Last updated on: February 4, 2025

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Introduction

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Welcome to The Win Zone!

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At The Win Zone, protecting your personal information (“Personal Data”) is important to us. This privacy notice (“Privacy Notice”, or simply, “Notice”) explains how we handle your data, how we keep it safe, and what rights you have under applicable data protection and privacy laws like the California Consumer Privacy Act of 2018 (“CCPA”) and the Personal Information Protection and Electronic Documents Act (“PIPEDA”). It applies to all players using The Win Zone, operated by playSWEEPS, LLC (“playSWEEPS”).

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What Can You Find in this Notice?

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This Notice tells you, among other things:

• What Personal Data we collect about you and how we obtain it;

• The bases for processing your Personal Data;

• For what purposes we use that Personal Data;

• How long we keep your Personal Data;

• With whom we share your Personal Data;

• Your rights about the Personal Data we collect about you and how you can exercise those rights;

• How we protect your Personal Data; and

• How to contact us.

 

Who Decides How Your Data Is Used?

 

Within the scope of this Notice, playSWEEPS, LLC is the organization that decides how and why Personal Data is collected, used, and protected by us. In legal terms, we’re the "data controller” or “business”.

 

Why We Use Your Personal Data?

 

We only use your Personal Data when we have a valid reason to. These are the main reasons we might use your Personal Data:

• Yourt Consent: In certain situations where the applicable law requires so, we will ask for your permission before using your data. For example, this might happen if:

  • We’re asking for your location.

  • We’re sending you marketing emails and you’re not already a player.

  • We’re conducting profiling that could significantly affect you or is based on sensitive data.
    You can change your mind about giving consent anytime, but this won’t undo actions we’ve already taken with your data.

• Fulfilling Our Agreements: To deliver the services, we need certain Personal Data from you. Without it, we wouldn’t be able to create and manage your account, process your prize redemptions, or provide support, for example. This information is essential for fulfilling the agreements we may have with you. If you choose not to provide the necessary data, we may not be able to offer some or all of our services.

• Our Business Needs (Legitimate Interests): We sometimes use your information for reasons that help us run and improve our services without needing your consent. This includes, for example:
  Our Business Needs (Legitimate Interests): We sometimes use your information for reasons that help us run and improve our services without needing your consent. This includes, for example:

  • Improving Our Services: Making the game better and easier to use.

  • Keeping You Informed: Sharing updates about features, new content, or things you might like.

  • Advertising and Promotion: Showing you ads or recommendations based on your activity in the game. This may include:

    • Cross-context behavioral Advertising and Targeted Advertising: Using your Personal Data to show you relevant ads across different websites and platforms. You can opt out of the use of cookies for analytics purposes by adjusting your preferences through our cookie banner.

    • Profiling: Using non-sensitive data, such as your gameplay behavior or purchase history, to offer personalized recommendations (like showcasing games you might enjoy), adjust max wager limits in games, send out marketing messages, and give access to offers, and enhance your gaming experience. We do not use sensitive personal information or fully automated profiling to make decisions that would significantly affect you. We do not use demographic data to build user profiles.

  • Analytics: Understanding how you interact with the game to improve its features and functionality. We do not infer sensitive traits from your behavior and Personal Data. You can opt out of the use of cookies for analytics purposes by adjusting your preferences through our cookie banner.

  • Safety and Fraud Prevention: Protecting your account and our services from security risks, and carrying out due diligence and verification processes for security purposes.

  • Running Our Business: Managing everyday operations to ensure the game works smoothly.

  • Legal Compliance: We process your data to meet legal and regulatory requirements, such as:

    • Verifying your identity, age, and location to ensure eligibility for prize redemptions.

    • Keeping accurate records for tax and other compliance purposes.

    • Performing due diligence and security checks to prevent fraud and unauthorized access and comply with our data security obligations.

