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Last Updated:October 8, 2021


Welcome!  This privacy policy (“Privacy Policy”) governs your use of the TrueLuck Website (“Website”) and TrueLuck Apps (“Apps”) and your use of any interactive features, services, widgets, plug-ins, applications, content, downloads and/or other online services that we own and control and that post a link to this Privacy Policy (collectively with the Website and the Apps, the “Services”), which are made available by ???? (“???”, “TrueLuck”, “we” “our” or “us”).  To ensure the trustworthiness of our games and the quality of your experience, we collect and process information about our users. We are committed to handling that information with respect, because your privacy is very important to us.  TrueLuck Inc. has prepared this notice to explain how we collect, use, and share information from users of our Website located at, our mobile Apps, and our online gaming products and related Services available through the Website and Apps including our social networking features. This notice does not apply to websites, applications, or services that do not display or link to this statement or that display or link to different privacy statements.This Privacy Policy does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below), and does not govern the data practices of third parties that may interact with our Services.  To the extent we provide you notice on our Services of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Services’ Terms of Use, which governs your use of the Services. By using our Services you consent to our Privacy Policy and Terms of Use and our collection, use and sharing of your information and data, and other activities, as described below. If you do not agree to the terms of this Privacy Policy, please do not provide us with any Personal Information and do not use these Services.  If you object to the collection, use, and sharing practices described in this notice, you should not use our Website, Apps, or Services. If you are a California resident, please see Section 12 below for additional information regarding your California Privacy Rights.



It is important that you read and understand the entire Privacy Policy before using the Services. To ease review, each section below contains a brief introductory summary and a link to the full explanation. Click on the headings to be taken to the full explanation. Any capitalized terms that appear in but are not otherwise defined in the introduction have the meanings given to them elsewhere in the Privacy Policy.


  1. What Information Do the Services Collect?
    We collect and receive certain information about you as you interact with our Services, explained further in this Section.

    1. Information You Provide to Us
      We may collect certain Personal Information and Demographic Information (defined below) that you provide to us when you interact with the Services. For example, we may collect this information through various forms and in various places on the Services, including when you sign-up for an account to use the Services or otherwise make a request on the Services.

    2. Information Collected and Stored As You Access and Use the Services
      Certain information may be collected from you automatically when you access and use the Services. For example, we and third parties may use Tracking Technologies (defined below) to collect Usage Information (defined below) based on your Device Identifier (defined below) for a variety of purposes, which may include activities over time and across third party locations.

    3. Information collected via Technology

When using our Services, we may automatically track your visits and usage, collect information regarding your device(s), and use third-party analytics to analyze how you use our Services.

  1. Location-Based Information
    When using our Services, we may obtain information about your location or provide other location-based services to you.

  2. Information Third Parties Provide About You
    We may obtain information about you from third parties.

  3. Interactions with Third-Party Services
    If you interact with third-party services, those services may send us information about you and you or we may send them information about you.

  4. Information You Provide About a Third Party
    You may provide us information about others, such as when you send a friend a message.

  5. Do Not Track Disclosures
    We do not look for or respond to “do not track” signals.

  1. How do we use the information collected?

We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this Section.

  1. How and When do we share information with Third Parties?

We may provide your information to third parties under various circumstances detailed in this Section. These may include:

  1. When You Request Information From or Provide Information to Third Parties
    If you request information from third parties, request that we send information to third parties or interact with third-party websites, ads, content or tools, we may share your information with such parties and/or they may collect your information directly.

  2. Third Parties Providing Services on our Behalf
    Our vendors may collect your information on our behalf or we may share it with them so that they may provide services to us and you. Some may offer you choices regarding the collection and use of your information.

  3. To Protect the Rights of ??? and Others
    There are a variety of administrative and legal reasons for which we may share some or all of your information.

  4. Affiliates and Business Transfer
    We may share your information with our affiliates as well as in the event of a sale, merger or similar transaction.

  1. What about information I disclose publicly or others?

    1. User Content and Public Information
      Posting content in public areas makes it available to others. We may share and use your public information for any reason not otherwise prohibited by this Privacy Policy.

    2. Name and Likeness
      You grant us the right to use your name and likeness in connection with your posting and activities.

  2. Ads and Information about You

We and third parties may send you targeted ads based on your location, information and/or behavior. If you object, you can exercise choices some third parties may offer.

  1. Does Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

We may allow you to access third-party content on the Services, or to link to third-party applications and locations from the Services, but we are not responsible for your interaction with third-party content, apps and locations. 

  1. How Do I Change My Information and Communications Preferences?

You may change certain account information and communications preferences as more fully detailed in this Section.

  1. Your choices regarding Personal Information

Information on receiving your tax information and changing or deleting your private information is detailed in this Section.

