Rights of Residents in Brazil under LGPD

 Children's Privacy (COPPA Compliance)

 Legal Basis for Processing Personal Data

 Changes To This Policy

 How To Contact Us

 

About this Privacy Policy

Last modified on: October 14, 2024

This Privacy Policy outlines how and when we collect, manage, store, and protect personal data collected in connection with our app and related services (collectively, the "Services"). It also explains your rights and choices regarding your personal data. For the purposes of this Privacy Policy, Theotino (or "we," "our company," or "data controller") refers to Theotino and its subsidiaries, affiliates, representatives, officers, and directors for services that link to this Privacy Policy or otherwise make it available to you.

By using the Services, you consent to the collection and use of your personal information as described in this Privacy Policy. This policy is subject to updates, which will be posted here and take effect immediately. We encourage you to review it regularly to stay informed of any changes.

We may update this Privacy Policy from time to time by posting a new version on our website or within the app. Any material changes will be communicated through the Services.

Please review this Privacy Policy carefully. By continuing to use our Services, you acknowledge and agree to the practices outlined within.

If there is any difference between the English version and any other language version of this Privacy Policy, the English version will apply (to the extent of the difference and to the extent permitted by applicable law).

 

Information We May Collect

Our primary objective in collecting user information is to verify user accounts, render good service, fulfill your requirements, and resolve your issues. Rest assured that any information provided by you is well protected according to this Privacy Policy and applicable laws.

When you register for the game and use the Service, we may collect and record the information you provide to us, whether through the game or through social networks or other third-party services ("Account Information").

 

Personal Information

 Name: Your first and last name as provided during account creation.

 Location: Your general location based on your IP address.

 Third-Party IDs: Any third-party identifiers you provide when linking external accounts (e.g., Facebook, Google).

Usage Information

 In-Game Purchases:Records of any purchases made withinthe app.

 Game Features:Information about which game features you use most frequently inthe game.

 Game Preferences:Your preferred game settings and customization options inthe game.

 Game Types:The types of Bingo games you play inthe game.

  Usage Duration:How long you spend playingthe game.

 Usage Patterns:Information about how you interact withthe game. (e.g., gameplay frequency, time of day).

Technical Information

 IP Address:Your internet protocol address.

 Advertising Identifiers: Unique identifiers used for targeted advertising inthe game.

 Cookies: Small text files stored on your device to track your preferences and usage.

 Software Development Kits (SDKs):Third-party tools used for analytics and other purposes inour app.

Device Information

 Device ID: A unique identifier for your device.

 Device Platform:The operating system (e.g., iOS, Android) your device uses.

 Firmware: The version of your device's software.

 Mobile Carrier:Your mobile network provider.

 Preferred Languages:The languages you select.

Please note, while we do not access your financial information (such as credit card details), any purchases made through third-party platforms (e.g., Apple App Store, Google Play Store) are subject to their respective privacy policies.

In all cases, your data will not be disclosed, rented, loaned, leased, sold, or shared with unaffiliated third parties unless required to provide services or comply with legal obligations.

Permissions and Files

 Read/Write Permissions: We may request access to read and write files within the app's directory on your device, such as player log files, to ensure proper functionality and performance of the app.

Communications Data

 Customer Support Interactions: Records of your communications with our support team, including any issues reported and resolutions provided.

 Feedback: Information from feedback forms and surveys to improve our services.

 Text Messages: Data related to text messages for service interactions.

 Contacts: Information from your contacts may be collected to enable specific features or services within the app.

Transaction Data

 Payment Information: This includes details related to transactions, such as payment methods and billing information.

Other Personal Data

While our game itself does not require access to certain types of personal data, some third-party services (SDKs) integrated into the game may need to collect and use this information to function properly. These data collection processes are necessary for the features provided by these third-party services, not for the core game itself. We want to make sure you are informed about what data might be involved:

 Music Files: Audio files like music tracks or playlists that you may upload or access via certain features in the game.

 Other Audio Files: Non-music audio recordings, such as sound effects or voice memos, that are generated or interacted with using third-party services.

 Photos: Images or photos that you upload or capture within the game, including profile pictures or media shared through third-party services.

 Videos: Video files that you upload, record, or interact with via third-party services, including any videos you create or receive.

 Voice or Sound Recordings: Audio recordings made through third-party features, such as voice messages or notes.

 Files and Docs: Documents of various types (e.g., text files, PDFs) that you upload, store, or access through third-party services integrated into the game.

We are committed to ensuring that data collected by these third-party SDKs is securely managed and handled in compliance with this Privacy Policy and applicable laws.

