PRIVACY POLICY

Effective Date: 2026-10-19

This Privacy Policy describes how Milky Way Entertainment LLC, a company incorporated under the laws of the State of Wyoming (“Company”, “we”, “us”, or “our”), collects, uses, discloses, and protects information in connection with your use of:

1. the website available at https://turbostakes.com/, including all associated domains and sub-domains,
2. any related mobile or web applications, and
3. any content, functionality, and services offered thereon (collectively, the “Website” or “Service”).

This Privacy Policy forms part of, and must be read together with, our Terms and Conditions, Sweeps Rules, Responsible Social Play Policy, and any other applicable policies and notices governing your use of the Website (collectively, the “Legal Documentation” or “Documentation”). Capitalized terms used but not defined in this Privacy Policy have the meaning given to them in the Legal Documentation. For users of Turbo Rips, the Legal Documentation also includes the Turbo Rips Terms of Service, and the Section of this Privacy Policy titled “Turbo Rips” applies.

By creating an Account, accessing, or otherwise using the Website, you acknowledge that you have read and understood this Privacy Policy and agree to the processing of your information as described herein. If you do not agree, you must not use the Website or the Service.

By accessing or using the Website and/or providing us with any personal information, you acknowledge and agree that you have read, understood, and consent to the practices described in this Privacy Policy. You further acknowledge and agree that your information will be collected, used, stored, and disclosed in accordance with this Privacy Policy and the laws of the United States.

To the fullest extent permitted under applicable law, you agree that your access to and use of the Website is governed exclusively by United States law. You understand and agree that any rights you may have under the data protection or privacy laws of any other jurisdiction may not apply to your use of the Website, and you expressly consent to the processing of your information in accordance with U.S. legal standards and this Privacy Policy.

If you do not agree with any provision of this Privacy Policy, you must immediately discontinue use of the Website and refrain from providing any personal information to us.

We may update or amend this Privacy Policy from time to time. You are encouraged to review this Privacy Policy periodically to remain informed about our privacy practices.

If you have any questions or requests in relation to this Privacy Policy, please contact us at [email protected].

1. DATA SECURITY

1. We are committed to safeguarding your personal information and maintaining the privacy and integrity of the data we collect. We implement commercially reasonable technical, physical, and administrative safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized access, disclosure, or misuse. These measures include, without limitation:

1. restricting physical access to servers and data storage environments;
2. implementing authentication controls, access-management protocols, and password protections;
3. using industry-standard security technologies, such as encryption and firewalls; and
4. conducting monitoring, logging, and other security processes intended to detect and mitigate potential threats.

1. Despite our efforts, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security. Any transmission of personal information to or through the Website is undertaken at your own risk. You understand and acknowledge that we are not responsible for interception, compromise, or unauthorized access to personal information that occurs due to causes beyond our reasonable control, including but not limited to:

1. your own actions or omissions;
2. failures or vulnerabilities in third-party systems, networks, or service providers;
3. corruption or failure of storage media;
4. power outages, natural disasters, or other force-majeure events;
5. acts of vandalism, hacking, malware, sabotage, or terrorism; or
6. unauthorized circumvention of any privacy settings or security measures employed by the Website.

1. You are solely responsible for maintaining the confidentiality and security of your Account credentials, including your username and password. You must not share, disclose, or otherwise make your login information available to any third party. If you believe that your Account has been accessed without authorization or that your interaction with us is no longer secure, you must notify us immediately using the contact information provided below.
2. In the event that we determine that the security of personal information in our possession or control may have been compromised, we may notify you as required by applicable law. Where notification is appropriate and permissible, we will endeavor to do so as promptly as reasonably practicable under the circumstances. If we have your email address, notification may be sent to you electronically.

