1. What We Collect
We collect information in three categories:
- Account information — email, declared US state, age confirmation.
- Identity verification information — at redemption, government ID and self-portrait photograph processed through our KYC provider.
- Usage information — IP address, device fingerprint, raffle entries, balance history, login timestamps.
2. How We Use It
- To provide and operate the Service.
- To verify your identity and eligibility for redemption (KYC, age, geolocation).
- To detect fraud, abuse, and prohibited multi-accounting.
- To comply with tax reporting (W-9, 1099-MISC).
- To send transactional notifications you opt into.
3. Who We Share With
- Stripe — for processing credit purchases.
- Persona / Veriff / Onfido (whichever provider we use) — for identity verification.
- Dwolla / Plaid / PayPal — for cash redemptions.
- SendGrid / Twilio — for transactional email and SMS.
- Government authorities — when required by law (e.g., IRS reporting, OFAC sanctions screening).
We do not sell or rent your personal data. We do not use your data for advertising profiling on third-party platforms.
4. Cookies and Tracking
We use first-party cookies and localStorage for essential functionality (session, geolocation declaration, responsible-gaming preferences). We do not use cross-site advertising trackers.
5. Data Retention
We retain your account information for as long as your account is active. Identity verification records are retained for at least 5 years after redemption to comply with tax and AML record-keeping laws. You may request deletion of your account; some records are retained beyond the closure date as required by law.
6. Your Rights
Depending on your state of residence, you may have the right to:
- Request a copy of the personal data we hold about you.
- Request deletion of your data (subject to retention obligations).
- Correct inaccurate information.
- Opt out of non-essential communications.
To exercise these rights, contact support. We respond within 30 days.
7. Security
We use industry-standard encryption in transit (TLS) and at rest. Identity documents are stored only with our KYC provider and never transmitted to operators or other staff.
8. Children
The Service is not directed at persons under 18. If you believe we have collected information from a minor, contact us and we will delete it.
9. Changes
Material changes to this policy will be communicated by email or in-app notice at least 30 days in advance.
10. Contact
Privacy questions: support. For California residents, use the same channel and identify your request as a CCPA inquiry.