  In some cases, we will give you opt-out options instead of asking for your consent. For example, we might use your data for marketing, advertising or analytics, but you can opt out of these activities if you prefer.

  • Complying With Applicable Law: We may process your Personal Data to comply with applicable law, such as keeping records of your cookie consent choices to comply with applicable cookie consent rules and regulations (e.g., various U.S. state and Canadian data protection laws), and carrying out due diligence and verification processes for legal compliance.

 

What Personal Data Is Processed to Run The Win Zone

 

The table below describes the categories of Personal Data involved in operating The Win Zone, distinguishing between data collected and maintained by service providers and data collected, maintained by playSWEEPS.

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Processing Alternative Method of Entry Submissions (AMOEs)

 

We use Octacom to receive, process and validate all alternative method of entry submissions (“AMOEs”). They scan all AMOEs and store a digital copy of the information on the front and back of the envelope and the AMOE postcard. Octacom will provide us with the first, middle and last name, email address, unique identifier, and one-time request code or each AMOE.

 

To learn more about the information collected, processed and maintained by our AMOE processor Octacom, read their privacy statement here.

 

Cookies and Other Tracking Technologies

 

To provide you with the best possible experience on our website and services, we use cookies and other tracking technologies. These tools help us understand how you interact with our platform, remember your preferences, ensure the website functions smoothly, and personalize your experience. Some of these technologies are necessary for essential website functionality, while others are used to enhance your experience, such as delivering targeted ads or collecting usage analytics.

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In addition to the cookies and trackers we manage directly (first party), third parties and service providers also place their own cookies and trackers on your device through our website. These third-party cookies allow our partners to provide services such as analytics, advertising, and geolocation. Below, you’ll find details about the main third parties and service providers we work with and links to their privacy policies, where you can learn more about how they collect and use your data:

• Google Analytics: Used for website analytics and reporting on user interactions. Learn more here.

• Braze: Facilitates in-app messaging and user engagement tracking. Learn more here.

• Radar: Provides geolocation tracking for compliance and user experience enhancement. Learn more here.

• Prizeout: Supports prize and cash redemption activities. Learn more here.

• AptPay: Manages financial transactions related to payouts. Learn more here.

• Socure: Facilitates identity verification through biometric and document processing. Learn more here.

• Pragmatic Play: Provider of slot games. Learn more here.

• Relax Gaming: Provider of slot games. Learn more here.

• Booming Games: Provider of slot games. Learn more here.

• Google Ads: Used for delivering targeted advertisements and ad tracking. Learn more here.

• Meta Ads: Facilitates targeted advertising and engagement through social media platforms. Learn more here.

• Singular: Provides marketing analytics and attribution services. Learn more here.

 

Cookies: A “cookie” is a small file stored on your device that contains information about your device. We use cookies to provide ads, website functionality, authentication (session management), usage analytics (web analytics), to remember your settings, and to generally improve our websites and services.

 

These are the cookies we use on the website. The list is updated automatically from time to time:

If you would prefer not to accept cookies, you can adjust your cookie settings by clicking on the button below, or change the setup of your browser to reject all or some cookies. Note, if you reject certain cookies, you may not be able to use all features of our services. For more information, please visit https://www.aboutcookies.org/.

 

Cookie Settings

 

Local Storage Objects:

 

These objects are used to store information directly on your device to enhance your experience on our website and ensure continuity across sessions:

• ab.storage.deviceId.[uniqueID]: Stores a unique device identifier to track user activity across sessions and personalize services.

• ab.storage.userId.[uniqueID]: Stores a unique user ID to personalize user sessions and experiences across visits.

• fedops.logging.sessionID: Tracks performance metrics and user interactions for debugging and optimization.

• identifier: Maintains a unique identifier for specific user-related tracking purposes, such as authentication or personalization.

• loyalty-path-origin: Tracks referral sources or paths to provide rewards or bonuses for specific campaigns.

• radar-devicID: Stores device-related geolocation identifiers for compliance with location-specific restrictions.