  1. What About Data Retention?

We may retain your data for a period of time, explained more in this Section.

  1. What Should Parents Know About Children?

We do not intend to collect Personal Information from children as explained in this Section. If you think we have, let us know. 

  1. What About Security?

No data security is absolute, but we endeavor to take reasonable steps to secure data appropriately as explained in this Section.

  1. State-Specific Privacy Rights for Residents of Certain States (California, Nevada)

Certain states require specific disclosures about collection and sharing of their data and provide certain rights to residents of their states. These are detailed below.

  1. What About Changes to the Privacy Policy?

We may change this Privacy Policy upon posting of a revised privacy policy. However, we will continue to treat your Personal Information under the terms of the privacy policy in effect when it was collected unless you otherwise consent.

  1. Your Rights and Responsibilities

You should take reasonable steps to keep your information from getting stolen as explained in this Section.


The Full Detailed Privacy Policy


  1. What Information do the Services collect?
    1. Information You provide to Us

  1. You may choose voluntarily to provide certain personal information to us (“Personal Information”). Personal Information is information that can be used to identify you, such as your name, address, email address, phone number, credit card information, billing information, driver's license number, and social security number.

  2. For example, you may decide to share your first and last name, date of birth, location, email address, phone number, username and password, and the country and state in which you reside when you create an account to log in to our network ("Account"). We need this information to set up your Account, verify your identity, and provide you with our Services.

  3. We may also ask you to provide demographic information, such as information about your gender (“Demographic Information”). We may collect this information through various forms and in various places on the Services, including if you register for an Account, through “contact us” forms, or when you otherwise interact with the Services. If we combine Demographic Information with the Personal Information we collect directly from you on the Services, we will treat the combined data as Personal Information under this Privacy Policy.

  4. When you use our website (“Website”), our mobile, tablet, and any other TrueLuck Application(s) (“Apps”), or Services (collectively the Website and Apps), or deposit or withdraw funds from your Account, we may collect all information necessary to complete the transaction and provide you with the Services, including your name, address, email address, phone number, credit or debit card information and other billing information, social security number, tax documents, and records of the products and Services you purchased, obtained, or considered.

  5. If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content provided in the email, in order to send you a reply, provide customer and technical support, improve and optimize our Services, satisfy our legal obligations, enforce our contracts, and address any existing or anticipated disputes.

  6. We will collect the profile photo you upload and username you choose for your public profile page including in connection with our social networking features ("Profile") to give you a personalized experience of our Services. When you participate in any contest, game or other gaming-related product or promotion through the Website, Apps, or Services (each, a "Game" or, collectively, "Games"), other participants (each, a "Player") will be able to see the information you selected for your Profile.

  7. If you tell us where you are (e.g., by allowing your mobile device to send us your location or by otherwise permitting us to geolocate you), we may store and use that information to verify your eligibility to enter certain Games, to comply with relevant laws, and for fraud prevention purposes.

  8. When you participate in one of our surveys, we may collect additional information about your Profile, activity, usage, and preferences related to the Website, Applications and Services, so that we can evaluate your interest in and the quality of our products, Services, and customer and technical support.

  9. If you participate in a sweepstakes, Game, or giveaway through our Services, we may collect your email address and phone number, to notify you if you win or not. We may also ask for users' first and last names and addresses, in order to verify their identities. In some situations we may need to collect other information about user preferences as part of the entry process, such as a prize selection, or in connection with the award of prizes over a certain dollar amount. Such sweepstakes and Games are voluntary. We recommend that you read the rules for each sweepstakes and Game before you enter it.

  10. In the event you use our social networking features, we may collect and other TrueLuck users may be able to see your Profile information, including your username, real name, photo, location, the content you post on your social feed and the feeds of other TrueLuck users, and any other information you choose to upload or share. We may also collect, and other TrueLuck users may be able to see, information about the Games you participate in, including the bets you have made and your betting unit data as shown in your betting feed, along with your aggregated betting data on our trending bets page. In the event you elect to sync, upload, or import data about your contacts from your device's address book, we may collect and use that information to provide you and your contacts with our Services, help you find and connect with your contacts through our social networking features, help your contacts connect with you through our social networking features, and for other purposes set forth in this privacy notice. In general, the information you choose to provide when using our social networking features is public and you should exercise caution and good judgment before you post, upload, sync, import or otherwise share information with us and others, in order to avoid disclosing sensitive, harmful, or unlawful information. You are solely responsible for the content you post and other information you provide, whether by posting, syncing, importing, uploading or otherwise, when you choose to use our social networking features. You may control who is able to view and access the information you share by using our social privacy settings. The privacy settings allow you to determine who is able to see your Profile information and Game participation activity through our social networking features; who can add you as a friend on TrueLuck; who can find you in a username search; who is able to see your real name on search and friends lists; whether you will receive notifications of replies and reactions to your posts; whether you will receive notifications that someone has posted content to your feed or mentioned you in a post; who can see your posts; who is able to see your betting unit data alongside the bets shown in your betting feed; who is able to share their bets with you and invite you to place a bet; and who will be able to see your aggregated betting data on our trending bets page.


