Privacy Policy

 

Revised as of【November 17, 2024】

 

We, Epic Arcane Productions LTD, respect our users' privacy rights, and take the security of personal information seriously. This Privacy Policy ("Policy") explains our data practices for the Competitions, Software and Services that we offer to our users.

This Policy is incorporated into, and is part of, our Terms of Services available at https://epicarcane.com/tos.html which govern your access to the Account and your use of the Software and Services. Unless otherwise defined herein, capitalized terms shall have the meaning assigned to such terms in the Terms of Services.

By accessing any part of our Software or using any of the Services, you agree to be bound by this Policy. If you do not agree with this Policy, please do not use the Software or Services.

1.  WHO WE ARE

We are Epic Arcane Productions LTD, a leading developer, publisher and marketer in the field of interactive entertainment.

2.  INFORMATION WE COLLECT

The information we collect depends on how you interact with us, our Services and Software and the requirements of applicable law. We collect information that you directly provide to us, information that we obtain automatically when you use our Services or Software and information from other sources.

2.1 Information You Directly Provide to Us

• Account Information. When you create your Account, we may collect username, geolocation, email address and profile image (if any).
• Payment Information. When you make purchases and withdrawals via our Services or Software, we may collect your first name and last name, physical address, the form of payment you use and payment method details (such as credit or debit card number) as well as your deposit and withdrawal records.
• Identity Information. In certain instances, for anti-fraud and anti-laundarying purpose, you will be required to complete identity verification procedures. In such case, we may require and collect your first name and last name, birthdate, phone number, physical address and government-issued ID (e.g., passport number, driver‘s license number, social security number or ITIN). You may also be required to take a selfie with your government-issued ID, which our service providers may analyze to ensure your facial image matches the photo in your government-issued ID. If you consent to our collection of such information, you agree that we may collect your image, including your image on your government-issued ID, and your such information may be shared with our service providers who may perform a scan of your facial geometry to provide identity verification services to us.
• Competitions. We may collect personal information you provide for any Competitions (e.g., date of birth and geolocation).
• Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support or otherwise communicate with us.

2.2   Information Collected Automatically

• Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, WiFi routing information, location information (including approximate location derived from IP address) and Internet service provider.
• Usage Data. We may automatically collect information regarding your use of our Services, such as pages that you visit during using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, usage details about when you launch our games, when and how long you play each game and other information about how you use our Services.
• Gameplay Content. When you play our games, we may collect information about gameplay, game server usage, game device usage, system interactions and other information associated with your Account. We may also record your in-game behavior (including your button inputs) and skill levels (e.g., scores, rankings, and achievements), and replay them to you or other Users or use them to match with other players, to improve our Services and prevent fraud.
• Diagnostics Data, including any crash logs and usage and performance statistics.

2.3 Information Collected from Other Sources

• Third-Party Websites, Applications, or Platforms. To access some of our Services, you may have the option to link an account on a third-party website, application or platform, such as Google, Samsung and Apple (“Third-Party Platforms”) with the Services. Third-Party Platforms are not controlled by us and their collection and usage of personal data is subject to their respective privacy policies. We may obtain additional information about you from the Third-Party Platforms, depending on your privacy settings.
• Referrals Features. Our referral services may allow you to share a link with your friends to invite them to use our Services.

We collect and use your information for a variety of business purposes, including providing our Services, administrative purposes and marketing and advertising purposes.

3.1 Provide Our Services

We collect and use your information to fulfil our contract with you and provide you with our Services, such as:

• Providing access to the Competitions, Software and Services offered by us;
• Determining your skill levels and matching you with players of a similar skill level
  
• Managing your information and Account;
• Personalizing the Services for you, such as sending you rewards or other benefits;
• Answering requests for customer or technical support;
• Communicating with you about your Account, our Competitions, Software or Services, and policy changes; and
• Processing your payment instructions regarding the Software or Services.

