Privacy Policy

1. Who we are

Brave Technology Co., Limited (香港勇敢者信息科技有限公司), a company registered in Hong Kong with registration number 76815857 (“Brave Technology”, “we”, “our” or “us”), operates Lucky Casino, including the website at www.luckycasinocenter.com, the Lucky Casino: Spin and Win mobile app and related services (together, the “Services”). We are responsible for the personal information described in this Privacy Policy. Our registered address is Room B3, 19/F, Tung Lee Commercial Building, 91–97 Jervois Street, Sheung Wan, Hong Kong.

2. Information we collect

2.1Information you give us.

• Account and contact information: your name, email address, phone number and login credentials.
• Identity and age verification information: your date of birth, residential address, images and details of your government-issued ID (such as the ID number and expiry date), and a selfie taken with your device camera for liveness and face-matching checks.
• Prize and tax information: the bank account or payment details you use to receive prizes, your Social Security number, and other information needed for tax reporting.
• Enhanced review information: where required for fraud or financial crime checks, information such as your occupation and source of funds, and supporting documents such as proof of address.
• Mail-in requests: the information you write on a mail-in request card under the Official Sweeps Rules.
• Communications: messages you send us, survey responses and customer support records.
• Responsible gaming settings: limits, breaks and self-exclusion requests.

2.2Information we collect automatically.

• Location information: precise location from your device, when you allow location access, and approximate location from your IP address. We use it to confirm that you are in a permitted location.
• Device and network information: device identifiers, IP address, browser and operating system type, app version, and signals that show the use of a VPN, proxy or location-spoofing tool.
• Gameplay and usage information: games played, coin balances and transactions, log-in times and the features you use.
• Purchase information: your Gold Coin purchase history, transaction identifiers and amounts, and refund and chargeback history. Card payments are processed by our payment providers, and purchases made through an app store are processed by that app store. We receive limited payment details, such as transaction identifiers and the last four digits of your card, rather than your full card number.
• Cookies and similar technologies: see Section 6.

2.3Information from third parties. We receive information from identity verification, age verification and geolocation providers (such as Vesant.ai); payment processors, banks and app stores; fraud prevention and sanctions screening providers; and advertising and analytics partners.

3. How we use information

We use personal information to:

• create and manage your account and provide the Services, including Gold Coin play and the Sweepstakes;
• verify your age, identity, residence and location, and determine whether you are eligible to take part in the Sweepstakes;
• process purchases and prize redemptions, including paying prizes and meeting tax reporting obligations;
• prevent, detect and investigate fraud, multiple accounts, money laundering, terrorist financing, sanctions violations and other misuse, and meet our anti-money laundering and sanctions obligations;
• support responsible play, including applying limits, breaks and self-exclusion;
• provide customer support and send you service messages, such as verification and redemption updates;
• send you promotional messages where permitted (you can opt out at any time);
• show advertisements, including rewarded ads, and measure their performance, as described in Section 6;
• analyze, maintain, improve and secure the Services; and
• comply with legal obligations, respond to lawful requests, enforce our Terms of Service and the Official Sweeps Rules, and establish or defend legal claims.

4. Biometric data

4.1To verify your identity, we and our identity verification provider, Vesant.ai, compare a selfie you take with the photo on your government-issued ID and check that the selfie comes from a live person. This process creates facial geometry data (“Biometric Data”).

4.2We use Biometric Data only to verify your identity and age, to confirm that you are a real person, to prevent fraud and duplicate accounts, and to re-verify your identity when you request a prize redemption.

4.3We collect Biometric Data only after you give your consent in the app. If you do not consent, you cannot complete identity verification.

4.4We do not sell, lease or trade Biometric Data or otherwise profit from it. We disclose it only to Vesant.ai and other providers that help us verify identity, or where required by law or by a valid warrant or subpoena.

4.5We and our providers permanently destroy Biometric Data when the purposes in Section 4.2 have been satisfied, for example when your account is closed, and in any event within one year after your last interaction with us, unless a valid warrant or subpoena requires us to keep it longer. Images of your ID document and the results of your verification are kept as described in Section 7.

4.6We protect Biometric Data with at least the same standard of care that we use for our other confidential and sensitive information.

5. How we share information

We do not sell your personal information for money. We share personal information only as follows:

• Service providers that act on our behalf, such as hosting and IT, identity and age verification and geolocation (including Vesant.ai), payment processing, customer support, communications, analytics and security providers. They may use personal information only to provide services to us.
• Payment partners, such as payment processors, acquiring banks and card networks, to process purchases and prize payments, handle disputes and chargebacks, and prevent fraud and financial crime.
• App stores, such as Apple, when you download the app or make purchases through them.
• Advertising partners, as described in Section 6.
• Legal, regulatory and safety recipients, such as law enforcement, regulators, courts and tax authorities, when we believe disclosure is required by law or legal process, or is necessary to prevent fraud or financial crime or to protect the rights, property or safety of our users, us or others.
• Professional advisers, such as lawyers, auditors and compliance testers, who are bound by confidentiality obligations.
• Business transfers, in connection with a merger, acquisition, financing or sale of all or part of our business.
• Prize publicity: if you win a prize, we may publish your name and prize information as described in the Official Sweeps Rules, except where prohibited by law.
• Others with your consent or at your direction.