  1. Information Collected and Stored As You Access and Use the Services

    1. In addition to any Personal Information or other information that you choose to submit to us via our Services, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Services (''Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Services. When your Device contacts our web servers (for example, when you visit these Services or view an HTML email), our web servers automatically collect Usage Information. We also may determine the applicable technology available in order to serve you the most appropriate version of a web page, email, advertising or promotional announcement or similar service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Services, we will treat it as Personal Information.
      This Usage Information may include:

      1. your IP address, UDID or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Services, and our computers identify your Device by its Device Identifier;

      2. your Device functionality (including browser type, operating system, hardware, mobile network information);

      3. the areas within our Services that you visit and your activities there, including remembering you and your preferences;

      4. your Device location;

      5. your Device characteristics; and

      6. certain other Device data, including the time of day, referrer data that identifies the web page visited prior and subsequent to visiting our Services among other information.


  1. Information collected via Technology

    1. In order to improve, personalize, and optimize our Services and meet our legal obligations, we may automatically track certain information about your visits to and usage of our Website, Apps, and Services, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), device identifier, domain name, clickstream data, referring/exist pages, geolocation, and a date/time stamp for your visit. We also use this information to analyze trends, administer the Website, gather demographic information about our user base, deliver advertising, perform research, provide technical and customer support, inform our product development efforts, protect our legal rights, address disputes, and prevent our Services from being used to commit harmful or unlawful activities, including fraud. Some of this information may also be collected so that when you use the Website, Apps, or Services again, we will be able to recognize you and optimize your experience accordingly.

    2. We may collect information about the devices you use to access our Services, including the hardware models, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information. If you have downloaded our mobile Apps, we may also collect certain information from your mobile device, including information about how you use the Apps. This information is generally used to help us deliver relevant information to you. In the event our Apps crash on your mobile device, we will also receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs, provide other technical support, and improve and optimize the performance of our Apps.

    3. Like many online services, we use "cookies" to collect technical information. Cookies are small pieces of information that a website sends to your computer's hard drive while you are viewing the website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website, Apps, and Services. We may use cookies to collect information about your IP address, browser type, operating system, device type and identifiers, platform type, as well as your usage of and activity on our Website and Apps and the performance of our Services. These types of information are collected to make the Website, Apps and Services more useful to you and to tailor your online experience to meet your special interests and expectations. You can use the options in your web browser to notify you when you receive a cookie or you may change your cookie preferences in your Internet browser or with third parties. You can control and/or delete cookies used by our Services at any time. For instructions on how to delete cookies using your particular internet browser, visit . You can delete all existing cookies on your computer and adjust settings for most browsers to prevent cookies from being received.

    4. In addition, we use "pixel tags" (also referred to as clear gifs, web beacons, or web bugs). Pixel tags are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of web users. In contrast to cookies, which are stored on a computer's hard drive or web browser, pixel tags are embedded invisibly in web pages. Pixel tags are often used in combination with cookies, trigger the placing of cookies, and transmit information to us or our service providers. This enables two websites to share information. The resulting connection can include information such as a device's IP address, the time a person viewed the pixel, an identifier associated with the browser or device, the type of browser being used and the URL of the web page from which the pixel was viewed. Pixel tags also allow us to send email messages in a format that users can read, tell us whether emails have been opened, and help to ensure we are sending only messages that may be of interest to our users. We may also use this information to reduce or eliminate messages sent to a user.

    5. We use certain service providers, such as ThreatMetrix, to provide threat detection, user authentication, and fraud prevention services. These service providers may automatically collect certain information about your visits to the Website and Apps, as well as the device you use to connect to our Services, in order to monitor for potential threats and bad actors. This information may include, among other things, your IP address and your device's unique identifiers. If you would like to know more about ThreatMetrix's data privacy practices, please review their privacy policy located at: .

    6. We may use certain vendors to serve ads on our Services, as well as on other websites, applications, and social media networks. In connection with the delivery of advertising, certain vendors , including, but not limited to, Facebook, Twitter, Reddit, TikTok, Snapchat, FantasyPros, LiveRamp, The Trade Desk and TruSignal, may collect information about you and your visits to this and other websites. That information may include your IP address, internet service provider, unique personal identifiers (e.g., email address), and the browser you use to visit and use our Services and other websites and applications. They may do this by using cookies, beacons, pixel tags, clear gifs, or other technologies. The information collected may be used, among other purposes, to deliver advertising targeted to your interests and to better understand your usage of, preferences on, and visitation of our Services and other sites, social media networks, and applications tracked by such vendors. This notice does not apply to, and we are not responsible for, cookies, pixel tags and other technologies used in connection with other parties' ads, and we encourage you to check the privacy policies of advertisers and ad services to learn about their use of such technologies. If you would like more information about these practices to understand your options for not having your information collected and used by such companies, please click and .