3.2 Administrative Purposes

We collect and use your information to analyze and improve our Services in our legitimate interest, or to comply with our legal obligations, such as:

• Pursuing our legitimate interests such as research and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent and illegal activities, and prosecuting those responsible for those activities;
• Determining your eligibility to participate in the Competitions or use the Software or Services;
• Measuring interest and engagement in our Competitions, Software or Services;
• Short-term, transient use, such as contextual customization of ads;
• Improving, upgrading, or enhancing our Competitions, Software or Services;
• Developing new Software and Services;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities, including requests to exercise your rights under this Policy;
• Debugging to identify and repair errors with our Services;
• Auditing relating to interactions, transactions and other compliance activities;
• Enforcing our Terms of Services and this Policy; and
• Other uses as required to comply with our legal obligations.

3.3 Marketing and Advertising

We collect and use your information to tailor and provide you with content and advertisements, such as:

• Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services; and
• Email campaigns, custom audiences advertising, and interest-based advertising or personalized advertising.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time.

We would not share with advertisers information that can be used to personally identify you.

3.4 Other Purposes

We also collect and use your information for other purposes as requested by you or as permitted by applicable law.

• Anti-Fraud. Providing users with a fair, balanced and competitive experience on our Services is extremely important to us. Therefore, we strictly enforce prohibitions against cheating, hacking, account stealing and any other unauthorized or fraudulent activities. When you create an Account, participate in the Competitions, or use the Software or Services, we may use a variety of anti-cheat and anti-fraud prevention technologies to help us identify and prevent malicious activities. These services may collect and analyse data about the game binary or your computer to detect cheating, and may be provided by us or by third party service providers.
• Automated Decision-Making. We may engage in automated decision making, including profiling, for example to determine your skill levels, to match you with players of a similar skill level, to determine if you are permitted to make withdrawals from your Account and to block a user in case we suspect such user is using our services for illegal acts or acts that violate our Terms of Services. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us at any time.
• Other Purposes. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

4.  HOW WE SHARE INFORMATION

We may share and disclose your information to third parties, by using Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”), for the purpose of providing the Services. These third-party service providers are not authorized to retain, share, store or use the personal information for any purposes other than to provide the Services they have been hired to provide. The third parties we may share your information with include:

• Service Providers. We may share your personal information, such as your first name and last name, email address, phone number, physical address and payment information, with our third-party service providers, who provide us with IT support, hosting, payment processing, fraud prevention and/or “Know Your Customer” verification, customer service and related services, so that they can use such information to help us provide our Services, for example they authenticate your identity, confirm your eligibility to receive payments and process your deposits.
• Business Partners. We may share your personal information with our business partners to provide you with the requested Competitions or Services jointly offered by us and our business partners.
• Other Users/Software Visitors. The Software and Services allow you to share the Content created by you with other Users/publicly, including those who do not use our Services.
• Advertising Partners. We may partner with third party advertising partners to either display advertising on our Software or to manage our advertising activities on other websites or apps. Our third party advertising partners may use Tracking Technologies to gather information about your activities on our Software and other websites and apps (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day) in order to provide you with advertising based upon your browsing activities and interests. Please refer to the privacy policies of our advertising partners for more information on how to exercise your rights and control your advertising choices. Our advertising partners include the following:

  AppLovin: https://www.applovin.com/privacy/

  InMobi: https://www.inmobi.com/privacy-policy

  Unity: https://unity3d.com/legal/cookie-policy#cookies

  Vungle: http://vungle.com/privacy

  ironSource: http://www.ironsrc.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf

  Chartboost: https://www.chartboost.com/legal/cookie-policy/

  Digital Turbine Console: https://www.digitalturbine.com/legal/privacy-policy

  Mintegral: https://www.mintegral.com/en/privacy

  Moloco: https://www.moloco.com/privacy-policy

We may also disclose any information we store associated with you to third parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property or safety; enforce our Terms of Services and this Policy; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

We may also share your data with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers) for ensuring our compliance with regulatory requirements and industry standards.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, liquidation, dissolution, receivership, purchase or sale of assets, or transition of service to another provider, your information may be transferred as part of such a transaction, as permitted by law and/or contract.