• radar-installID: Tracks app installation data to improve user engagement metrics.

• radar-sessionID: Identifies sessions for accurate geolocation tracking.

• ab-storage.events.[uniqueID]: Logs in-app events, like clicks or actions, for analytics and campaign performance monitoring.

• ab-storage.brazeSyncRetryCount.[uniqueID]: Tracks retry attempts for syncing data with Braze, ensuring messaging reliability.

• ab-storage.globalRateLimitCurrentToken.[uniqueID]: Monitors and regulates data requests to prevent overloading systems.

• ab-storage.lastReqToEndPoint.[uniqueID]: Tracks the last data request for synchronization or analytics purposes.

• ab-storage.messagingSessionStart.[uniqueID]: Records the start of messaging sessions to optimize communication timing.

• ab-storage.requestAttempts.[uniqueID]: Logs request attempts for troubleshooting and optimization.

 

Session Storage Objects

 

These objects store temporary data to manage user interactions and session-specific activities. They expire when the session ends:

• AI_buffer_1: Temporarily stores AI-generated recommendations or analytics results to enhance user experience.

• AI_sentBuffer_1: Tracks AI-driven messages or prompts sent during the session for monitoring delivery and user interaction.

• loyalty-logger-session-id: Records loyalty program activity during the session to ensure accurate tracking and rewards.

• prevPageVisitData: Tracks data about the last visited page to streamline navigation or personalization.

• ab.storage.sessionId.[uniqueID]: Maintains the session state for consistent functionality.

• bSession: Tracks session-level activity for analytics or application functionality, expiring with the session.

 

How We Respond to Opt-Out Signals

 

You may also set your browser to send a Do Not Track (“DNT”) signal or Global Privacy Control (“GPC”) signals. For more information, please visit https://allaboutdnt.com/ and https://globalprivacycontrol.org/. Please note that our website has the capability to respond to GPC signals received from web browsers, and we have configured our cookie consent management platform to respect DNT and GPC where required. However, please note that the technology to detect whether a website honors DNT and GPC signals does not always work as intended.

 

For What Purposes Do Use Your Personal Data?

 

We may process your Personal Data for the following purposes:

• Account Management: Creating and registering player accounts directly with The Win Zone and facilitating logins/authentication via The Win Zone or third-party platforms like Google, Facebook, and Apple.

• Verification: Ensuring identity, age, and location verification before redeeming prizes, creating accounts, or accessing age- or location-restricted content. This includes meeting Know Your Customer (KYC) obligations and complying with legal requirements.

• Game Customization: Enhancing your gaming experience by tailoring gameplay based on geographic location, device type, and player settings. This includes profiling based on gameplay behavior and achievements to offer personalized tips, adjust max wager limits, recommendations, or game content.

• Game Progress Tracking: Logging player actions to monitor game progress, unlock levels or rewards, and track achievements. We also provide analytics and personalized feedback about your in-game achievements.

• Prize and Cash Redemption: Facilitating cash redemptions via third-party payment providers like Paysafe, Apt Pay, and Prizeout. We also track prize redemption history for auditing, compliance, and fraud prevention purposes.

• Purchases and Transactions: Supporting in-game purchases, refund mechanisms, and chargeback processes. You can track your spending, and we may analyze or profile spending behavior to improve in-game offers and user experience.

• Social Features: Allowing players to share achievements with others through social sharing tools provided within the game.

• Analytics: Tracking gameplay activity to improve our services. This includes debugging, product optimization, CRM messaging, offering loyalty/retention/bonus incentives, analyzing player churn, monitoring game performance, and identifying crash issues.

• Security and Fraud Prevention: Protecting accounts and services by tracking prize redemption history, detecting and preventing fraud, and suspending or blocking accounts for security purposes. Profiling may be used for fraud detection and account security.

