POLICY SUMMARY

Personal Data collected for the following purposes and using the following services:

Advertising

  • AdColony, AppLovin
    Personal Data: Cookies and Usage Data

Analytics

  • Null

Contacting the User

  • Mailing list
  • Personal Data: email address, first name and password (encrypted)

User Registration

You need an account for most activities on our platform. Keep your password somewhere safe, because you’re responsible for all activity associated with your account. If you suspect someone else is using your account, let us know by contacting our contact us. You must have reached the age of consent for online services in your country to use Luck-O-meter.

You need an account for most activities on our platform, including to purchase and access services. When setting up and maintaining your account, you must provide and continue to provide accurate and complete information, including a valid email address. You have complete responsibility for your account and everything that happens on your account, including for any harm or damage (to us or anyone else) caused by someone using your account without your permission. This means you need to be careful with your password. You may not transfer your account to someone else or use someone else’s account. If you contact us to request access to an account, we will not grant you such access unless you can provide us with the information that we need to prove you are the owner of that account. In the event of the death of a user, the account of that user will be closed.
You may not share your account login credentials with anyone else. You are responsible for what happens with your account and Luck-O-meter . will not intervene in disputes between user who have shared account login credentials. You must notify us immediately upon learning that someone else may be using your account without your permission (or if you suspect any other breach of security) by contacting our contact us. We may request some information from you to confirm that you are indeed the owner of your account.
Users can delete their accounts at any time. If the user deletes their accounts, then there is no data available with the Luck-O-meter App. If you have deleted your user account from Luck-O-meter, then there is no refund for subscription.

Content performance and features testing (A/B testing)

  • Firebase Remote Config
    Null

Infrastructure monitoring

  • Firebase Crash Reporting
    Null

Managing contacts and sending messages

  • OneSignal
    Personal Data: Cookies, email address, , unique device identifiers for advertising, Usage Data and various types of Data as specified in the Privacy Policy of the service

Registration and authentication

  • Facebook Authentication
    Null
  • Direct registration
    Personal Data: email address, first name, last name, password (encrypted)

Enabling you to communicate with other users

Certain parts of our app services enable you to communicate and interact with other users. We will use information you have provided us to enable these interactions and communications on our Apps.

Our lawful basis for this use of your data is: performing our contract with you

Processing payments

We will use your information to process payments for our goods and services.

Our lawful basis for this use of your data is: performing our contract with you.

Targeted advertising

Through cookies, clear GIFs, web beacons and tracking pixels we will use your information to deliver relevant advertisements and offers to you and measure the effectiveness of the advertising and offers. These technologies connect your behaviour across different websites, mobile apps and devices and enable tailored advertising to be served to your game, web browser, or mobile device.

Our lawful basis for this use of your data is: your consent.

Social media

We will use your information to communicate with you where you message us, respond to our posts, “like” our posts, tweet or retweet us or otherwise interact with us directly on social media platforms.

Our lawful bases for this use of your data are: our legitimate interests in promoting our brand and communicating with interested individuals.

Anti-cheat, anti-tampering, fraud and unlawful activity detection and prevention

To enforce our rules and policies, protect our customers and business, protect the competitive integrity of our games, investigate, and deter against fraudulent, unauthorised or illegal activity.

Our lawful bases for this use of your data are: our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so.

Community and customer support

Handling all enquiries or complaints, troubleshooting and solving technical issues over live chat, phone, email and in-game chat, making necessary changes to our products and services and monitoring your participation in our forums and all parts of our services that allow you to publicly post information or interact with other users.

Our lawful bases for this use of your data are: performing our contract with you, our legitimate interests to provide you with customer service, our legitimate interest in providing the correct products and services to our website users or to comply with our legal obligations.

Improving and developing our Apps

Traffic optimisation, App data collection, analytics and research, including profiling and the use of machine learning (we sometimes use carefully selected third parties to do this on our behalf), cheat detection and prevention, managing landing pages and heat mapping our App.

Our lawful bases for this use of your data are: performing our contract with you and our legitimate interests in learning about the types of people who are interested in our App to keep our App, online services and updated and relevant, to develop our business and to inform our marketing strategy.

Contests

To process your entry into, contests, surveys or other promotional events that we run from time to time, should you decide to participate in them.

Our lawful bases for this use of your data is: your consent or contract.

Marketing

Sending you communications about our services, products and features that you have agreed to receive.

Our lawful bases for this use of your data are: your consent or our legitimate interests to provide you with marketing communications where we may lawfully do so.

Contact information

Owner and Data Controller
NE GAMES LTD
Owner contact email: gdpr@ne-games.com
Opt-out gdpr@ne-games.com

FULL POLICY

Owner and Data Controller
NE GAMES LTD
Owner contact email: gdpr@ne-games.com
Opt-out gdpr@ne-games.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: cookies, usage Data, unique device identifiers for advertising, email address, first name and password (encrypted).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this Privacy Policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the user, or, in case of usage Data, collected automatically when using this application.