Please note that while you can purchase virtual goods through the Service, these purchases are processed through third-party platforms (e.g., Apple App Store, Google Play Store). We do not have access to your financial or billing information, such as credit card details. All financial data related to your transactions is securely managed by the third-party platforms according to their own privacy policies.

In all cases of data access and collection, the information you provide will not be disclosed, rented, loaned, leased, sold, or otherwise shared voluntarily with unaffiliated third parties. We may use your information in the following ways:

 To create and manage your account, ensuring a secure and seamless gameplay experience.

 To facilitate communication between users.

 To provide technical support and respond to your queries.

 To complete transactions that you initiate.

 To collect feedback for improving our game and to tailor your experience.

With your consent, we may also send you push notifications to keep you informed about game updates, promotions, or other relevant information. You can opt out of receiving these notifications at any time through your device settings.

How We Collect Your Information

We collect your information through various interactions with our services, including:

 Registering for an account and using the service.

 Entering a game, competition, promotion, or survey.

 Providing feedback, requesting support, or otherwise communicating with us.

 Making a purchase of any virtual product.

 Connecting with or accessing our services using a third-party ID or log-in, such as a social networking site ID.

 

How We Use Your Information

The information we collect is used for the following purposes:

 To Provide and Improve Our Services:We use your information to deliver personalized content, process payments, and enhance the functionality and user experience.

 To Communicate with You:We may send you notifications, updates, and promotional emails to keep you informed about new features, offers, and other relevant information.

 To Perform Advertising and Marketing:Your information may be used to display personalized ads and promotional content based on your interests and preferences.

 To Protect Our Rights and Comply with Legal Obligations:We may use your information to enforce our Terms of Service, prevent fraud or illegal activities, and comply with applicable laws and regulations.

 For Any Other Business Purpose:As stated when collecting your personal data or as required by applicable data privacy laws, such as the California Consumer Privacy Act (CCPA).

How We Share Your Information

We may share your personal information with service providers who help us deliver products and services, process purchases, and communicate with you. Additionally, we partner with companies that manage our websites and third-party analytics firms that conduct market research to gain a better understanding of our users. These service providers are permitted to use or disclose your information only to fulfill their contracted responsibilities or as required by law.

 Third-Party Ad Servers: We collaborate with third-party ad servers to display advertisements, generate reports, manage ad responses, and analyze site usage. This enables us to deliver relevant marketing messages and ads to users. These ad servers may utilize cookies and tracking technologies to gather information about your visits to our app and other websites, allowing them to serve targeted, interest-based ads. This process involves the anonymous analysis of user behavior to ensure that the ads presented align with your interests.

 Endpoints: Your data may be securely transmitted through various communication endpoints to enhance your gaming experience and ensure data integrity and privacy. These endpoints support essential services such as personalized advertising, analytics, user authentication, crash reporting, and customer support. They also include services like Google Firebase for login management and Google Fonts for consistent content display. The partners and services involved include Facebook, Google, Google Firebase & Firebase Crashlytics, Google AdMob, Applovin, Unity, Zendesk, Mintegral, and Appsflyer. These endpoints safeguard your information as it interacts with our partners' systems, ensuring secure data transmission throughout.

 Data Types:The types of data we may share include user profiles, in-app activity and usage statistics, purchase and transaction details, and device identifiers (such as device ID or IP address). We ensure that only the necessary information is shared with service providers to perform specific functions related to the services they provide.

 SDKs (Software Development Kits): Our platform integrates SDKs from third-party vendors, which may collect and transmit personal data for purposes such as analytic, advertising, or payment processing. These SDKs enable the proper functionality of third-party services within our platform. We ensure that these vendors handle your data in compliance with applicable regulations.

Monetization Partners: We may share your personal data with our monetization partners, who assist in delivering personalized advertisements, measuring ad performance, and optimizing app functionality. These monetization partners include, but are not limited to:

Categories of Monetization Partners:

Monetization Partner

Purpose

Facebook

Personalized advertising based on your app interactions.

Google

Deliver tailored ads and analytics.

Google Firebase & Crashlytics

App analytics and crash reporting.

Google AdMob

Serve in-app advertisements.

Applovin

Deliver personalized ads.

Unity

Serving video and interactive ads.

Zendesk

Manage customer support inquiries.

Mintegral

Provide targeted advertising services.

Appsflyer

Mobile attribution and tracking user behavior.

Digital Turbine

Delivers apps and ads to increase developer revenue.

IronSource

Supports app growth and monetization through targeted ads.

 

These partners may collect data such as device identifiers, geographic location, and in-app activity to deliver relevant ads and optimize user experiences. We ensure that they process your data in accordance with this Privacy Policy.

You have the right to be informed when your data is shared or sold. To exercise your right to opt out, please contact us at support@luckybingo.xyz or through any available in-game support system. Once your request is received, we will ensure your data is no longer shared or sold in any ways you have opted out of.