1. INFORMATION WE COLLECT

1. Information We Collect from Users. We collect information about Users through a variety of methods, including information you provide directly and information collected automatically through your interaction with the Website and Services. This may include personal information and account-related information, such as:

1. Contact Information: Your email address, physical mailing address, mobile number, and any other telephone numbers you provide.
2. Identification Information: Your first name, last name, age, likeness, and any other identifiers necessary to establish or maintain your Account.
3. Account Credentials: Your username, password, profile images, and other authentication details associated with your Account.
4. Transactional and Verification Information: Mailing address, telephone number, payment information, and any additional information required for redemption, verification, or compliance purposes (including financial institution details, credit card information, bank account statements, or similar documentation).
5. Customer Support Communications: Information you provide through live chat, email, support tickets, or any other method of contacting our customer support team.
6. Third-Party Source Information: Data we receive from third parties, such as social media platforms (e.g., Facebook), advertising partners, or other service providers regarding your interaction with or connection to the Services.
7. Location Information: Geographic and location-related data derived from the device(s) used to access the Website, subject to your device settings and permissions.
8. Activity and Device Information: Data related to your interaction with the Services, including content viewed or used, session duration and frequency, referral information, device type, hardware model, unique device identifiers, operating system, browser type, IP address, and similar technical details.
9. Gameplay and Account Balance Information: Data related to your use of the Games and your Account balance, including the games played and the dates and times of play, amounts wagered, records of Gold Coins and Sweepstake Coins credited to or debited from your Account, deposit and withdrawal history, and Prize and winnings history, including in connection with resolving chargebacks, disputes, claims, reversals, returns, or inquiries.
10. Turbo Rips Information: if you use Turbo Rips, the additional information described in the Section titled “Turbo Rips”.

1. Other information. We may also collect non-directly identifying information or aggregated information that does not, on its own, identify you personally. This may include, without limitation:

1. general usage data and browsing patterns;
2. statistical or demographic information related to groups of Users; and
3. geographic indicators such as a device’s zip code or postal code.

Such information may be used for analytics, service improvement, reporting, or other lawful business purposes.

2. Accuracy of Information Provided

1. By submitting any information to or through the Website, you represent and warrant that all such information is true, accurate, complete, and current for the purposes for which it is provided. This includes, without limitation, maintaining the accuracy of your contact information, such as telephone numbers and email addresses.
2. You are solely responsible for ensuring that any information you provide is updated promptly as necessary to maintain its accuracy and completeness. We may rely on the information you provide unless and until you notify us of any changes.

1. By providing your telephone number(s) to us, you expressly consent to our use of such number(s) to contact you. Such communications may be made through pre-recorded or artificial voice messages, autodialed or automated calls, SMS or text messages, and emails, and may relate to:

1. matters concerning the Legal Documentation;
2. Account-related information, including purchases, redemptions, verifications, or security notices; and
3. promotional or marketing communications from us or on our behalf, to the extent you have provided any legally required opt-in consent for such messages.

We may rely on the contact information you provide unless and until you withdraw your consent or otherwise update your details.

2. Opting Out.
   You may opt out of receiving certain types of communications at any time by contacting us at [email protected] or by using the unsubscribe or opt-out mechanism included in the applicable message.

Please note that opting out of marketing or promotional communications will not affect our ability to send non-promotional messages relating to your Account, the Service, or important updates to the Legal Documentation.

3. We collect information about Users through multiple channels and interactions, including but not limited to when a User accesses or navigates the Service, creates or manages an Account, purchases or acquires virtual items, participates in Promotions or surveys (including those administered by third-party partners), or engages with any other feature, functionality, or service made available through the Website.
4. We may also collect information through various communication channels, including telephone calls, video calls, email correspondence, instant messaging, live chat, physical mail, SMS/text messages, and interactions on social media platforms.
   Telephone and video communications may be recorded for training, quality assurance, fraud prevention, and compliance purposes. By participating in such calls, you acknowledge and consent to the recording of the call, except where applicable law requires additional notice or consent procedures, in which case we will comply with those requirements.
5. We utilize a range of technologies on our Website and within our applications, including technologies embedded on third-party sites or platforms, to enhance functionality, analyze usage, personalize content, and support marketing activities. These technologies may include, without limitation:

1. Cookies: Small text files placed on your browser or device that uniquely distinguish your device, enable core functionality, remember your preferences, and help us understand how you interact with the Website.
2. Similar Identifying Technologies:
   Technologies such as marketing pixels, tags, mobile device identifiers, and event tagging, which assist in tracking interactions, attributing conversions, delivering targeted advertising, and monitoring performance. Mobile Device Identifiers may, where permitted by applicable law and your device settings, be shared with advertisers or analytics partners for marketing, attribution, or measurement purposes.
3. Analytical Tools:
   Third-party and proprietary analytics technologies used to collect information during your interactions with the Website or our applications on third-party platforms. These tools help us understand Website performance, user behavior, session patterns, and the effectiveness of content, campaigns, and features.

