Privacy Policy

This Privacy Policy outlines the policies of SWPMSystem, LLC (“SWPMSystem”) and Sweepium LTD, individually and/or through its licensed partners (each, a “Partner” or “Sponsor”), concerning the collection, utilization, sharing, and secure storage of information. It is applicable to all interactions with our Website, regardless of whether you access it via a PC, a mobile device, or through a third-party application (e.g., Facebook). Please review this Privacy Policy thoroughly before engaging with any of our products. These guidelines are to be read in conjunction with our Terms and Conditions, Sweeps Rules regarding StarCoin (SC, FICO OR FC) (“Rules”), Responsible Gaming Policy, and and/or any other pertinent documents relating to your use of the Website (collectively referred to as the "Documentation"). Any terms defined in the Documentation but not explicitly outlined in the Privacy Policy hold the same meaning as specified in the Documentation. For inquiries, contact us at support@starsplay.com.

The following definitions are applicable to this Privacy Policy:

"Account" refers to your user account created on the Website.

"Covered Information" denotes data that enables the identification or contact of an individual, encompassing, but not limited to, first and last names, addresses, email addresses, phone numbers, and any identifier facilitating direct or indirect contact.

"Confidentiality Incident" encompasses unauthorized access, use, loss, or transmission of a user's personal information, including any data enabling direct or indirect identification, as well as any breach of data protection.

"Data Protection Officer" signifies a role within an organization responsible for ensuring compliance with prevailing data protection legislation.

"Event Tagging" represents tags enabling the tracking of specific events carried out on our Website (e.g., purchases).

"StarCoin (SC, FICO OR FC)" stands for the in-game currency used to enter and participate in Promotions as governed by our Rules and/or the Website’s Terms and Conditions.

"Gold Coin (GCO, TICO OR GC)" refers to the in-game currency utilized for Gold Coin Games as governed by our Rules and/or the Website’s Terms and Conditions.

"Marketing Pixels" are snippets of code allowing us to gather information about visitors to our Website and their interactions with our webpages.

"Mobile Device Identifiers" represent unique identifiers on mobile devices used to differentiate one device from another, especially in internet-based advertising.

"Participant" denotes a user acquiring, utilizing, or redeeming StarCoin (SC, FICO OR FC)s in games.

"Prize(s)" are StarCoin (SC, FICO OR FC) that are eligible for redemption by a Participant in accordance with our Rules and/or the Website’s Terms and Conditions.

"Service" signifies any service accessible through our Website or mobile applications.

"Website" refers to our website hosted at www.starsplay.com.

"User" represents an individual utilizing the Service.

Data Collection

We acquire information about Users through various methods. This includes directly identifiable information, such as:

• Contact details, encompassing your email address, physical mailing address, mobile phone number, and any additional phone number(s) provided.
• Personal information like your first name, last name, age, and likeness.
• Account login details, including your unique username, password, and associated account images.
• Transactional details provided by you, such as mailing address, phone number, payment and/or other information for redemption and/or verification purposes (e.g., financial institution details, credit card information, and bank account statements).
• Information shared via live chat, email, or any other customer support method.
• Data obtained from third-party sources (e.g., Facebook) regarding your interaction with the Services.
• Location information provided by devices interacting with our platform.
• Activity and device data related to your use of our Service, encompassing content viewed/used, duration and frequency of access, source of learning about our Service, specific hardware model, device type, unique device identifiers, operating system, browser type, and IP address.
• Any documentation required to verify your eligibility for an account and payouts.

Additionally, we may collect non-directly identifying information, as well as data related to groups of customers that doesn't directly identify you, such as usage patterns of the Website or the device's zip code/postal code.

Upon providing any information to or via the Website, you affirm that the details furnished are accurate, complete, and up-to-date as is necessary for the purposes for which it is used. This includes acknowledging the accuracy of your contact information, like phone numbers and email addresses. It shall be your sole responsibility to update any and all information provided for use of the Website.

By providing your phone number(s) to us, you consent to being contacted using the provided number. Possible communication methods include pre-recorded voice messages, autodialed calls, SMS messages, and emails regarding:

• The Documentation.
• Account-related purchases or redemptions.
• Promotional content from or on behalf of us, given we have your opt-in consent for certain types of messages.

To opt out of these messages, contact us at support@starsplay.com or use the unsubscribe feature in the message.

Collection of Information

User information is gathered through various avenues, such as when a User accesses our Service, creates an Account, makes a purchase, responds to surveys (including those from related third parties), and interacts with any other service or feature offered by the Website.

We may also gather information from Users through various channels such as telephone, video, and correspondence via email, instant messaging, physical mail, SMS, and social media platforms. Telephone and video calls may be recorded for training, quality control, and compliance purposes. Participation in such calls implies consent to the call being recorded.

Technology Usage

We employ diverse technologies within our Website or applications on third-party sites, including cookies, pixels, tags, and application program interfaces (APIs). For instance:

• Cookies: Small text files stored on your device distinguishing it uniquely.
• Similar Identifying Technologies: Such as Marketing Pixels, Mobile Device Identifiers, and Event Tagging. At times, Mobile Device Identifiers might be shared with advertisers.
• Analytical Tools: Utilized to gather information during your visits to our Website or when using our applications or services on third-party platforms.

