Privacy Policy

1. Who we are and what this policy covers

Coinmaster Limited (“we”, “us”, or “our”) operates Vegas jackpots, a social slots game for iOS distributed through the Apple App Store. This Privacy Policy explains our handling of personal data in connection with the game, its policy pages, and customer support (the “Service”).

For privacy questions or requests, contact vegas_jackpots@hummergames.com. This mailbox is also our customer support channel. This policy provides information about our practices; reading it or using the Service does not by itself constitute consent to optional data processing.

2. Personal data handled by the Service

We process the following types of information in connection with the Service. The information involved depends on your account, interactions and use of the game. Guest access does not necessarily make your activity anonymous.

• Email address and correspondence: information you provide when contacting support or exercising privacy rights, and an email address made available through Sign in with Apple where you choose to share one. Apple may provide a private relay address instead of your personal email address.
• User identifiers and account information: identifiers for your guest or Apple-linked game account, together with information used to associate that account with game progress and virtual balances.
• Device identifiers: identifiers processed by the app and its integrated software to support app functionality, analytics and product personalization. A device identifier is not necessarily anonymous simply because it does not include your name.
• Purchase history: information about your one-time in-app purchases, used to deliver and verify purchased content, handle related support and analyze purchase activity. Apple processes App Store payments under its own terms and privacy practices.
• Game progress and support information: the progress, virtual items and information needed to provide gameplay and address your requests, including information you voluntarily send to support.

Sources include your interactions with the Service, Sign in with Apple, App Store transaction services and software integrated into the app. The app uses Unity-based software. We do not require your Apple Account password. Please do not send us passwords or full payment card details.

3. Why we process personal data

We use personal data to operate accounts and gameplay, maintain progress and virtual balances, provide purchased content, respond to support and privacy requests, analyze use of the Service, personalize the in-game experience, protect against misuse and comply with legal obligations.

Where EEA or UK data protection law applies, we rely on the following bases as applicable:

• Performance of our contract: processing necessary to provide the account, gameplay, purchased content and associated support you request.
• Legal obligations: processing required by applicable laws, including required transaction records and responses to valid legal requests.
• Legitimate interests: proportionate processing for security, fraud prevention and service administration, and permitted service improvement, only where our interests are not overridden by your rights. Our interests are to provide a reliable, secure and useful Service.
• Consent: optional analytics, personalization or device access where applicable law requires consent. You may withdraw consent without affecting the lawfulness of processing before withdrawal.

We do not treat every use of information as necessary to perform our contract. Where a feature requires consent, we will obtain it before the relevant processing and provide a means to withdraw it. Acceptance of our Terms does not itself authorize optional processing.

4. Advertising and privacy choices

The initial release of Vegas jackpots does not display advertisements. Advertising capability is reserved for possible future use.

If we introduce advertising, we will update this policy to explain the relevant data, purposes, recipients and privacy choices before the new processing begins, and obtain any consent or permission required by law or Apple. We will not treat acceptance of the current Terms as consent to future advertising-related processing.

The absence of displayed advertisements does not itself mean that no personal data is processed. Account, device, purchase and other processing described in this policy may still occur. You can manage available app permissions through iOS Settings and contact us for help with privacy choices.

5. Who receives information

Information is disclosed only where necessary for the purposes described in this policy and permitted by applicable law. Recipients may include:

• Service providers: providers supporting hosting, software operations, analytics, customer support and security, subject to arrangements appropriate to their roles.
• Apple: in connection with Sign in with Apple and App Store purchases. Apple’s processing is also governed by its applicable privacy information and terms.
• Professional advisers and authorities: where disclosure is required by law or necessary and legally permitted to protect rights, respond to valid legal process, or investigate fraud or security incidents.
• A successor operator: where relevant information transfers in a merger, restructuring or transfer of the Service, subject to applicable safeguards and any required notice.

Providers acting on our behalf must process information for the agreed purposes and under appropriate instructions and safeguards. Where a recipient determines its own processing purposes, its own privacy information also applies. We do not authorize unrelated uses simply because a provider receives information from us.

6. International processing

Where personal data is processed outside your country, applicable transfer requirements must be met. For transfers subject to EEA or UK restrictions, we use a legally available mechanism where required, such as an applicable adequacy decision or appropriate contractual safeguards, together with any necessary supplementary measures. You may contact us for information about the safeguards relevant to your data.

7. Retention and security

We retain personal data only for as long as needed for the relevant purpose, taking account of the type of record, the Service you use, applicable legal requirements and any ongoing disputes or security matters. The criteria below determine retention; we do not retain information indefinitely merely because it may have a commercial use.

• Account information and game progress: retained while needed to provide your account and gameplay. Following an account deletion request, we delete the associated personal data unless specific records must be retained for a lawful purpose such as compliance, security or legal claims.
• Purchase records: retained for delivery and verification of purchases and for the period needed to meet applicable accounting, tax and other recordkeeping obligations or resolve related disputes.
• Support records: retained while needed to handle your request and any related follow-up, complaint or legal claim.
• Security and service-operation records: retained while necessary to investigate and address misuse or incidents, maintain service security and meet related legal obligations. Retention is limited to what is proportionate to those purposes.
• Analytics and personalization data: retained while needed for the stated analysis or feature, subject to applicable privacy choices and deletion rights. When identifiable data is no longer necessary, we delete it or appropriately anonymize it.
• Backups: residual copies are removed through the applicable backup rotation process. Until removal, access and use are restricted to necessary recovery, security or legal purposes. If a backup is restored, applicable deletion requests must be reapplied.

Where we retain records after account deletion, we limit them to what is necessary for the relevant lawful purpose. Retention ends when that purpose and any applicable legal requirement end. You may contact us for information about retention relevant to your request.

We use appropriate technical and organizational measures to protect personal data. No system is completely secure. Please contact us if you suspect unauthorized use of your account.

8. Your privacy rights and account deletion

Depending on applicable law, you may have rights to access, correct, delete or obtain a portable copy of your personal data, restrict or object to processing, withdraw consent, and complain to a competent data protection authority. Some rights are subject to legal conditions and exceptions.

You can initiate account deletion using the account deletion option in the app. You may also contact vegas_jackpots@hummergames.com for deletion assistance or other privacy requests. Account deletion includes associated personal data unless retention is legally justified; simply deactivating an account is not a substitute for deletion. Removing the app from your device does not itself send us a deletion request.

We may request information reasonably necessary to verify your identity or authority, without collecting excessive information. We respond within the applicable legal deadline. Where GDPR applies, we ordinarily respond within one month; a legally permitted extension will be explained within that month. If we cannot fulfill a request, we explain why and the available complaint options as required by law.

Where applicable US state laws apply to us, eligible residents may also have rights to opt out of sale, sharing or targeted advertising, to limit certain sensitive-data uses, to use an authorized agent, and to appeal a denied request. We will not unlawfully discriminate against you for exercising your rights.

9. Adults only

The Service is intended only for users who have reached the age of majority in their jurisdiction and meet any higher minimum age required by applicable law for using the Service. It is not directed to children or other ineligible minors.

If you believe an ineligible minor has provided personal data, contact vegas_jackpots@hummergames.com. We will investigate and take appropriate steps to restrict access and delete personal data where required, subject to lawful retention obligations.

10. Changes and contact

We will update this policy when our practices or applicable requirements change. The effective date identifies the current version. We will provide appropriate notice of material changes and obtain fresh consent where required; merely continuing to use the Service will not replace required consent.

Privacy and customer support: vegas_jackpots@hummergames.com, for Coinmaster Limited’s Vegas jackpots service. For terms governing use of the game, see our Terms of Service.