    7. We use a number of service providers, such as Google Analytics, to help analyze how people use our Services ("Analytics Companies"). Analytics Companies use cookies and similar technologies to collect information pertaining to how people use our Website and Applications, what pages they visit, and what other sites they may have used prior to using our Services. We use the information we get from Analytics Companies to improve and optimize our Website, Apps, and Services.

    8. We may enter into agreements with companies that refer users to our Services via hyperlinks available on the referring party's website. We may automatically collect certain information, such as your IP address, other personal identifiers, and the identity of the referring website via cookies, pixel tags and similar technologies that are provided to us in connection with your use of the referring party's website.


  1. Location-Based information

    1. Our Services use location-based services in order to locate you so we may verify your location, including your geolocation records, for purposes of verifying whether you are eligible to participate in a Game, sweepstakes, or giveaway or to determine if you are otherwise permitted to use our Services. We also use location-based services to deliver you relevant content and ads based on your location as well as to share your location with our vendors as part of the location-based services we offer. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by us and our partners and licensees to provide and improve location-based products and services. You should consider the risks involved in disclosing your location information to other people. We may also use such information to comply with our legal obligations, protect our legal rights, and address existing or anticipated disputes.


  1. Information Third Parties Provide About You

    1. We may receive information about you from your friends and others that use the Services. Additionally, we may, from time to time, supplement the information we collect directly from you on our Services with outside records from third parties including from our pages on certain Social Networking Sites, the Social Networking Sites themselves, and from commercially available sources (e.g., data brokers and public databases) for various purposes,including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. The information we receive may include demographic data such as age, gender and income level, your preferences, interests, associations, commercial information, including records of products or services purchased, obtained, or considered and other purchasing or consuming histories or tendencies, as well as information regarding your interaction with various websites and applications, including the Services. To the extent we combine information we receive from those sources with Personal Information we collect on the Services, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties, even if they have used our technology to collect it and share it with us. Our Services may enable you to invite your friends to join in the fun. We enable users to invite friends in two ways:

      1. You may invite a friend to register on our Services by providing us with their email address. We will collect any email address you provide in order to facilitate the invitation. In this case, we rely upon you to obtain any consents from the third party that may be required by law to allow us to access and upload the third party's name and email address as required. If you are using one of our Applications to refer-a-friend, the Application may also collect your phone number, which we may use for fraud prevention, user authentication, and to provide our Services. You or the third party may contact us at to request the removal of this information from our database.

      2. We may enable you to send your friends an invite to register on our Services via text message. We employ various techniques to enable you to invite your friends via text message, including offering contact importer tools to facilitate adding your contacts, including contacts in your address book, so that you can readily ask your contacts to join and communicate with you through the Services. With your permission, we will access your address book, and import your contacts' names, email addresses, phone numbers, images, geolocation details and other information associated with your contacts to determine which of your friends have not registered an Account. The text message that is sent to your friends will come from your phone number so that your friends know that you want to invite them to visit the Website or Apps. During this process, we also collect your phone number (to send you a text message for account verification purposes), some information on your settings that help us interpret your data (such as language and keyboard settings that you set), and the identity of your phone's carrier, mobile network code, and mobile country code. Such information is collected in order to facilitate your and your friends' use of our Website, Apps, and Services.

    2. Our Services may also enable you to invite your friends who already have an Account to enter a Game. In order to invite friends with Accounts to join a Game, you may: (i) enter your friend's username associated with their account to find and locate them; or (ii) in the event you are using our Apps, use our contact importer tool to import and search through your contacts, including contacts in your address book, in order to match those of your friends who are also registered users of the Services. With your permission, we will access your address book, and import your contacts' names, email addresses, phone numbers, image, geographic location, and other information associated with your contact in order to facilitate connection with your friends.


  1. Interactions with Third-Party Services

    1. Certain products, services, or other materials displayed on the Website and Apps may integrate with, be integrated into, or be provided in connection with certain third-party services and content. We do not control those services and content and our Terms of Use and this notice do not apply to those services and content. You should read the terms of use agreements and privacy policies that apply to such services and content. TrueLuck, Inc. is not responsible for the practices used by any third-party websites or services linked to or from our Website or Apps, including, without limitation, the information or content contained within them. By using our Website, Apps, or Services, you acknowledge and agree that we are not responsible for and do not have control over any third-party services and content that you authorize to access information you provide to them. If you are using a third-party website or service and allow it to access your personal information, you do so at your own risk.