These technologies may operate independently or in combination and can collect data such as device type, browser information, IP address, pages viewed, session duration, referral sources, and interactions with Website elements.

2. UTILIZATION OF YOUR INFORMATION

1. We use the information we collect from and about you for the purposes set forth in this Privacy Policy and the Legal Documentation, including the Terms and Conditions, Sweeps Rules, and Responsible Social Play  Policy. Such information may be processed by us or by other companies within our corporate group acting as data processors or service providers, strictly in accordance with applicable law and our instructions.
2. Your information may be used for a variety of operational, administrative, legal, and commercial purposes, including but not limited to:

1. Provision and Operation of the Services:
   To create, maintain, and administer your Account; provide access to Gold Coin Games and Sweepstakes; process purchases, redemptions, and Prize claims; and deliver the functionalities, features, and content offered through the Website.
2. Verification, Eligibility, and Compliance:
   To verify your identity, age, residency, location, device integrity, and eligibility to participate in sweepstakes or Promotions; to conduct responsible gaming assessments; and to comply with the Sweeps Rules and other Legal Documentation.
3. Customer Support and Communications:
   To respond to inquiries, resolve disputes, provide assistance, and communicate about Account activity, security issues, updates, and changes to the Legal Documentation.
4. Security, Fraud Detection, and Risk Management:
   To safeguard the Website, detect and prevent fraud, unauthorized activity, bonus abuse, or violations of the Legal Documentation; and to maintain technical and organizational security measures.
5. Marketing, Analytics, and Personalization:
   To deliver promotional communications (subject to your consent where required), conduct surveys and market research, analyze user behavior, optimize Website performance, personalize your experience, and measure advertising and campaign effectiveness.
6. Internal Business Purposes:
   To support internal operations such as auditing, recordkeeping, data analysis, research, reporting, training, and service development.
7. Legal and Regulatory Compliance:
   To comply with applicable laws, law-enforcement requests, regulatory requirements, anti-money-laundering (AML) obligations, tax rules, and reporting duties, and to establish or defend legal claims.

3. REASONS FOR COLLECTION AND USE OF INFORMATION

1. We collect and use your information for a variety of operational, legal, and commercial purposes, each of which supports the functioning, integrity, and compliance of the Website and the Services. These purposes include, without limitation:

1. Identification, Eligibility, and Verification. To identify you as a User, confirm your age and identity, collect and verify your location, and determine whether you meet the eligibility requirements to access the Website, create an Account, participate in Sweepstakes, or redeem Prizes. This may include the use of geolocation data, government-issued identification, and other verification documentation.
2. Transactions and Payment Processing. To process transactions, including (without limitation) the purchase of Gold Coins, acquisition of promotional items, and submission of redemption or Prize requests.
   Information you provide may also be used to satisfy anti-money laundering (AML), fraud-prevention, sanctions-screening, and payment authentication obligations.
   We disclose payment-related information only to third-party processors to the extent necessary to facilitate such transactions or comply with legal and regulatory requirements. In connection with a chargeback, dispute, claim, reversal, return, or inquiry initiated by a financial institution, Payment Provider, card network, or payment intermediary, we may also disclose to such third party additional Account information reasonably necessary to investigate, document, or respond to that chargeback, dispute, claim, reversal, return, or inquiry, including records of Account funding and balance transactions (such as the dates and amounts of deposits, withdrawals, and other balance adjustments), wagering and gameplay activity (such as the games played and the dates and times of play), and Prize and winnings history (such as the dates and amounts of any Prizes or winnings credited to or debited from your Account).
3. Service Provision and Account Management. To establish, maintain, operate, and manage your Account; enable access to the Website and its features; conduct routine and enhanced security checks; prevent unauthorized activity; and address technical, operational, or customer service inquiries.
4. Customer Service and User Experience Enhancement. To improve your interaction with the Website and optimize customer support, including:

• responding to inquiries and support requests,
• tailoring content and service delivery to your preferences,
• monitoring and enhancing the overall quality, reliability, and user experience of the Website.