5.  OUR LEGAL BASES

The legal bases, upon which we collect, process, use and disclose your personal information, are as follows:

• Your Consent: We ask you for consent to collect or use your personal information for specific purposes, such as when we want to send you emails about special offers or competitions.
• Contract Performance: We process your personal information when we need to perform and manage a contract with you, such as our Terms of Services and this Policy.
• Legal Requirement: We process your personal information when required by law.
• Legitimate Interest: We process your personal information when necessary for our or others' legitimate interests and when these interests do not outweigh your own rights and interests. This covers processing for purposes such as improving our Software and Services; performing analytics to better understand our users; otherwise supporting our business, operations and Services; ensuring the proper function, security and integrity of our Software and Services; dealing with users' questions; preventing fraud; preventing illegal activities; preventing violations of our Terms of Services and this Policy; and preventing intellectual property right infringement.

6.  TRACKING TECHNOLOGIES

When you access our Services and Software, we may use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"), which allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Service's performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better correspond with your interests.

6.1 Categories of Tracking Technologies

The categories of Tracking Technologies that we use are as follows:

• Strictly Necessary Tracking Technologies.  These Tracking Technologies are automatically placed on your Device when you access our Services or take certain actions within our Software. These Tracking Technologies are essential to enable you to navigate around and use our Services.
• Tracking and Advertising Tracking Technologies.  These Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The Tracking Technologies remember the websites you visit and that information is shared with other parties such as advertisers and/or publishers. Publishers, advertisers, and third-party ad networks may also utilize Tracking Technologies or similar technologies to deliver ads and monitor the performance of such ads. The collection of information through Tracking Technologies by such third parties will be governed by their own privacy policies/cookies policies and principles, which we do not control;
• Functionality Tracking Technologies. These Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services;
• Performance Tracking Technologies. These Tracking Technologies collect information about your online activity (for example the duration of your visit to our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).

6.2 Ways to Manage Tracking Technologies

You can withdraw your consent to personalized advertising experience on your Device at any time by using your device settings as follows:

• On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version.)
• On Android, you may manage the interest-based advertising through the setting menu on your mobile device by seletinng "opt-out of interest-based ads", or you may also withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).

7.  YOUR PRIVACY CHOICES AND RIGHTS

7.1 Your Privacy Choices

The privacy choices you may have about your personal information are determined by applicable laws and are described below:

1.    Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services).

2.    Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your Device.

3.    Tracking Technologies. You may manage the Tracking Technologies on the Device in accordance with the ways introduced under the Section 6.2. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. For your reference only, the online advertising industry (such as the Network Advertising Initiative and the Digital Advertising Alliance) also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.

Please note you must separately opt out on each Device.

7.2 Your Privacy Rights

In accordance with applicable laws, you may have the right to:

1.    Access Your Personal Information, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information in a structured, commonly used, and machine readable format; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format;

2.    Request Correction of your personal information when such information is inaccurate, incomplete and outdated. You may change your data at any time through the profile settings on your Device;

3.    Request Deletion of your personal information, subject to certain exceptions (such as if we are legally required to keep the information);

4.    Request Restriction of or Object to our processing of your personal information which is based on our legitimate interest or for direct marketing purposes;

5.    Withdraw Your Consent to our processing of your personal information. You may change the settings on your mobile device operating system at any time to prevent us gaining access to certain data such as your accurate location – but this may negatively impact on your user experience. Please note that your withdrawal will only take effect on future processing, and will not affect the lawfulness of processing before the withdrawal;

6.    Request Restriction on the Use and Disclosure of Your Sensitive Personal Information (for example, financial account information and your precise geolocation data) for limited purposes such as providing you with the services you requested;

7.    Request Opt-out of Selling or Sharing Your Personal Information. We will not sell or share your personal information after receiving your opt-out request unless you later authorize us to do so again;

8.    Request Non-discrimination for exercising your privacy rights. We shall not deny the Services, charge you a different price or provide a different level or quality of the Services just because you exercise the rights provided under this Section; and

9.    Request not Being Subject to Automated Decision-making. You have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Please note that the above rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.

You may also contact us as set forth in “Contact Us” below to exercise the above rights. We will process such requests in accordance with applicable laws.