    2. The Service may include functionality that allows certain kinds of interactions between the Services and a third-party website or application. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, we may provide third-party sites’ interfaces or links on the Services to facilitate your sending a communication from the Services such as facilitating emails, tweets or Facebook postings. These third parties may share information with us and they may also retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party tools on our Services.


  1. Information You Provide About a Third Party

    1. You may send someone else a communication from the Services, such as sending an invitation to a friend. If so, the information you provide (names, email addresses, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Services, your contact information, name or username and message may be included in the communication sent to your addressee(s). Some of these tools may be third-party tools subject to third-party privacy policies.

    2. When you use the Website, Apps or Services, the personal and other information you choose to provide, including through our social networking features, will be shared with parties you allow to receive such information. For example, you may elect to communicate personal information to your friends and other Players, including those who are participating in the same Game as you. In addition, any information you post, upload, or disclose through your use of our social networking features may be available to other TrueLuck users and the general public. As provided above, by using the social privacy settings, you may control who may view your social networking Profile information, your Game participation activity you share through the social networking features, and the notifications you would like to receive through the social networking features.


  1. Do Not Track Disclosures

    1. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.


2. How do we use the information collected?
  1. We may use your Personal Information, Demographic Information or Usage Information that is subject to this Privacy Policy:

    1. to provide you with information such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties, including to let you know about new products, services or upcoming contests, promotions or events;

    2. to protect and administer your Services account;

    3. to process and track the results of your gambling and other transactions you enter into using the Services;

    4. to verify your identity, including your accounts on the Services;

    5. manage risk, or to detect, prevent, and/or remediate fraud or other potentially prohibited or illegal activities;

    6. manage and protect our information technology infrastructure;

    7. to provide the Services, including the gaming opportunities available on the Services;

    8. to improve the Services, marketing endeavors or our offerings;

    9. to provide to Co-Branded Partners (companies with whom we may jointly offer a service or feature) to register for a service offered by a CoBranded Partner;

    10. to provide information to Social Networking Services (e.g., Facebook) (each, a "SNS") to enable you to post content to such SNSs in accordance with your elections;

    11. to share some or all of your personal information with our corporate affiliates, including, without limitation, our subsidiaries, joint ventures and other companies under a common control ("Affiliates"), in which case we will require our Affiliates to respect this notice;

    12. to customize your experience on the Services or to serve you specific content or ads that are relevant to you, including using your location information to display advertisements for businesses in your close vicinity;

    13. to provide customer support, including to resolve disputes, collect fees and troubleshoot problems;

    14. to contact you with regard to your use of the Services and, in our discretion, changes to the Services and/or Services’ policies;

    15. to identify your product and Services preferences so that you can be informed of new or additional products, services and promotions;

    16. to enable you to participate in a variety of the Services’ features;

    17. to improve the overall experience at the Services;

    18. to comply with our legal and regulatory obligations;

    19. for internal business purposes;

    20. for obtaining advice or other professional services from professional advisers, including lawyers, auditors, bankers, insurers and consultants; such advisers are bound by legal and/or contractual duties of confidentiality and other prohibitions against disclosure of personal information; and

    21. for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

  2. Other disclosures:

Regardless of the choices you make regarding your personal information, TrueLuck, Inc. may disclose personal information if it in good faith believes that such disclosure is necessary (i) to comply with relevant laws (e.g., gaming regulations) or to respond to discovery requests, subpoenas, or warrants served on TrueLuck; (ii) in connection with any legal investigation; (iii) to protect or defend the rights or property of TrueLuck or users of the Website, Apps, or Services; (iv) to investigate or assist in preventing any violation or potential violation of law, this notice, or our Terms of Use; or (v) if we believe that an emergency involving the danger of death or serious injury to any person requires or justifies disclosure of information.

3. How and When do we share information with Third Parties?
  1. We may share non-Personal Information, including Usage Information, such as aggregated user statistics, with third parties. Further, we may share your Device Identifiers with third parties along with data related to you and your activities. Also, we may share your Personal Information with third parties with whom we have marketing or other relationships for the third parties’ direct marketing purposes. Additionally, in our continuous effort to provide services that we believe you may find useful or of value, we may make your Personal Information available to third parties better facilitate your requests, provide more personalized services and communicate separately with you. ??? does not sell customer information to advertisers or third party marketers. In addition, we may share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. ??? may additionally disclose your information as follows:

    1. When You Request Information From or Provide Information to Third Parties
      you may be presented with an option on our Services to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools, apps or ads on our Service or link to them from our Service. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by interacting with your consent to such third party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

    2. Third Parties Providing Services on our Behalf
      We may use third-party vendors to perform certain services on behalf of us or the Services, such as: (i) to assist us in Services operations; (ii) to manage a database of customer information; (iii) hosting the Services; (iv) designing and/or operating the Services’ features; (v) tracking the Services’ activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; (vii) to process payments and deliver prizes; and (viii) other services designed to assist us in maximizing our business potential.  Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Personal Information, about you. We are not responsible for those third party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.