5. Compliance With Law and the Legal Documentation. To comply with obligations under applicable laws and regulations, including U.S. gaming, sweepstakes, consumer protection, privacy, and financial regulations.
   This includes enforcing our Terms and Conditions, Sweeps Rules, and other policies; investigating suspicious activity; and responding to lawful governmental, regulatory, or judicial requests.
6. Legitimate Business Interests. Where necessary for our legitimate business interests, or those of a third party, provided that such interests are not outweighed by your rights, freedoms, or reasonable expectations. These interests may include:

• operating, securing, and improving the Website and Services;
• conducting analytics, performance measurement, and internal reporting;
• developing new features, products, and marketing strategies; and
• maintaining fraud prevention, risk management, and IT infrastructure.

4. COMMUNICATION AND NOTICES

1. We may contact you using any contact details you have provided to us, including email, live chat, telephone, SMS/text message, push notification, physical mail, or via social media or in-Account messaging. Such communications may include, without limitation:

1. administration and management of Promotions, Sweepstakes, and competitions in which you choose to participate;
2. notifications regarding purchases, redemptions, Prize claims, and verification requests;
3. important notices concerning updates to the Legal Documentation, including this Privacy Policy, the Terms and Conditions, the Sweeps Rules, and any other applicable policies;
4. information necessary for security, fraud prevention, and Account integrity; and
5. marketing or promotional communications, to the extent you have provided any legally required consent and as further described in this Privacy Policy.

1. Certain categories of communications (for example, transactional emails, security alerts, and notices of material changes to the Legal Documentation) are considered service or legal notices and are not subject to marketing opt-out, as they are necessary for the proper administration of your Account and the Website.
2. Where required by applicable law, we will obtain your consent before sending specific types of promotional or marketing communications, and you may withdraw such consent at any time in accordance with this Privacy Policy.

5. COMPLIANCE AND LEGAL OBLIGATIONS

1. We use and may disclose the information we collect to comply with our legal, regulatory, and contractual obligations. This includes, without limitation:

1. complying with applicable sweepstakes, gaming, consumer protection, privacy, tax, and financial regulations;
2. performing know-your-customer (KYC), identity verification, age verification, and anti-money-laundering (AML) checks;
3. meeting record-keeping, reporting, and audit requirements;
4. enforcing, monitoring, and evidencing compliance with the Legal Documentation, including the Terms and Conditions and Sweeps Rules;
5. responding to lawful requests from courts, regulators, law-enforcement authorities, or other governmental bodies; and
6. establishing, exercising, or defending legal claims, including in connection with investigations of suspected fraud, abuse, or other prohibited conduct.

1. Any use or disclosure of information for these purposes will be made strictly in accordance with applicable law and, where required, subject to appropriate safeguards or legal process.

6. YOUR RIGHTS REGARDING INFORMATION

1. Subject to applicable law and any limitations set out therein, you may have certain rights in relation to the personal information we hold about you. These may include the right to:

1. Access: request confirmation as to whether we process your personal information and obtain a copy of such information;
2. Rectification: request correction or completion of inaccurate or incomplete personal information;
3. Erasure: request deletion of your personal information, where there is no overriding lawful basis for its continued processing;
4. Restriction: request that we restrict the processing of your personal information in certain circumstances (for example, while we verify its accuracy or our legal basis for processing);
5. Objection: object to certain processing activities, including processing based on our legitimate interests and, where applicable, direct marketing;
6. Withdrawal of consent: where processing is based on your consent, withdraw that consent at any time, without affecting the lawfulness of processing carried out prior to such withdrawal.

1. To exercise any of these rights (where available under applicable law), please contact us using the contact details provided in this Privacy Policy. We may need to verify your identity before responding to your request and may decline a request where we are legally permitted or required to do so (for example, where retention is necessary for compliance, dispute resolution, or fraud prevention).
2. Your exercise of these rights does not relieve you of any obligations under the Legal Documentation, and certain rights may be limited, unavailable, or subject to conditions depending on your jurisdiction and the nature of the information involved.

7. INFORMATION SECURITY MEASURES

1. Safeguarding your personal information is of fundamental importance to us. We implement physical, electronic, and organizational safeguards designed to protect your information from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These safeguards may include, without limitation:

1. access controls and authentication mechanisms, including password protections and role-based access;
2. the use of firewalls, intrusion detection, and other technical security measures;
3. secure data-storage practices and encryption where appropriate;
4. operational protocols and internal policies governing how information is accessed, used, and shared; and
5. periodic review and updating of our security measures to reflect industry practices and legal requirements.

