Privacy Policy

LAST Updated: September 1, 2025

Lucky Link Ltd. owns and operates this platform. We respect your privacy and recognize your right to understand why we collect your personal data and how it is used. This Privacy Policy governs the information we gather through our platform, as well as information collected offline. It outlines the types of data we may collect from you when you access or use our website and/or mobile applications, or voluntarily provide to us.

We are committed to protecting your Personal Information and keeping it secure. We implement commercially reasonable measures—physical, electronic, and administrative—to safeguard the Personal Information we collect. These measures include restricting physical access to database servers, using electronic security systems, and employing password protections to prevent unauthorized access. All payment transactions are processed by our third-party payment providers, meaning we do not have access to your credit card numbers or other financial information.

While we take significant steps to protect your data, no method of transmission over the Internet can be guaranteed as fully secure. You assume the risk when transmitting Personal Information via our Sites. We cannot guarantee that third parties will not intercept your information, and we are not liable for any breaches of security caused by factors beyond our control, including, but not limited to, user actions, storage media corruption, third-party security failures, power outages, natural disasters, riots, vandalism, hacking, sabotage, terrorism, or unauthorized circumvention of any security measures or privacy settings on our Sites.

INFORMATION WE COLLECT

The Personal Information we typically collect includes:

• Contact information: such as name, email, telephone number, address, VIP level, and occupation;
• Account details: including your user ID and password;
• Personal attributes: such as date of birth, gender, age, and purchase history;
• Preferences: including wish lists, marketing preferences, and reasons for requesting free SC coins.

We generally collect this information directly from you, for example when you:

• Make purchases online;
• Communicate with us via email or other channels;
• Join our social networking platforms;
• Register for an account;
• Participate in promotions, surveys, or contests;
• Play our social games.

HOW WE USE YOUR INFORMATION

We may use your Personal Information in the following ways:

• When you have given consent or requested its use;
• To fulfill contractual obligations with you;
• To serve legitimate business interests, provided that your fundamental rights are not overridden;
• To comply with applicable laws or regulatory requirements.

SHARING PERSONAL INFORMATION WITH THIRD PARTIES

We prioritize your trust and aim to be transparent about the circumstances under which your Personal Information, and information we collect about you, may be shared. Except as described in this Policy, we do not disclose your Personal Information to any third parties.

Your Personal Information may be shared with external individuals or organizations that assist us in delivering our products and services, as well as in creating, operating, and maintaining our Sites. Such third-party support may include, but is not limited to:

• Managing customer information databases;
• Assisting with email distribution;
• Supporting direct marketing and data collection;
• Providing data storage and analytical services;
• Offering fraud prevention solutions;
• Delivering customer support;
• Handling order fulfillment and delivery;
• Performing other services that help us operate our Sites effectively and optimize our business operations.

All third-party partners are required to maintain the confidentiality of the information shared with them and to use it solely to fulfill their obligations on our behalf.

In the event of business transactions such as seeking investors, mergers, acquisitions, or the sale of all or part of our assets, your Personal Information may be included in the negotiations and may be transferred as part of the business assets if a transaction occurs.

Additionally, we may disclose your Personal Information when required by law, to comply with legal or regulatory processes, to cooperate with law enforcement investigations, to prevent misuse or unauthorized access to the Sites, to limit our liability, to protect our rights, or to safeguard the rights, property, or safety of our users or the general public.

TARGETED ADVERTISING AND REMARKETING

We may display advertisements for our products or services on third-party websites and mobile apps. We partner with advertisers to conduct remarketing and retargeting, enabling interest-based, demographic, and contextual ad targeting. These third-party advertisers may track your activity online, across multiple websites and apps, using automated technologies such as cookies, web beacons, and server logs. They may collect information about your interactions with ads, pages visited, and other online behaviors to provide tailored advertising and evaluate marketing effectiveness.

OTHER WEBSITES

Our Sites may include links to or references from third-party websites, or you might arrive at our Sites via a link from another website. This does not imply that we endorse these external sites, their products, or services. We make no representations or warranties regarding any third-party websites linked to our Sites. These external websites operate independently, and we have no control over, and accept no responsibility for, their content, products, or activities. Their privacy practices may differ from ours. If you provide Personal Information on such third-party websites, it will be governed by that site's privacy policy, not ours. Please review the privacy policy of any external website before sharing your Personal Information.

If you access our Sites or your account using a third-party service (such as Facebook, Google+, or Twitter), your activities on those platforms are governed by the privacy practices of those services. We have no control over how these services operate or handle the data they collect.

LEGAL DISCLOSURES

You authorize us to disclose your Personal Information when required by law, in response to judicial or administrative proceedings, or to law enforcement or governmental authorities. Additionally, we may disclose your Personal Information if we believe it is necessary to investigate suspected illegal or improper conduct on our Sites, including, but not limited to, fraud, misrepresentation, intellectual property violations, or any activities that may expose us to legal liability.

RIGHT OF ERASURE

You may request the deletion of your Personal Information where there is no compelling reason for us to continue processing it. This right is subject to certain conditions and is not absolute. To request erasure of your data, please contact us via email.

CHILDREN

We do not knowingly permit individuals under the age of 18 to use our Sites, nor do we knowingly collect Personal Information from them. If we discover that we have inadvertently collected information from a child under 18, we will take reasonable steps to delete it from our records.

CALIFORNIA PRIVACY

These California-specific privacy disclosures ("CA Disclosures") apply only to residents of California and supplement our main Privacy Policy. They provide additional details regarding how we collect, use, and disclose personal information under the California Consumer Privacy Act (CCPA). Terms not specifically defined in this section retain the meanings given in our Privacy Policy or under the CCPA. For these purposes, "personal information" has the meaning defined by the CCPA and excludes publicly available, de-identified, aggregated, or CCPA-exempt information. This section does not apply to information about our employees, contractors, or other personnel.

California residents may have the following rights, subject to legal limitations:

• Right to Know: Request details about personal information we collected or disclosed in the past 12 months, including:
  • Specific personal information collected;
  • Categories of personal information collected;
  • Sources of personal information;
  • Categories of personal information disclosed to third parties and recipients;
  • Categories of personal information sold and third parties to whom it was sold;
  • Business or commercial purposes for collecting or selling personal information.
• Right to Delete: Request deletion of personal information, subject to certain exceptions. Please note that deletion may affect your access to some services.
• Right to Opt-Out: Opt out of the sale of your personal information to third parties now or in the future.

CONFIDENTIAL INFORMATION

Do not send confidential or proprietary information to us via email or other means. Any ideas, suggestions, comments, or materials you provide will be treated as non-confidential. By submitting them, you grant us the unrestricted right to use, modify, reproduce, transmit, display, and distribute the information for any purpose, without compensation. We will not attribute your name unless legally required or unless we obtain your consent.

CONTACT

For questions regarding privacy or security, or to update your Personal Information, please contact us at: [email protected].