    3. To Protect the Rights of ??? and Others
      We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Services’ Terms of Use or other policies applicable to the Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Further, we may use IP address or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion, subject to applicable law. Such disclosures may be carried out without notice to you. In circumstances where we inadvertently obtain information that appears to pertain to the commission of a crime or where we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person exists, ??? may voluntarily disclose the record or the contents of your communications or other information about you to law enforcement agencies and governmental entities without providing you advance notice. Upon receipt of an applicable search warrant or administrative, grand jury or trial subpoena, ??? may be required to disclose to the government or law enforcement agencies, without advance notice to you, the content of your communications and other records relating to your electronic communications, as well as the following records: your name and address; records of your online communication (including session times and duration); how long you have subscribed to our service(s) (including start date) and the type(s) of service(s) utilized; your telephone number or other subscriber account identifying number(s), including any Internet or network address(es) assigned to you by our network; and the means and source of your payment(s) (including any credit card or bank account number).

    4. Affiliates and Business Transfer
      We may share your information, including your Device Identifiers and Personal Information, Demographic Information and Usage Information with our parent, subsidiaries and affiliates, including for their marketing or other purposes. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

4. What about information I disclose publicly or others?
  1. User Content and Public Information
    The Services may permit you to submit ideas, photographs, video, audio recordings, computer graphics, pictures, data, information about your location, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”). We or others may store, display, reproduce, publish, distribute or otherwise use User Content online or offline in any media or format (currently existing or hereafter developed) and may or may not attribute it to you. Others may have access to this User Content and may have the ability to share it with third parties. Please think carefully before deciding what information you share, including Personal Information, in connection with your User Content. Please note that ??? does not control who will have access to the information that you choose to make public, and cannot ensure that parties who have access to such publicly available information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the Services or what others do with information you share with them on the Services. We are not responsible for the accuracy, use or misuse of any User Content that you disclose or receive from third parties through the Services.

  2. Name and Likeness
    We may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities. For full terms and conditions regarding User Content you submit to the Services, please review our Services’ Terms of Use.


5. Ads and Information About You
  1. We and third parties such as network advertisers and ad exchanges may serve advertisements on the Services or across the Internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party sites and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which may be based on your activities across the Internet and mobile media (“ Behavioral Ads”). Behavioral Ads enable us to target advertisements to you for products and services in which we believe you might be interested. If you object to receiving Behavioral Ads from us on third party sites, you can learn more about your ability to limit Behavioral Ads below.

  2. Our third party ad network and exchange providers, the advertisers and/or traffic measurement services may themselves set and access their own Tracking Technologies on your Device and track certain behavioral Usage Information via a Device Identifier. These third party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements; and (c) understand the usefulness of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities.

  3. Third-party Tracking Technologies are not controlled by us, even if they use our technology to help store or collect data. Statements regarding our practices do not apply to the methods for collecting information used by these third parties or the use of the information that such third parties collect. We do however work with third parties to make efforts to have you provided with information on their practices and any available opportunity to exercise choice. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.

  4. We may use third-party advertising companies to target advertisements to you on our Services, across the web, on your mobile Device and on any of your other Devices, based on the information we have collected from and about you, as well as information relating to your and other users’ visits to this and other websites and online services. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags) or recognize an identifier associated with your mobile device. These companies may also use these Tracking Technologies, along with personal information they or we collect on the different devices you use, to recognize you across the Devices you use, such as a mobile device and a laptop or other computer. Some third parties may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available here. Further, while sites use a variety of companies to serve advertisements, you may wish to visit , which provides information regarding this practice by Network Advertising Initiative (“NAI”) members, and your choices regarding having this information used by these companies, including the “opt-out” procedures of NAI members. Opting out of one or more NAI members only means that those NAI members no longer will be allowed under their own rules to deliver Behavioral Ads to you, but does not mean you will no longer receive any targeted content and/or ads. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different Device or change web browsers, your NAI opt-out may not, or may no longer, be effective. You may also opt-out of receiving Behavioral Ads on participating sites and services by visiting the Digital Advertising Alliance (“DAA”) website at . You may download the AppChoices app at to opt out in mobile apps. Similar limitations may apply to the DAA opt-out. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options or programs.