1. Notwithstanding our efforts to maintain a secure environment, no system or method of data transmission or storage can be guaranteed to be 100% secure. Accordingly, we cannot and do not guarantee the absolute security of your information.
2. If you believe that your Account or any interaction with us is no longer secure (for example, if you suspect unauthorized access to your Account or your credentials), you must notify us immediately at [email protected].
3. Where we are legally required to do so, and where feasible under the circumstances, we will notify you of any breach of security that results in unauthorized access to your personal information, using the contact details we have on file and in accordance with applicable law.

8. INFORMATION RETENTION

1. We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, to meet our legitimate business needs, and to comply with applicable legal, regulatory, and contractual obligations. Retention periods may vary depending on the nature of the information and the purposes for which it was collected.
2. If your Account is closed, suspended, or terminated for any reason, we may continue to retain certain information for a period of time that is reasonably necessary to:

1. resolve disputes;
2. investigate or clarify past activity;
3. comply with statutory recordkeeping requirements;
4. enforce the Legal Documentation;
5. prevent fraud, abuse, or unlawful activity; and
6. meet our legal or regulatory obligations.

After the applicable retention period has expired, we will delete, anonymize, or otherwise render your information unusable in accordance with our internal policies and applicable law.

9. INFORMATION SHARING

1. Sharing With Group Companies and Authorized Service Providers
   We may share your information with our parent companies, subsidiaries, affiliates, and other entities within our corporate group, as well as with trusted third-party service providers that perform services on our behalf. Such services may include, without limitation:

1. processing payments and facilitating financial transactions;
2. conducting identity, age, fraud, and geolocation verification;
3. performing quality assurance and website performance testing;
4. personalizing and enhancing your experience on the Website;
5. sending email, SMS, push notifications, and other communications;
6. providing security monitoring, data storage, hosting, and technical maintenance;
7. preventing, detecting, or investigating potentially harmful, fraudulent, or unlawful activities; and
8. assisting in compliance with legal, regulatory, and reporting obligations.

1. We share only the minimum amount of information necessary to allow these service providers to perform their respective functions. All such parties are required to protect your information and may use it solely as instructed by us and in accordance with this Privacy Policy and applicable law.
2. Sharing of Aggregated or De-Identified Information
   We reserve the right to disclose aggregated, anonymized, or otherwise de-identified information to third parties for purposes including, but not limited to:

1. marketing and advertising analysis;
2. reporting and analytics for business partners;
3. demonstrating Website usage patterns or performance metrics;
4. improving our products, services, and user experience; and
5. supporting advertisers, advertising networks, and strategic partners.

Any information disclosed in this manner will not identify any individual User and will not include personal information.

10. THIRD PARTY SERVICES AND COLLECTION OF INFORMATION

1.  Third-Party Tracking Technologies and Data Collection. Certain third parties may provide content, advertising, analytics tools, or other materials on or through the Website. Such third parties may use cookies, pixels, web beacons, tags, APIs, mobile identifiers, and other tracking technologies to collect information about you, including information about:

1. your interactions with the Website and third-party content;
2. your browsing behavior over time;
3. your activity across different websites, applications, and online services;
4. device identifiers, IP address, geolocation data, and other technical information.

1. These third parties may use such information for various purposes, including delivering interest-based advertising, retargeting, behavioral analysis, market research, analytics, and other forms of targeted content.
2. We do not control third-party tracking technologies or how those third parties choose to use the information they collect. Their data collection and processing activities are governed exclusively by the terms, conditions, and privacy policies of those third parties, not by this Privacy Policy.
3. Your use of any third-party service, application, or feature integrated with or accessible through the Website is subject to the user terms and privacy policies of the third-party provider. This Privacy Policy does not apply to third-party websites, applications, or services, even if accessible through the Website.
4. Third-Party Payment Processing. When you initiate a payment or redemption-related transaction through the Website, the transaction may be processed by a third-party payment processor or other external service provider. In such cases, the third-party processor may collect certain payment or billing information directly from you, which may include:

1. your name;
2. email address;
3. physical address;
4. payment card details or financial institution information;
5. other billing, authentication, or verification information.