Third-Party Services

We may work with third-party service providers, such as payment processors, analytics firms, and other specialized services, to help enhance the functionality and performance of our app. These providers operate independently and have their own privacy policies, which govern how they collect, use, and share your information. We recommend that you review these third-party privacy policies to understand how your data may be managed. Although we carefully select these providers and ensure they comply with relevant data protection laws, we do not have control over their privacy practices.

 

Data Security

We employ stringent security measures to safeguard your personal information from unauthorized access, modification, disclosure, or destruction. This includes the use of industry-standard encryption protocols and secure servers to protect the confidentiality and integrity of your data. Access to your personal information is restricted to employees, agents, contractors, and partners who require it to manage, develop, or enhance our services. These individuals are obligated to maintain strict confidentiality and may face disciplinary actions, including termination, if they fail to comply with these requirements.

Data Protection Officer (DPO): Theotinos IT team is responsible for overseeing data protection. If you have any questions or concerns about how your personal information is handled, you can reach out to our Data Protection Officer (DPO) at: support@luckybingo.xyz.

Data Retention

We will retain your personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy. After that, your information will be securely deleted or anonymized. If you wish to request the deletion of your personal data, please contact us at support@luckybingo.xyz.

Data Deletion

You have the right to request the deletion of your personal data. To exercise this right, please contact us at support@luckybingo.xyz. Upon receiving a valid request, we will:

 Verify Your Identity: For your data's security, we may need to confirm your identity before proceeding with your request. This may require you to provide additional information to verify that you are the rightful data subject.

 Process Your Request: Once your identity is confirmed, we will review your request and proceed with the deletion of your personal data, unless legal or contractual obligations require us to retain it.

 Confirm Deletion: After completing the deletion, we will send you a confirmation that your personal data has been successfully removed from our records.

 Exceptions: Please note that certain circumstances may require us to retain your data, such as fulfilling legal obligations, resolving disputes, enforcing agreements, or for other legitimate business purposes.

Your Rights

You have the right to request information about how we process your personal data, access a copy of the personal data we hold about you, and request that your data be modified, corrected, or deleted from our system. You may also request to limit or object to the processing of your personal data.

We will not make any decisions based solely on automated processing (including profiling).

If you have consented to the use of your data, for instance, to receive marketing emails or view personalized advertisements, you can withdraw your consent at any time. Please note that withdrawing consent does not affect the legality of data processing that occurred before your withdrawal.

To exercise any of the above rights, please contact us at support@luckybingo.xyz.

 

Cookies

Cookies are small files containing data, often used to identify users anonymously. These files are sent to your browser from the websites you visit and are stored in your device’s memory.

While this service does not directly use cookies, the app may incorporate third-party code and libraries that utilize cookies to gather information and enhance their services. You can choose to accept or decline these cookies, and be notified when a cookie is being sent to your device. However, if you decide to reject cookies, certain features of the service may become unavailable to you.

 

California Consumer Privacy Act (CCPA)

If you are a resident of California, the CCPA grants you the following rights regarding your personal information:

 Right to Non-Discrimination:You have the right to not be discriminated against for exercising any of your CCPA rights.

 Right to Opt-Out:You have a right to opt out from future sales or sharing of personal information as those terms are defined by the CCPA.

 Right to Delete:You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions.

 Right to Know:You have the right to request details about the personal information we collect, use, disclose, and sell, if applicable.

To exercise any of these rights, please contact us at support@luckybingo.xyz. We will respond to your request in accordance with the GDPR requirements.

Virginia Consumer Data Protection Act (VCDPA) Rights

If you are a resident of Virginia, the VCDPA provides you with the following rights:

 Right to Access:You have the right to request access to the personal information we hold about you.

 Right to Correct:You have the right to request the correction of inaccurate or incomplete personal information.

 Right to Delete:You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected or if you withdraw your consent.

 Right to Data Portability:You have the right to request a copy of your personal information in a portable and readily usable format.

 Right to Opt-Out:You have the right to opt out of the sale of your personal information or the processing of your data for targeted advertising purposes.

 Right to Appeal:If we deny your request to exercise any of these rights, you have the right to appeal our decision.

To exercise any of these rights or to appeal a decision, please contact us at support@luckybingo.xyz. We will respond to your request or appeal in accordance with the VCDPA requirements.

GDPR Rights for EU Residents

If you are a resident of the European Union (EU), you have certain rights under the General Data Protection Regulation (GDPR):

 Right to Access:You have the right to request access to the personal information we hold about you and to obtain a copy of that information.

 Right to Rectification:You have the right to request that we correct or update any inaccurate or incomplete personal information.