6. Does Third-Party Content, Links to Third-Party Sites and/or Third-Party Apps Appear on the Services?

When you are on the Services you may be directed to other sites and apps that are operated and controlled by third parties that we do not control such as merchants who directly sell products and services to you. We are not responsible for the data collection and privacy practices employed by any of these third parties or their sites or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the Services onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third-party owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party online service or otherwise interacting with it and exercise caution in connection with these services. We also encourage you to note when you leave our Services and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.


7. How Do I Change My Information and Communications Preferences?


  1. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. The Services may allow you to review, correct or update Personal Information you have provided through the Services’ registration forms or otherwise by updating your account, and you may provide registration updates and changes by contacting us by email at: support@???.com. If so, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records). Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Services, information that you remove may persist internally for ???’s administrative purposes. You may cancel or modify our email marketing communications you receive from us by following the instructions contained within our promotional emails. This will not affect subsequent subscriptions and if your opt-out is limited to certain types of emails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Services, such as administrative and Service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications.  If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: ????; Email: support@???.com .

  2. We will periodically send you free newsletters and emails that contain information about our various products and Services, or other products and services we feel may be of interest to you. At any time you can easily indicate your preference to stop receiving such communications from us, and you may opt out of receiving further marketing from TrueLuck, Inc. by emailing us at or by following the unsubscribe instructions provided in the email you receive. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our Terms of Use and this privacy notice.

  3. You may request a copy of personal information that TrueLuck, Inc. has collected about you through the Services by emailing our privacy team via email addressed to or through the "Contact Us" web form located at . You may also request that TrueLuck, Inc. correct any factual inaccuracies in your personal information by contacting

8. Your choices regarding Personal Information


  1. Tax Information. You consent to receive your TrueLuck-related tax information electronically, which information will be securely hosted by TrueLuck and accessible by you through your player account page for at least seven (7) years following the year to which the information relates. Your electronic tax information will be furnished on a downloadable PDF file, which you should be able to access and print using a standard PDF reader. You may contact TrueLuck at, if you cannot access your electronic tax information or if you wish to request a paper copy of your tax information. If you wish to revoke your consent to receiving your tax information electronically, you may contact us at to arrange for all of your post-revocation tax information to be provided to you in paper form. In order to update your recipient information, please use the instructions for changing your personal information set forth below.

  2. Changing or Deleting Your Personal Information. You may change any of your personal information in your Account by simply editing it within your Account or by requesting changes by emailing us at You may request deletion of certain personal information maintained by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be legally or otherwise required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). Deletion requests may be made by emailing us at or by submitting a privacy request through the "Contact Us" web form located at . When we delete information, it will be deleted from the active database, but may remain in our archives. We may also retain your information to prevent fraud or other unlawful activity or for similar purposes.

  3. Applications. You may stop all collection of information by our Apps by uninstalling the Apps. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.


9. What About Data Retention?

??? is committed to only retaining Personal Information for a period of time that is necessary to fulfill a legitimate business purpose and deleting or de-identifying the Personal Information thereafter. The legitimate business purposes for which we retain Personal Information are described in Section 2 above and throughout this Privacy Policy but may additionally include, without limitation: to provide, develop and improve the products and the services we make available through the Services, to maintain the security, integrity and operation of the Services, to comply with our legal and regulatory obligations and other third party requirements, to resolve disputes, and to enforce our agreements, to prevent fraud or criminal activity, to maintain business records and for other purposes we determine in our sole discretion. We destroy or de-identify Personal Information that is no longer necessary for the legitimate business purpose for which it was originally collected unless there is a legitimate request or order to inspect the information still outstanding or the information remains in routine records that are periodically discarded under our document retention policies. The Personal Information that you have provided us is maintained in our management information system and billing systems, and is updated as new information is added. Accounting and billing records are retained for ten (10) years for tax and accounting purposes or until the relevant income tax years for which the document was created have been closed for income tax purposes and/or all appeals have been exhausted. Records may remain on file even after you have terminated your account on our Services. Subject to applicable law, we may also keep records to facilitate collection and to evaluate credit worthiness.


10. What Should Parents Know About Children?

We understand the importance of protecting children’s privacy in the interactive world. We are a general audience service and do not use the Services to knowingly collect personal information from children under the age of thirteen (13) that requires parental notice and consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. If you are under twenty-one (21) years of age, you are not permitted to use the Service and should not send any information about yourself to us through the Service.  In the event that we become aware that we have collected personal information from anyone under the age of twenty-one (21), we will dispose of that information in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information without COPPA-required consent, please contact us at: support@???.com.


11. What about Security?


We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Service and provide us with your information at your own risk. We utilize the industry standard, Secure Socket Layer (SSL)-capable web browsers support encryption technology that helps prevent unauthorized users from viewing or manipulating your Personal Information as it travels over the Internet.