6. Advertising, cookies and tracking

6.1We and our partners use cookies, pixels, software development kits (SDKs) and similar technologies to operate the Services, remember your preferences, measure performance and, where permitted, show advertisements. Some advertising partners may collect information about your activity on the Services and on other websites and apps over time. Some state laws treat this as a “sale” or “sharing” of personal information, or as “targeted advertising”.

6.2If you choose to watch an advertisement to spin the daily bonus wheel, the advertisement is served by a third-party advertising platform, which may collect device and usage information under its own privacy policy.

6.3On iOS, we ask for your permission through Apple’s App Tracking Transparency framework before tracking your activity across other companies’ apps and websites. You can change your choice at any time in your device settings.

6.4You can control cookies through your browser settings and advertising identifiers through your device settings. You can also opt out of targeted advertising by emailing business@brave-technology.com with “Opt out of targeted advertising” in the subject line. Where required by law, we treat a Global Privacy Control signal from your browser as a request to opt out of targeted advertising and the sale or sharing of your personal information. Our Services do not respond to Do Not Track signals.

7. How long we keep information

We keep personal information only for as long as we need it for the purposes described in this Privacy Policy, including to meet legal, tax, accounting and regulatory requirements. In particular:

• identity verification, account, transaction and redemption records are kept for at least five years after the relevant transaction or the end of our relationship with you, whichever is later;
• sanctions screening records are kept for at least ten years;
• Biometric Data is kept and destroyed as described in Section 4.5; and
• other information, such as marketing preferences and support records, is kept for as long as it is needed for the purpose for which it was collected.

When we no longer need personal information, we delete it or de-identify it.

8. Your choices and privacy rights

8.1Account information. You can review and update some of your account information in your account settings or by contacting us.

8.2Marketing. You can opt out of promotional emails by using the unsubscribe link in any such email or by contacting us. We will still send you service messages about your account, verification and redemptions.

8.3Location. You can turn off location access in your device settings, but the Services, including the Sweepstakes, are not available if we cannot confirm your location.

8.4Deleting your account. You can request deletion of your account from within the app or by emailing us. We will then delete or de-identify your personal information, except information we must keep to comply with legal obligations (such as anti-money laundering and tax record-keeping), to resolve disputes, to prevent fraud or to enforce our agreements.

8.5State privacy rights. Depending on the state where you live, you may have the right to confirm whether we process your personal information and to access it; to correct inaccurate information; to delete personal information; to obtain a portable copy of it; to opt out of targeted advertising, the sale of personal information and certain profiling; and to limit or withdraw consent to the use of sensitive personal information. We will not discriminate against you for exercising these rights.

8.6How to make a request. Email business@brave-technology.com with “Privacy Request” in the subject line. We will verify your identity before acting on your request, which may involve asking for information that matches our records. You may use an authorized agent, who must provide proof of their authority. We will respond within the time required by law. If we decline your request, you may appeal by replying with “Appeal” in the subject line; if your appeal is denied, you may contact the attorney general of your state.

8.7California residents. California Civil Code Section 1798.83 allows California residents to request, once per calendar year, information about our disclosure of personal information to third parties for their own direct marketing purposes. To make a request, email business@brave-technology.com with “California Privacy Rights” in the subject line.

9. Security

We use technical and organizational measures designed to protect personal information, including encryption, access controls and audit logging. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. Please keep your login details confidential and contact us straight away if you think your account has been compromised.

10. International transfers

We are based in Hong Kong. We and our service providers may process personal information in Hong Kong, the United States and other countries whose data protection laws may differ from those where you live. We take steps to protect personal information wherever it is processed.

11. Children

The Services are only for adults aged 18 or older (19 in Alabama and Nebraska). We do not knowingly collect personal information from anyone under 18. If we learn that we have done so, we will close the account and delete the information, except where we must keep it by law. If you believe that a minor has given us personal information, please contact us.

12. Third-party links and services

The Services may contain advertisements and links to websites and services run by third parties. We do not control those websites and services and are not responsible for their content or privacy practices, which are governed by their own privacy policies.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The updated policy will be posted on the Services with a new “last updated” date. If we make material changes, we will notify you by email or by a prominent notice on the Services. Your continued use of the Services after the changes take effect means you accept the updated policy.

14. Contact us

If you have any questions about this Privacy Policy or our handling of your personal information, please contact us at business@brave-technology.com or write to:

Brave Technology Co., Limited
Room B3, 19/F, Tung Lee Commercial Building
91–97 Jervois Street, Sheung Wan, Hong Kong