These third-party processors operate independently from us and may maintain, store, or process your payment information in accordance with their own privacy policies and legal obligations. We do not control, and are not responsible for, their data practices.

5. Third-Party Websites and External Links. If you choose to access, click on, use, or provide any personal information to a third-party website, application, or service (including through links, integrations, or embedded content), you acknowledge and agree that you do so at your sole risk. We do not operate, control, monitor, endorse, or assume responsibility for:

1. the content, policies, security, or practices of any third-party site;
2. the accuracy, availability, or reliability of third-party materials;
3. how any third party collects, uses, stores, or shares your information;
4. whether any third-party website functions without error or interruption; or
5. whether such websites or their servers are free of malware, viruses, exploits, or harmful components.

1. To the fullest extent permitted by law, we disclaim all liability arising from your use of or interaction with any third-party website, service, or provider.
2. We strongly encourage you to review the terms of use and privacy policies of any third-party website before providing personal information or engaging with that service.

11. ANNOUNCEMENT OF PRIZE WINNERS AND INFORMATION SHARING

1. We may use certain information about Prize winners for announcement, verification, promotional, and marketing purposes, as permitted under this Privacy Policy, the Sweeps Rules, the Terms and Conditions, and applicable law. Subject to any required consent and any statutory restrictions, we reserve the right to publicly disclose information relating to a Prize winner, which may include, without limitation:

1. the winner’s name (full or partial, as permitted by law);
2. the type and amount of Sweepstake Coins, Gold Coins, or Prize awarded;
3. the winner’s city, state, and country of residence;
4. the winner’s profile picture or avatar; and
5. any other personal information collected and used in accordance with this Privacy Policy.

1. Such information may be displayed or distributed across various channels, including but not limited to:

1. the Website and Services;
2. social media platforms;
3. affiliated or partner marketing channels;
4. email or push notification campaigns;
5. promotional materials; and
6. traditional media, including radio, television, print media, or other physical distribution channels.

1. Where required by applicable law or the Sweeps Rules, we may request your explicit consent to use your information for publicity purposes. In jurisdictions where winner disclosure is mandated (for example, for regulatory transparency), we may publish certain details irrespective of additional consent.
2. By participating in Sweepstakes or Promotions, you acknowledge and agree that your information may be used and disclosed in accordance with this section and the broader Legal Documentation. This Section 12 does not apply to Turbo Rips. Information about your Turbo Rips activity is displayed publicly only as described in the Section titled “Turbo Rips”

12. INFORMATION SHARING IN BUSINESS TRANSACTIONS

Your information may be shared in association with the sale, merger, acquisition, or similar transaction involving the company to a third party, or in the transfer of substantial company assets to a third party.

13. CHANGES TO THE PRIVACY POLICY

Updates to this Privacy Policy will occur periodically to reflect legal changes and adjustments to our policies. Users will be notified of any significant changes, and when required by law, consent will be obtained. Changes become effective upon posting the updated Privacy Policy on our Website. Users are responsible for staying updated on these changes posted on our Website (https://turbostakes.com/).

14. CONTACT INFORMATION

For inquiries, please reach out to our representative at [email protected].

15. INFORMATION FOR SPECIFIC GROUPS IN THE UNITED STATES

Our Services are available to individuals who have reached the age of majority in their respective jurisdictions. We will not knowingly collect or maintain information from minors. If you suspect that a minor has provided us with personal information and wishes for it to be deleted, contact us at [email protected]. Turbo Rips is available only to individuals who are at least 19 years of age and at least the age of majority in their state of residence, and all other Services are available only to individuals who are at least 21 years of age.

16. FOR NEVADA RESIDENTS

Nevada residents who have made purchases related to the Services may opt out of the "sale" of "Covered Information" under Nevada law. While we may share your information with third parties for offers and promotions, we do not believe this sharing constitutes a sale under Nevada law. Nevada residents can request to opt out by contacting the representative at [email protected]. Reasonable steps will be taken to verify your identity and the authenticity of your request.

17. OTHER U.S. STATE PRIVACY RIGHTS

Depending on your state of residence (including, where applicable, Texas, Virginia, Colorado, Oregon, Utah, Iowa, Nebraska, New Hampshire, Kentucky and Rhode Island), you may have the right, subject to applicable exceptions, to: (a) confirm whether we process your personal information and access it; (b) correct inaccuracies in your personal information; (c) delete personal information you provided or that we obtained about you; (d) obtain a copy of your personal information in a portable and, where technically feasible, readily usable format; and (e) opt out of the processing of your personal information for targeted advertising, the sale of your personal information, or profiling in furtherance of decisions that produce legal or similarly significant effects.