8.  DATA SRTORAGE AND TRANSFER

Your information collected through our Services may be stored and processed in the United States. If you are located in the European Union or other regions, please note that we may transfer your Personal Information to the United States.

As mentioned in the Section 4, we may share your personal information with our service providers, thus during this course, your personal information may be transferred to, stored and processed in a country where our service providers are located.

All the above transfers will be made pursuant to appropriate safeguards as provided by applicable laws. If you wish to enquire further about the transfers, please contact us using the details set out at the end of this Policy.

9.  DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we will consider the amount, nature, and sensitivity of personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Please note that in order to comply with anti-money laundering regulations, we may need to keep your data (e.g. a copy of a passport, driver's licence or utility bill for at least five years or the maximum period permitted by applicable laws.

10. SECURITY OF YOUR INFORMATION

We have taken steps to ensure that your information is treated securely and in accordance with this Policy, and try our best to prevent unauthorized access, use, or disclosure of your Personal Data. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. We have taken appropriate safeguards to require that your personal information will remain protected, and take steps to require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

11. MINORS' INFORMATION

Our Services are not directed to users who do not reach the legal age of majority in the jurisdiction in which such users are physically located, and we do not knowingly collect personal information from minors. If you are a parent or guardian and believe your child has uploaded personal information to our Software, you may contact us to delete the relevant information. If we become aware that a child has provided us with personal information, we will delete that personal information upon discovery.

12. NOTICE FOR CALIFORNIA RESIDENTS

If you are resident in the State of California in the United States, please refer to Annex 1 for additional California-specific privacy notice.

13. CHANGES TO THIS POLICY

We reserve the right to amend this Policy at any time in our sole discretion. The most current version will always be posted on our Software. You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

14. CONTACT US

If you have any questions about this Policy or wish to exercise your privacy rights, please contact us by email at: LuxeMirageReels@outlook.com.

ANNEX 1

California Privacy Notice

 
This CALIFORNIA PRIVACY NOTICE (“Notice”) IS FOR CALIFORNIA RESIDENTS solely and supplements this Policy. We have adopted this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

1. Privacy rights
California residents are entitled to enjoy all privacy rights provided under the Section 7 of this Policy and can exercise such rights in accordance with the Section 7 of this Policy.

2. Personal information collected
In the preceding 12 months, a list of the categories of personal information we have collected about California residents is as follows:
a. Identifier, such as your first name and last name, your username, physical address, Internet protocol (IP) address, email address, bank account name, phone number, passport number and driver‘s license number;
b. Personal information described in subdivision (e) of Section 1798.80. of Cal. Civ. Code, such as your first name and last name, physical characteristics or description, physical address, phone number, passport number, driver‘s license number, bank account number, credit or debit card number;
c. Characteristics of protected classifications under California or federal law, such as age;
d. Commercial information, such as as your deposit and withdrawal records;
e. Biometric information, such as your facial image;
f. Internet or other electronic network activity information, such as browsing history, usage data, gameplay content and advertisement;
g. Geolocation data;
h. User settings, cookies, and other information from which we can draw inferences to create your profile reflecting your preferences and behaviors. 

3. Sources
The categories of sources from which we collect personal information are set forth in the Section 2 of this Policy. Namely, we collect information that you directly provide to us, information that we obtain automatically when you use our Services or Software and information from other sources. Please refer to the Section 2 for more information.

4. Purpose
We collect, use and share your information for providing our Services, administrative purposes, marketing and advertising purposes and other purposes, as set forth in the Section 3 of this Policy.

5. Personal information sharing
We share your personal information with the third parties as listed in the Section 4 of this Policy.
For purposes of the CCPA, we do not “sell” personal information. That said, we do share information with third-party advertisers for the purpose of promoting our Services. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your information shared by disabling third-party cookies on your device or by contacting us.
Please refer to the Section 2 of this Notice for a list of the categories of personal information we have shared about you in the preceding 12 months and a list of the categories of personal information we have disclosed about you for business purpose in the preceding 12 months.
 
6. Verifiable consumer request
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us and provide a written authorization signed by you and your designated agent.
To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent, which may include asking you to answer questions regarding your account and use of our Services.