• Advertising: Displaying targeted ads based on in-game activity and previous play history across PLAYSTUDIOS games. This includes:

  • Counting ad impressions for frequency capping.

  • Promoting The Win Zone and PLAYSTUDIOS games outside the game.

  • Profiling gameplay activity to deliver relevant, personalized advertisements.

• Marketing: Delivering personalized in-game or email marketing messages, including promotional offers based on player activity and preferences.

• Player Support: Managing customer support inquiries and feedback via Helpshift, social media (e.g., Facebook, Instagram, TikTok, Discord), and in-game support to resolve issues and improve the player experience.

• Communications: Sending in-game surveys, feedback requests, and notifications or alerts about your account or game features or updates.

• Record Keeping for Disputes: Retaining purchase data to resolve disputes, investigate complaints, and defend against legal claims.

 

How Long We Keep Your Personal Data

 

We keep your Personal Data for as long as necessary to meet the purpose it was collected for and any related legal or business needs. If you have an active account with us, we retain your Personal Data while your account remains active. However, even if you close your account, we may need to keep certain information to:

• Follow legal requirements (e.g., keeping specific records for tax or regulatory compliance).

• Keep purchase-related data for up to 6.5 years to handle disputes or legal claims.

• Enforce our agreements and policies.

 

If your data is used for more than one purpose, we will keep it until the purpose with the longest retention period is complete, while stopping its use for shorter-term purposes as they expire. Our retention timelines follow our business needs, legal obligations, and industry best practices.

Some of your Personal Data may also be stored in backup systems. This data will only be deleted or overwritten later as part of our regular backup schedule, in compliance with applicable laws.

Disclosing Personal Data with Service Providers and Third Parties

 

We strive to provide a comprehensive and transparent overview of the third parties and service providers we work with. The following table describes the categories of personal data we disclose to service providers for business purposes and the categories of those service providers. It also outlines the categories of information we sell or share (as defined under the CCPA) with third parties, and the categories of those third parties.

 

Please note that this list does not include the categories of personal data collected by other entities, such as social media platforms (e.g., Facebook, TikTok, Discord), when you visit their platforms or use their services. Similarly, it does not cover data collected by providers of Single Sign-On (SSO) services (e.g., Google, Facebook, Apple) when you link or create your account with us through their platforms.
While we make every effort to name the specific third parties and service providers we work with, this list may be updated from year to year to reflect changes in our partnerships and service arrangements.

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We may disclose your Personal Data to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings.

 

We may also disclose your Personal Data if we sell or transfer all or some of our company’s business interests, assets, or both, or in connection with a corporate restructuring.

 

International Transfers of Your Personal Data

 

We are a company in the United States of America, and our affiliates, our service providers and other third parties with whom we share Personal Data with, operate globally. This means that your Personal Data may be transferred outside your country, state, province or territory.

 

When you use the Services, certain third parties and service providers may collect Personal Data about your online activities over time and across different websites or online services. Please refer to the policies of these third parties and service providers to learn more about the way in which they collect and process information about you.

 

What Privacy Rights Do You Have?

 

Under applicable laws, you may have specific rights regarding your Personal Data’s uses controlled by us. In this section, we describe those rights.

 

In the next section, we explain how you can exercise them.

 

Right to Know What Happens to Your Personal Data

 

This is called the right to be informed. It means that you have the right to obtain from us information regarding our data processing activities that concern you, such as how we collect and use your Personal Data, how long we will keep it, and who it will be shared with, among other things.

We provide this information in this Privacy Notice and our cookie preference center.

 

Right to Know What Personal Data We Have About You

 

This is called the right of access. It allows you to:

• Confirm whether we process Personal Data about you.

• Request details of the Personal Data we hold and related information (e.g., its sources, purposes of processing, and the categories of third parties with whom we share it).

• Obtain a copy of your Personal Data or access it.
  For security and compliance reasons, we cannot disclose certain sensitive details (e.g., Social Security numbers, driver’s license numbers, financial account details, or passwords). However, we can let you know if we hold this type of information.