12. State-specific Privacy Rights (California, Nevada)


  1. Privacy Information for California Residents

    1. Shine the Light Disclosures.
      If you reside in California, you may request certain general information regarding our disclosure of personal information during the preceding year to third parties for their direct marketing purposes. To make such a request, please write to us at the following address: ????.

    2. California Consumer Privacy Act.
      If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).
      Categories of personal information we collect. Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we may collect are: identifiers (such as name, address, email address, driver’s license); commercial information (such as deposit or wagering data); financial data (such as payment information); internet or other network or device activity (such as browsing history or Services usage); geolocation information (e.g., your city and state based on IP address); audio information (e.g., if you participate in a customer support call and do not opt out of call recording); inference data about you; in certain circumstances, information used to manage potential fraud or legal risk (such as employment status and criminal history); photos (e.g., if you voluntarily submit a photo); and other information that identifies or can be reasonably associated with you.
      How we use and disclose these categories of personal information. We use and disclose the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Policy, and how you engage with the Service. Please see the relevant section(s) above for more information.

    3. Your California Privacy Rights
      CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request:

      1. Information about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in this Privacy Policy.

      2. Provide access to and/or a copy of certain information we hold about you.

      3. Delete certain information we have about you.

      4. Provide you with information about the financial incentives that we offer to you, if any.

    4. The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.
      We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information or to comply with a legal obligation. We will let you know where this is the case or if certain rights don’t apply in your country or state of residence. We also will take reasonable steps to verify your identity before responding to a request, which might include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and date of birth. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such a request or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.  Additionally, exercising your deletion right may mean that you may no longer be able to use the Service.  If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at 1-???-???-???? or here.

    5. Notice of Right to Opt Out of Sale of Personal Information
      California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that includes when we share your information with third parties to provide you with offers and promotions that we believe may be of interest to you. It also may include allowing third parties to receive certain information, such as cookies IP address and/or browsing behavior, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.
      Depending on what Services you use, we may provide the following categories of information to third parties for these purposes:

      1. For online targeted advertising purposes: demographic and statistical information, device information and identifiers, connection and usage data, geolocation, and social media information.

      2. For sharing with third parties to send you relevant offers and promotions: contact and account registration information; demographic and statistical information, and geolocation.

    6. If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, you may do so as outlined on the following page: Do Not Sell My Personal Information . You can also submit a sale opt-out request by emailing us at support@????.com. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

  2. Privacy Information for Nevada Residents
    Under Nevada law, certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.  We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting support@s???.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.


13. What about changes to the Privacy Policy?


  1. Our right to make changes

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.  

  1. Our responsibility to notify you of changes

In the event we make material changes to this privacy notice, as determined by us in our sole discretion, we will notify you. You are solely responsible for updating your personal information to provide us with your most current email address. In the event the last email address you provided is not valid or for any reason is not capable of delivering notifications to you, then in the event we provide you notification via email, our dispatch of the email containing such notification will constitute effective notification of the changes made to the privacy notice.  In the event you do not wish to permit changes in our use of your personal information, you must notify us that you wish to deactivate your Account. Your continued use of the Website, Apps, or Services following any changes to this privacy notice will indicate your acknowledgement of and consent to such changes and to be bound by the terms of such changes, with the understanding that the updated privacy notice applies to all of your personal information, including the personal information collected before the changes went into effect.

  1. International Users

The Website and Apps are hosted in the United States and are intended for and directed to users in the United States and Canada. If you are a user accessing the Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Website, Apps or Services, which are governed by U.S. law, this notice and our Terms of Use, you are transferring your personal information to the United States and you consent to that transfer. The Website and Apps are not intended to subject us to the laws or jurisdiction of any state, country or territory other than those of the United States. Your information may be stored and processed in any country where we have facilities or in which we engage service providers and, by using the Website, Apps or Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

14. Your Rights and Responsibilities


It is extremely important that you keep your account information and other confidential account data protected and secure. Do not share your log-in information or leave your computer unattended when logged in to the Services. Please make sure that all information you provide to ??? is accurate and complete. Contact us immediately by email at support@???.com if you find any discrepancies in your account data or if you wish to inspect the records pertaining to you at our offices.


The following third parties that collect information from you on the Service have given us notice that you may obtain information on their policies and practices, and in some instances opt-out of certain of their activities, as follows:



For More Information

Use of Tracking Technologies

Privacy Choices

Google Analytics















Google Dynamic Remarketing



Adobe Media Optimizer


















Demand Media



PLEASE NOTE: We are not responsible for third-party policies or practices. We try to keep this information current, and will add to and subtract from the chart above as appropriate, but it is provided as a courtesy and may not be current or accurate. Please contact the relevant third parties regarding their privacy and data security policies and practices.

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