Privacy Policy
This Privacy Policy explains how Petaleads Ltd (“LuckAndSpin”, “we”, “us” or “our”) collects, uses, shares and protects your personal information when you visit luckandspin.com or use our games, apps and related services (together, the “Platform”). LuckAndSpin is a free-to-play social gaming and sweepstakes platform. We do not offer real-money gambling. By using the Platform, you agree to the practices described in this Policy.
1. Who we are
The controller responsible for your personal information is Petaleads Ltd. If you have any questions about this Policy or how we handle your data, contact us at privacy@luckandspin.com. We have not appointed a Data Protection Officer or EU/UK representative; please direct any privacy queries to privacy@luckandspin.com.
2. Information we collect
Information you give us. When you create an account or use the Platform you may provide: your username, email address, date of birth, and password; profile details you choose to add; messages you send to customer support; and, if you redeem a sweepstakes prize, the information we need to verify eligibility and deliver the prize (for example your name, postal address and, where legally required, identity or tax information).
Information we collect automatically. When you use the Platform we automatically collect: device and browser type, operating system and settings, device identifiers, IP address and approximate location derived from it; gameplay activity, in-game events, virtual currency balances and transactions; and usage data such as pages viewed, features used, time spent and referring links. Some of this is collected through cookies and similar technologies (see Section 6).
Information from third parties. If you register or sign in using a third-party account (for example Facebook, Google or Apple), we receive basic profile information in line with that provider’s settings. We also receive information from analytics providers, advertising partners, and the payment processors and app stores that handle purchases of virtual items.
3. How we use your information
- To operate, maintain and provide the games and features of the Platform.
- To create and administer your account and verify that you meet our age and eligibility requirements.
- To process purchases of virtual currency and to run sweepstakes promotions and fulfil prizes.
- To personalise content, offers and gameplay, and to remember your preferences.
- To provide customer support and respond to your requests.
- To detect, prevent and investigate fraud, cheating, abuse and security incidents.
- To send you service messages and, where you have not opted out or where you have consented, marketing communications.
- To analyse and improve the Platform, and to comply with our legal and regulatory obligations.
4. Legal bases for processing (EEA/UK users)
Where the GDPR or UK GDPR applies, we process your personal information on the following legal bases: performance of our contract with you (to provide the Platform and your account); our legitimate interests (to secure, improve and market the Platform in ways that do not override your rights); your consent (for certain marketing and non-essential cookies, which you can withdraw at any time); and compliance with a legal obligation (for example record-keeping, tax and anti-fraud requirements).
5. How we share your information
We share personal information with: service providers and processors who host our infrastructure and provide analytics, customer support, payment processing and prize fulfilment on our behalf; social login and advertising partners, where you have enabled those features; and other companies in our group. We may also disclose information where required by law, regulation or legal process, to enforce our terms, or to protect the rights, property or safety of our users, the public or LuckAndSpin. If we are involved in a merger, acquisition or sale of assets, information may be transferred as part of that transaction.
We do not sell your personal information for money. Depending on your region, some data sharing for analytics or advertising may be treated as a “sale” or “sharing” under local law (for example under California law); where that is the case you can opt out as described in Section 10.
6. Cookies and similar technologies
We and our partners use cookies, SDKs, pixels and similar technologies to keep you signed in, remember preferences, measure and analyse usage, secure the Platform and (where permitted) deliver relevant advertising. You can control cookies through your browser or device settings and, where required, through the consent banner presented when you first visit the Platform. Disabling some cookies may affect how the Platform works. For more detail see our Cookie Policy.
7. International data transfers
We may process and store information in countries other than the one in which you live, including outside the EEA or UK. Where we transfer personal data internationally, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses (and the UK Addendum) or an adequacy decision. You may request a copy of the relevant safeguards by contacting privacy@luckandspin.com.
8. Data retention
We keep your personal information for as long as your account is active and for as long as we need it for the purposes described in this Policy — including to comply with our legal, tax, accounting, dispute-resolution and fraud-prevention obligations. When we no longer need it, we delete or anonymise it.
9. How we protect your information
We use technical and organisational measures — such as encryption in transit, access controls and monitoring — designed to protect your information against loss, misuse and unauthorised access. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Keep your password confidential and let us know immediately if you believe your account has been compromised.
10. Your privacy rights
Depending on where you live, you may have the right to access the personal information we hold about you; to correct or update it; to request deletion; to restrict or object to certain processing; to receive a copy in a portable format; and to withdraw consent at any time. California residents may request disclosure of the categories and specific pieces of personal information collected, request deletion, and opt out of “sale” or “sharing”, without being discriminated against for exercising these rights. To exercise any right, email privacy@luckandspin.com. We will respond within the time required by applicable law and may need to verify your identity first. You also have the right to lodge a complaint with your local data protection authority.
11. Children’s privacy
The Platform is intended strictly for adults aged 18 or over (or the higher age of majority in your jurisdiction). We do not knowingly collect personal information from anyone under 18. If we become aware that we have collected information from a person under 18, we will delete it promptly. If you believe a minor has provided us with personal information, please contact privacy@luckandspin.com.
12. Third-party links and services
The Platform may contain links to third-party websites, apps and services that we do not control. This Policy does not apply to them, and we are not responsible for their content or privacy practices. Please review the privacy policies of any third party before providing your information.
13. Your marketing choices
You can opt out of marketing emails at any time using the unsubscribe link in each message or by adjusting your account settings. You may still receive non-promotional service messages relating to your account and use of the Platform.
14. Changes to this Policy
We may update this Policy from time to time. When we do, we will revise the “Last updated” date above and, where changes are material, provide additional notice (for example, in-app or by email). Your continued use of the Platform after an update means you accept the revised Policy.
15. Contact us
Questions, requests or complaints about privacy can be sent to privacy@luckandspin.com.