 Right to Erasure:You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected, or if you withdraw your consent on which the processing is based.

 Right to Restrict Processing:You have the right to request that we restrict the processing of your personal information under certain circumstances, such as when you contest the accuracy of the information or when you object to the processing.

 Right to Data Portability:You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another data controller.

 Right to Object:You have the right to object to the processing of your personal information on grounds related to your particular situation, including processing for direct marketing purposes.

 Rights Related to Automated Decision-Making:You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.

 Right to Complain:You have the right to complain to a supervisory authority about our collection and use of your personal data.

To exercise any of these rights, please contact us at support@luckybingo.xyz. We will respond to your request in accordance with the GDPR requirements.

Rights of Residents in Brazil under LGPD

If you are a resident of Brazil, the General Data Protection Law (LGPD) grants you the following rights:

 Right to Access:You have the right to request access to the personal information we hold about you and to obtain a copy of that information.

 Right to Rectification:You have the right to request the correction or update of inaccurate or incomplete personal information.

 Right to Erasure:You have the right to request the deletion of your personal information when it is no longer necessary for the purposes for which it was collected or if you withdraw your consent on which the processing is based.

 Right to Restrict Processing:You have the right to request that we restrict the processing of your personal information under certain circumstances.

 Right to Data Portability:You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another data controller.

 Right to Object:You have the right to object to the processing of your personal information on grounds related to your particular situation, including processing for direct marketing purposes.

 Right to Review Automated Decisions:You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.

To exercise any of these rights, please contact us at support@luckybingo.xyz. We will respond to your request in accordance with the LGPD requirements.

 

Children's Privacy (COPPA Compliance)

Our services are not intended for individuals under the age of 12, and we do not knowingly collect personal information from children under 12. If you believe we have inadvertently gathered such information, please contact us immediately at support@luckybingo.xyz, and we will take appropriate steps to delete the data.

Legal Basis for Processing Personal Data

We process your personal data in accordance with applicable data protection laws. The legal grounds for our processing activities include:

1. Consent
We may process your personal data when you have explicitly given consent for a specific purpose, such as signing up for newsletters, participating in promotions, or receiving marketing communications from us. You have the right to withdraw your consent at any time by contacting us at support@luckybingo.xyz. However, withdrawing consent may affect your ability to use certain features or services.

2. Contractual Necessity
Processing your personal data is often essential for fulfilling the terms of a contract to which you are a party. For example, we may process your data to manage your account, process purchases, provide customer support, and deliver services. Without this processing, we cannot meet our contractual obligations to you.

3. Legal Obligation
We may be required to process your personal data to comply with legal obligations imposed by laws, regulations, or government authorities. This includes obligations related to tax compliance, financial reporting, record-keeping, and responding to lawful requests from public authorities. Any data processed under this basis will comply with relevant legal standards.

4. Legitimate Interests
We may process your personal data based on our legitimate interests, as long as this does not override your fundamental rights and freedoms. Our legitimate interests include:

 Fraud Prevention and Security: We process data to monitor, prevent, and detect fraudulent activities, unauthorized access, and misuse of our services, ensuring your account and our platform are protected.

 Service Improvement: We analyze user behavior and feedback to enhance our services functionality, performance, and user experience. This includes research and analysis to better understand user preferences and trends.

 Marketing and Advertising: We may use your data to personalize and deliver targeted marketing communications, promotions, and ads relevant to your interests, providing a more tailored experience.

 Business Operations: We process data to support daily business operations, such as managing customer relationships, optimizing services, and conducting market research.

5. Public Task
In some cases, we may process your personal data to perform tasks carried out in the public interest or in the exercise of official authority vested in us. This may apply to situations where data processing is required for regulatory compliance, public health, safety, or other matters of public interest.

Changes To This Policy

We are dedicated to keeping our Privacy Policy up-to-date and reflective of our current data practices. Therefore, we reserve the right to update or modify this Privacy Policy at any time. Any changes will become effective immediately upon being posted within our app or on our website.

1. Notification of Changes
If we make any major changes to this Privacy Policy, we will notify you through prominent methods, such as in-app notifications, emails, or update notices on our website. We encourage you to review these notices to stay informed about how your data is being used.

2. Continued Use of Services
By continuing to use our services after any updates to this Privacy Policy, you are acknowledging and agreeing to the revised policy. If you do not agree with the updated policy, you should discontinue using our services and contact us to discuss your concerns.

3. Periodic Review
We recommend that you periodically review this Privacy Policy to stay informed about our data protection practices. This will help you better understand how we collect, use, and share your personal information, as well as your rights regarding that data.

How to Contact Us

If you have any questions about this Privacy Policy, please do not hesitate to contact us at support@luckybingo.xyz.