 

Right to Change Your Personal Data

 

This is called the right to rectification. If you believe the Personal Data we hold is incorrect or incomplete, you can ask us to correct or update it without undue delay.

 

If you can’t make the change yourself through your account settings, please contact us via Helpshift, and we’ll assist you.

Right to Delete Your Personal Data

 

This is called the right to erasure, deletion, or the right to be forgotten. You can request that we delete your Personal Data, which usually involves deleting your account.

 

Sometimes we cannot delete your data for technical or legal reasons. If that’s the case, we’ll consider limiting how we use it and explain our reasons for denying your request.

 

Right to Ask Us to Limit How We Process Your Personal Data

 

This is called the right to restrict processing or the right to limit the use of certain personal data. It allows you to ask us to only use or store your Personal Data, especially sensitive Personal Data, for certain purposes, particularly if you believe it’s inaccurate or if processing it is unlawful.

This right applies in specific circumstances. If you wish to exercise it, please contact us at privacy@thewinzone.com.

 

Right to Ask Us to Stop Using Your Personal Data

 

This is called the right to object. This is your right to tell us to stop using your Personal Data. You have this right where we rely on a legitimate interest of ours (or of a third party). You may also object at any time to the processing of your Personal Data for direct marketing purposes. To exercise this right in relation to email marketing, look for the “Unsubscribe” option in our emails.

 

We will stop processing the relevant Personal Data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, or freedoms; or (ii) we need to continue processing your Personal Data to establish, exercise, or defend a legal claim.

 

Right to Port or Move Your Personal Data

 

This is called the right to data portability. It is the right to ask for and receive a portable copy of your Personal Data that you have given us or that you have generated by using our Services, so that you can:

• Move it;

• Copy it;

• Keep it for yourself; or

• Transfer it to another organization.

 

We will provide your Personal Data in a structured, commonly used, and machine-readable format. To exercise this right, request a copy of your Personal Data via our form.

 

Right Related to Automated Decision Making

 

We sometimes use computers to study your Personal Data. We might use this Personal Data, so we know how you use our Services. For some decisions that may seriously impact you, you have the right not to be subject to automatic decision-making, including profiling. But in those cases, we will always explain to you when we might do this, why it is happening and the effect.

 

To turn off personalized advertising based on information obtained through cookies on our website, please change your cookie settings by clicking below:

 

Cookie Settings

 

Right to Withdraw Your Consent

 

If we process your data based on your consent, like your consent to receive email marketing from us, you may withdraw that consent at any time.

 

Any processing conducted before your withdrawal remains lawful.

 

If your consent involves sharing data with a third party, you’ll need to contact them separately to update your preferences.

 

Right to Non-Discrimination

 

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by law, we will not:

• Deny you goods or services;

• Charge you different prices or rates for goods or services;

• Provide you a different level or quality of goods or services; or

• Suggest that you receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Your Right to Opt Out of the Sale and Sharing of Personal Data

You may have the right to ask us not to sell or use your Personal Data for cross-context behavioral advertising at any time, referred to as the right to opt out. To exercise the right to opt out (if applicable), please change your cookie settings by rejecting targeting cookkies below:

Once you make an opt-out request, we will not ask you to reauthorize the use of cookies potentially involved in sales or sharing of your Personal Data for at least twelve months. However, if you change your mind (for example, you prefer seeing relevant ads), you may opt back into Personal Data sales by enabling advertising cookies,

 

Your Right to Opt Into the Sale or Sharing of Personal Data

 

If you previously directed us not to sell your Personal Data, you can opt back in at any time by readjusting your cookie settings.

 

How Can You Exercise Your Privacy Rights?

 

To exercise any of the rights described above, please submit a request by either:

1. (RECOMMENDED) Filling out this online form.

2. (RECOMMENDED) Contacting us via Helpshift for requests to correct Personal Data or assistance with unsubscribing from email marketing.