Sensitive data. We process sensitive data, such as biometric data and precise geolocation, only with your consent where required by applicable law, and only for the purposes described in this Privacy Policy, including identity verification, fraud prevention and legal compliance. You may withdraw your consent at any time, although this may prevent us from providing certain Services, such as Turbo Rips withdrawals or shipments.

Automated processing. We use automated tools, including those provided by our identity verification, geolocation and fraud-prevention providers, to verify your identity, age and location and to detect fraud and money laundering. These tools may result in a purchase, withdrawal or Account being restricted pending review. Where such a decision has a legal or similarly significant effect on you, you may request human review by contacting us at [email protected].

How to exercise your rights. To exercise these rights, contact us at [email protected]. We may need to verify your identity before responding. We will respond within forty-five (45) days, which we may extend by an additional forty-five (45) days where reasonably necessary, in which case we will inform you. We will not discriminate against you for exercising your rights. Where permitted by applicable law, you may authorize an agent to submit a request on your behalf.

Appeals. If we decline to take action on your request, you may appeal our decision by emailing [email protected] with “Privacy Request Appeal” in the subject line within a reasonable period after receiving our decision. We will respond to your appeal within the period required by applicable law and explain the reasons for our decision.

18. FOR CALIFORNIA RESIDENTS

1. As a California resident, you hold the right to request disclosure of the personal information collected from you, to have that information deleted, and, subject to specific constraints, to opt out of the sale of your personal information.
2. To exercise your California privacy rights, contact the representative by creating a ticket via our customer support portal. We will verify your identity when you request to exercise these rights. While logging into your Account might suffice, additional verification information may be requested if there are suspicions of Account compromise or if you do not have an Account.
3. You also have the right to appoint an agent to act on your behalf. To verify authorization, your agent must provide a signed written authorization or a copy of a power of attorney.
4. Twice within a 12-month period, you can request disclosure of the categories of personal information collected, used, and shared, including specific pieces collected and shared with third parties for direct marketing.
5. You can also request the deletion of personal information collected from you, although certain information may be exempt under California law. Your choice to exercise these rights won't impact your access to or the quality of our Services.
6. We might sell directly identifying information like name, telephone number, mailing address, or email address. Opting out of the sale of personal information is possible by contacting the representative via the customer support portal at [email protected].
7. If you're a California resident under 19 years old, you can request to view, correct, or delete information provided by you or posted publicly. However, our Services are limited to individuals of legal age, and we will not knowingly collect or maintain information from minors.
8. Regarding "Do Not Track" settings, we presently do not take actions to respond to these settings. Instead, we adhere to the standards outlined in this Privacy Policy.
9. California Collection Notice:

• We might share the information described below with third parties for various purposes:
• With our group companies in line with this Privacy Policy.
• With vendors and partners to deliver our Services.
• If obligated by applicable law or legal process.
• To exercise, establish, or defend our legal rights.
• To safeguard vital interests.
• In connection with business sales.

10. We collect various categories of information. The table below delineates how we collect and use such categories (additional categories collected in connection with Turbo Rips are described in the Section titled “Turbo Rips”):

19. INTERNATIONAL USERS

This Privacy Policy is intended to cover the collection of information within our home jurisdiction. Some countries may require stricter privacy policies than those described herein. If you are accessing the Website and/or Services from a foreign country, you understand and agree that your information may be transferred to, stored, and processed in our home jurisdiction or the jurisdiction of the third parties described herein, and that the data protection and other laws of our home jurisdiction or the jurisdiction of such third parties might not be as comprehensive as those in your home country

20. GOVERNING LAW

1. This Privacy Policy shall be construed and enforced in accordance with the laws of the State of Delaware without regard to any conflict of law provisions. Notwithstanding the foregoing, this Privacy Policy and the collection of information hereunder shall comply with all applicable data protection laws and regulations.
2. Any dispute over privacy is subject to the provisions of this notice and to our Terms and Conditions. For any dispute relating to Turbo Rips, references to the Terms and Conditions in this paragraph mean the Turbo Rips Terms of Service.
3. This Privacy Policy is effective as of the date indicated at the top of this document (the “Effective Date”) and will remain in effect until amended or replaced in accordance with its terms. We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or for other operational reasons. Any updates will become effective immediately upon being published on the Website, unless otherwise specified. By continuing to access or use the Website after the Effective Date of any revisions, you acknowledge and agree to the updated Privacy Policy.