Unless specified otherwise, all data requested by this application is mandatory and failure to provide this data may make it impossible for this application to provide its services. In cases where this application specifically states that some data is not mandatory, users are free not to communicate this data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which personal data is mandatory are welcome to contact the owner. Any use of cookies – or of other tracking tools – by this application or by the owners of third-party services used by this application serves the purpose of providing the service required by the user, in addition to any other purposes described in the present document and in the cookie Policy, if available. Users are responsible for any third-party personal data obtained, published or​ shared through this application and confirm that they have the third party's consent to provide the data to the owner.

Mode and place of processing the Data

Methods of processing

The owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the owner at any time.

Legal basis of processing

The owner may process personal data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • Provision of data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • Processing is necessary for compliance with a legal obligation to which the owner is subject;
  • Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the owner;
  • Processing is necessary for the purposes of the legitimate interests pursued by the owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The data is processed at the owner's operating locations and in any other places where the parties involved in the processing are located.

Depending on the user's location, data transfers may involve transferring the user's data to a country other than their own. To find out more about the place of processing of such transferred data, users can check the section containing details about the processing of personal data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the owner to safeguard their Data.

If any such transfer takes place, users can find out more by checking the relevant sections of this document or inquire with the owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the owner and the user shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. users may find specific information regarding the legitimate interests pursued by the owner within the relevant sections of this document or by contacting the owner.

The owner may be allowed to retain Personal Data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the owner may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Advertising, Content performance and features testing (A/B testing), Infrastructure monitoring, Registration and authentication, Analytics and Contacting the User.

Users can find further detailed information about such purposes of processing and about the specific personal data used for each purpose in the respective sections of this document.

Detailed information on the processing of personal data

Personal Data is collected for the following purposes and using the following services:

  • Advertising
  • Analytics
  • Contacting the User
  • Content performance and features testing (A/B testing)
  • Infrastructure monitoring
  • Managing contacts and sending messages
  • Registration and authentication

The rights of users

Users may exercise certain rights regarding their data processed by the owner. In particular, users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if data is being processed by the owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the owner.
  • Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where personal data is processed for a public interest, in the exercise of an official authority vested in the owner or for the purposes of the legitimate interests pursued by the owner, users may object to such processing by providing a ground related to their particular situation to justify the objection. users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn,​ whether the Owner is processing personal data for direct marketing purposes, users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the owner as early as possible and always within one month.

Additional information about data collection and processing

Legal action

The user's personal data may be used for legal purposes by the owner in Court or in the stages leading to possible legal action arising from improper use of this application or the related Services. The user declares to be aware that the owner may be required to reveal personal data upon request of public authorities.

Additional information about user's personal data

In addition to the information contained in this Privacy Policy, this application may provide the user with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

Legal action

The user's personal Data may be used for legal purposes by the owner in Court or in the stages leading to possible legal action arising from improper use of this application or the related Services. The user declares to be aware that the owner may be required to reveal personal data upon request of public authorities.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other personal data (such as the IP Address) for this purpose.

Information not contained in this Policy

More details concerning the collection or processing of personal data may be requested from the owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their Privacy Policies.

Changes to this Privacy Policy

The owner reserves the right to make changes to this Privacy Policy at any time by giving notice to its users on this page and possibly within this application and/or - as far as technically and legally feasible - sending a notice to users via any contact information available to the owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the user’s consent, the owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this application (or third-party services employed in this application), which can include: The IP addresses or domain names of the computers utilized by the users who use this application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the user, the various time details per visit (e.g., the time spent on each page within the application) and the details about the path followed within the application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the user's IT environment.

User

The individual using this application who, unless otherwise specified, coincides with the data subject.

Data Subject

The natural person to whom the personal data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, as described in this Privacy Policy.

Data Controller (or owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, including the security measures concerning the operation and use of this application. The data controller, unless otherwise specified, is the owner of this application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this application as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the user's device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

Alarm Manager

We are not using Alarm services at Luck-O-meter applications.


This Privacy Policy relates solely to this application, if not stated otherwise within this document.

Subscription Info

• Payment will be charged to iTunes Account at confirmation of purchase

• Subscription automatically renews unless auto-renew is turned off at least 24-hours before the end of the current period'

• Account will be charged for renewal within 24-hours prior to the end of the current period, and identify the cost of the renewal

• Subscriptions may be managed by the user and auto-renewal may be turned off by going to the user’s Account Settings after purchase

• Any unused portion of a free trial period, if offered, will be forfeited when the user purchases a subscription to that publication, where applicable.