Utilization of Your Information

Your information is employed for purposes outlined in this Privacy Policy. Additionally, it may be accessed by other companies within our group as data processors. Information collected is retained as required by this policy or permitted by law. We do not share personal information with third parties for their own direct marketing purposes.

Reasons for Collection and Use of Information

We collect and utilize your information for the following purposes:

• Identification and Verification: To identify you as a User and/or collect location information for the purpose of verifying whether you are eligible to access the Website.
• Transactions: To process transactions (including, without limitation, purchases and/or redemption requests). In the processing of payments, the information provided by you may be utilized to fulfill due diligence requirements related to anti-money laundering and payment verification. We do not disclose payment information to third-party processors except as necessary for transactional services.
• Service Provision: Establishing and maintaining your Account, conducting routine security checks, and addressing customer service requests.
• Customer Service Enhancement: Your information helps in providing optimal customer service.
• Legitimate Business Interests: When it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Use of Aggregated Information

We may also conduct research on our user demographics, interests and behavior. We aggregate, anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. We may share this aggregated and/or de-identified data with our affiliates, agents and business partners. We may also disclose aggregated and/or de-identified user statistics and other metrics related to our Website in order to describe our products or services to current and prospective business partners and to other third parties for other lawful purposes. Aggregated information assists in comprehending our users better, ensuring a more tailored user experience.

Communication and Notices

We may contact you via email, live chat, telephone, SMS, physical mail, or social media to manage Promotions and competitions you choose to participate in. This also includes sending important notifications concerning your purchases or any policy changes.

Compliance and Legal Obligations

Information collected is employed to adhere to legal and regulatory obligations, ensuring compliance with the Documentation and other regulatory requirements.

Your Rights Regarding Information

You have specific rights concerning the securely stored information about you. Contact our Data Protection Officer to exercise these rights, which include accessing stored personal information, objecting to processing, and withdrawing consent provided in this Privacy Policy.

Information Security Measures

Safeguarding your personal information is of utmost importance to us. We utilize physical, electronic, and operational protocols to secure your data, employing industry-standard practices for collection, storage, and processing. Although we consistently review and update our security protocols to meet industry standards, no system is entirely immune to unauthorized access. If you suspect a compromise of your information, notify us immediately at support@starsplay.com.

Information Retention

We retain your information for the duration necessary to fulfill the practices outlined in this Privacy Policy, as per our business needs, and in compliance with applicable laws. In case of Account closure, we may retain Account details for dispute resolution or clarification purposes.

Information Sharing

We do not share personal information with third parties for their own direct marketing purposes.We use your information to Provide and improve the Sites; Contact you; Fulfill your requests for products, services, and information; Send you direct promotional material; Analyze the use of the Sites and user data to understand and improve the Sites; Customize the content you see when you use the Sites; Prevent potentially prohibited or illegal activities and otherwise in accordance with our Terms and Conditions; and for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Third Party Services and Collection Of Information

Third parties may provide materials to the Website that use cookies, web beacons, or other tracking technologies to collect your information, including information about your online activities over time and across different websites and other online services. Those third parties may use this information to provide you with interest- based advertising or other targeted content. We do not control third party tracking technologies or how third parties use them. Your use of third party applications or services are governed by the user terms and privacy policy of the third party that provided that application or service. This Privacy Policy does not apply to any third party's websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Services.

When you initiate a payment transaction through the Website, we may process your payments through a third party website, including, without limitation, third-party payment processers. The third party website may collect certain financial information from you in order to process a payment, including your name, email address, address and other billing information.

If you decide to use, click on, access, or provide any personal information to a third party website, you acknowledge that you are doing so at your own risk. Please be aware that we do not operate, control, or endorse third party websites that may be linked on the Website or the Services, nor are we responsible for the content or privacy practices of third party websites. We disclaim any responsibility for your personal information on third party websites, and we do not make any warranties or representations that any third party website will function without error or interruption, that defects will be corrected, or that any third party websites or their servers are free of viruses or other problems that may harm your computer.

Announcement of Prize Winners and Information Sharing

We reserve the right to use a User's information to announce Prize winners through our Service, including details such as their name, the amount of StarCoin (SC, FICO OR FC) or Gold Coin (SC, FICO OR FC), their city, state, country, profile picture, or any other collected personal information as described in this Privacy Policy for marketing purposes. This may include social media platforms, affiliated marketing channels, and physical media channels (such as radio, television, or print media).

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.

Contact Information

For inquiries, please reach out to our Data Protection Officer at support@starsplay.com.

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 wish for it to be deleted, contact us at support@starsplay.com.

For California Residents

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.

To exercise your California privacy rights, contact the Data Protection Officer 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.

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.

Twice within a 12-month period, you can request disclosure of the categories of personal information collected.

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.

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 Data Protection Officer via the customer support portal at support@starsplay.com.

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.

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.

We might share the information described below with third parties for various purposes:

• If obligated by applicable law or legal process.
• To exercise, establish, or defend our legal rights.
• To safeguard vital interests.

We collect various categories of information. The table below delineates how we collect and use such categories:

International Users

This Privacy Policy is intended to cover 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

Governing Law

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 relevant data protection provisions, including, without limitation, the Data Protection Act, General Data Protection Regulation, the California Consumer Privacy Act ("CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), and/or any other applicable act or regulation governing our collection of your information.

Any dispute over privacy is subject to the provisions of this notice and to our Terms and Conditions.