22. TURBO RIPS

This Section describes how we handle personal information when you use Turbo Rips, our service for the purchase and sale of physical collectible trading cards, as described in the Turbo Rips Terms of Service (the “Rips Terms”). Capitalized terms not defined in this Section have the meaning given in the Rips Terms. The rest of this Privacy Policy, including your rights and how to contact us, also applies to Turbo Rips.

Information we collect. When you use Turbo Rips, in addition to the information described in Section 2, we collect:

(a) Identity and verification information: name, date of birth, residential address, government-issued identification, proof of address, proof of ownership of payment methods and, where a selfie or liveness check is used, a facial image and facial geometry data (“Biometric Information”);

(b) Location information: IP address and device location signals, used to confirm that you are located in a Permitted Jurisdiction;

(c) Purchase and activity information: packs viewed and purchased, the odds displayed at the time of purchase, the cards revealed, buyback offers and acceptances, Vault status and your Rips Balance;

(d) Payment and payout information: payment method details (processed by our Payment Providers; we do not store full card numbers) and the bank account or card details you provide for withdrawals;

(e) Shipping information: shipping name, address and phone number, carrier tracking data and delivery confirmations;

(f) Tax information: IRS Form W-9, Social Security Number or other taxpayer identification number, and withdrawal totals; and

(g) Responsible purchasing information: purchase limits, breaks and self-exclusion settings.

How we use it. We use this information to provide Turbo Rips; to process purchases, buybacks, shipments and withdrawals; to verify your identity, age and location; to prevent fraud, money laundering and other prohibited conduct; to keep records of odds and outcomes and respond to disputes and chargebacks; to meet our tax, accounting and legal obligations; to apply your responsible play settings; to provide customer support; and, subject to your choices, to send you marketing about Turbo Rips.

Who we share it with. We share Turbo Rips information only as necessary with: our identity verification provider Sumsub; our geolocation, IP intelligence and device identification providers; our Payment Providers; our fulfilment partner, which stores, insures, authenticates and ships cards; shipping carriers; our professional advisers, insurers and auditors; and government, tax and law enforcement authorities where required by law.

No sale; marketing. We do not sell Turbo Rips information. We do not use your Turbo Rips activity to market Gold Coin Games or Promotions to you unless you have agreed to receive such marketing, and we never send marketing about Gold Coin Games, Sweepstakes or Promotions to users under 21 years of age.

Biometric Information. If a selfie or liveness check is used during verification, you will be asked to give your consent before any Biometric Information is collected. This consent is requested through the interface of our identity verification provider, Sumsub, and is given to both us and Sumsub. Biometric Information is collected and processed by Sumsub on our behalf, used only to verify your identity and prevent fraud, and is never sold, leased, traded or otherwise disclosed except to our verification provider or as required by law. It is permanently destroyed when the purpose for collecting it has been satisfied and in any event within the period required by applicable law.

Sensitive information. Government identifiers, precise location, financial account information and Biometric Information are used only to provide Turbo Rips, verify you, prevent fraud and comply with law. We do not use them to infer characteristics about you.

Public display. We display your username, avatar or cards in public features of Turbo Rips (such as a “recent pulls” feed) only if you opt in. You can change this choice at any time in your Account settings.

Communications. Service messages about Turbo Rips, such as purchase confirmations, notices before an automatic buyback and shipping updates, are not marketing. Marketing text messages are sent only with your separate consent, as described in the Terms and Conditions and the Rips Terms.

Retention. Unless a longer period is required by law or for a pending dispute, we keep records of odds and Rip outcomes for at least 24 months, and we keep other Turbo Rips information for as long as necessary for the purposes described in this Section, including to comply with our legal, tax, accounting and regulatory obligations, as described in Section 8.

Minors. Turbo Rips is available only to individuals who are at least 19 years of age. We do not knowingly collect information about anyone younger, and we delete it if we learn that we have.