3. Contacting us by email at privacy@thewinzone.com

4. To exercise your right to opt out of/opt into sales or sharing of Personal Data, reject or accept advertising cookies:

 

Verification of Your Identity

 

To protect your data and account, we may need additional information to confirm your identity. Our web form outlines the details required.

 

We will only use the Personal Data you provide us in a request to verify your identity or authority to make the request.

 

Verification of Authority

 

If you are submitting a request on behalf of somebody else, we will need to verify your authority to act on behalf of that individual. When contacting us via the webform, please provide us with proof that the individual gave you signed permission to submit this request, a valid power of attorney on behalf of the individual, or proof of parental responsibility or legal guardianship. Alternatively, you may ask the individual to directly contact us by using the contact details above to verify their identity with playSWEEPS and confirm with us that they gave you permission to submit a request on their behalf.

 

Response Timing and Format of Our Responses

 

We will confirm the receipt of your request within statutory time limits, and, in that communication, we will also describe our identity verification process (if needed) and when you should expect a response, unless we have already granted or denied the request.

Please allow us up to a month to reply to your requests (except requests to stop selling your Personal Data) from the day we received your request. If we need more time (up to 90 days in total), we will inform you of the reason why and the extension period in writing.

If we cannot satisfy a request, we will explain why in our response.

 

Fees

 

We generally don’t charge fees for handling your requests. However, if a request is excessive, repetitive, or unfounded, we may charge a fee and will inform you beforehand.

 

Artificial Intelligence (AI), Your Personal Data, and Your Rights

 

playSWEEPS uses AI systems from reputable third-party service providers to enhance your experience, improve security, and ensure legal compliance. For example:

• AI systems analyze behavioral patterns to:

  • Identify potentially suspicious activities.

  • Protect users and the platform from fraud and malicious actions.

• AI helps verify user identity during account creation or prize redemption. For example: Socure uses AI to analyze identity documents and detect fraud, ensuring compliance with Know Your Customer (KYC) obligations.

• AI-powered geolocation tools, such as those provided by Radar, determine your location to:

  • Enforce jurisdictional restrictions.

  • Confirm prize eligibility in compliance with local laws.

• AI is used to analyze gameplay data, such as achievements, preferences, and engagement, to:

  • Customize your experience by providing personalized offers.

  • Suggest relevant games and content.

  • Track progress for a seamless gaming experience.

• AI technologies help deliver:

  • Targeted notifications and personalized offers.

  • In-game and email communications tailored to your activity, preferences, and interactions.

• AI-driven tools assist in:

  • Managing support tickets.

  • Providing automated responses to common inquiries.

  • Routing complex issues to the appropriate support team members.

  • AI technologies help deliver:

 

No sensitive personal data, such as biometric or geolocation data, is used to train AI models directly by playSWEEPS.

 

If you have questions or concerns about how decisions involving AI may have impacted you, please feel free to reach out for clarification or assistance. You can contact us using the details provided in the Contact Us section.

 

Privacy of Children

 

The Services are not directed at, or intended for use by, children under the age of 13.

 

Data Integrity & Security

 

We are strongly committed to keeping your Personal Data safe. We have implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect your Personal Data from unauthorized processing. Unauthorized processing includes unauthorized access, exfiltration, theft, disclosure, alteration, or destruction. Some of those measures include access controls, maintaining audit logs, tracking user updates or deletions of their personal data, using state-of-the-art encryption both in transit and at rest and using reputable vendors only. We also have a dedicated team to look after privacy.

 

Changes to this Notice

 

If we make any material change to this Notice, we will post the revised Notice to this web page and notify our players. We will also update the “Effective” date. By continuing to use our Services after we post any of these changes, you accept the modified Notice.

 

Contact Us

 

If you have any questions about this Notice or our processing of your Personal Data, or want to submit privacy rights requests, please use the contact details.