Privacy Policy

PLEASE READ THIS PRIVACY POLICY AND THE WINCITY/KOOLBIT TERMS OF SERVICE PRIOR TO USING, ACCESSING, OR DOWNLOADING ANY WINCITY LLC WEBSITE, APPLICATION, OR SOFTWARE, including 1Up Casino Slot Machines, Slots to Vegas: Slot Machines, and Slots Boss: Tournament Slots.
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WINCITY, LLC, a subsidiary of Koolbit, Inc., develops and publishes digital services and social games for the web and mobile devices. “WinCity,” or “we” or “our” or “us” refers to WinCity, LLC., and any of its affiliates, subsidiaries and/or its parent company, Koolbit (collectively, “WinCity”).

This Privacy Policy applies to each WinCity website, application and software that links to this Privacy Policy (collectively, the “Service”). This includes, 1Up Casino Slot Machines, Slots to Vegas: Slot Machines, and Slots Boss: Tournament Slots. These applications may be available through social networking or other mobile platforms, including Google Play and the Apple App Store, and software or games that we allow you to download.

NOTE: THIS WEBSITE AND THE SERVICES PROVIDED HEREIN DO NOT OFFER "REAL MONEY GAMBLING" OR AN OPPORTUNITY TO WIN REAL MONEY OR PRIZES BASED ON THE OUTCOME OF PLAY.

WinCity ("WinCity") is committed to protecting the privacy of its users ("users" or "you"). This Privacy Policy explains the information we collect, and how we collect, use and, in certain circumstances, share your information in connection with the Service we provide you. 

Please read this Privacy Policy carefully before using the Service, and if you have any questions, feel free to contact us support@koolbit [dot] com.

By using the Service, you agree to the collection and use of your personal information as outlined in this Privacy Policy. WinCity may amend the Privacy Policy from time to time, and WinCity encourages you to consult the Privacy Policy regularly for changes. We automatically collect some information when you access the Service and collect other information when you voluntarily submit it to us. If you elect not to provide certain information, you may be precluded from participating in some of the Services.

Information Collected by WinCity
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WinCity 's primary objective in collecting user information is to provide and enhance the Service and to enable users to enjoy the Service.
When you install any of the Services, WinCity may collect and record the information you provide to WinCity, whether through the Services or through social network or other third party services ("Account Information").

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

Passive Information
Passive information refers to information that is automatically collected from your device(s) when you access the Website or Apps and use the Services. WinCity may collect passive information such as your IP address, referral data, browser type, browser language, platform type, type of mobile or other computing device, and geographical data, such as zip code and geographic location. Your browser or device typically sends passive information to our servers without your intervention whenever you visit our Website or Apps and use the Services. For example, your browser or device may tell us your IP address (which may tell us generally where you are located) and the type of browser and device you are using. When you visit our Website or Apps, your browser may also tell us information such as the page or link that led you to our Website or Apps and, if applicable, the search terms you typed into a search engine that led you to our Website or Apps.

Cookies
While you are using the Services, we may seek to place a "cookie" (a small data file) or other tracking technology on your mobile device, computer or other participating device. If you access our Website, Apps or Services via a Partner Site, the Partner Site may also place cookies on your device as permitted by the terms of the agreement and your privacy settings with the Partner Site. Cookies placed by us are not used to obtain any personal data, and the information that is tracked is used only for internal purposes, such as to improve the Services. If you prefer not to accept cookies, you can set your web browser on your computer or device to reject them or to alert you before one is placed. Be advised, however, that some of our features and services may not function properly if you disable cookies.

Links
The Service may contain links to other websites or applications. The fact that the Service links to a website or application or presents a banner ad or other type of advertisement does not mean that WinCity endorses or authorizes that third party, nor is it a representation of any affiliation with that third party. If you click on a link to a third party site or application, including on an advertisement, you will leave the WinCity site you are visiting or application you are running and will go to the site or application linked to. These third party websites and applications may place their own cookies or other files on your computer or mobile device, and may collect data or solicit personal information from you. Other sites and applications follow different rules regarding the use or disclosure of the personal information you submit to them. Because WinCity cannot control the activities of third parties, it cannot accept responsibility for any use of your personal information by such third parties, and it cannot guarantee that they will adhere to the same privacy and security practices as WinCity. You are therefore encouraged to read the privacy policies or statements of other websites and applications you visit before providing any personal information.

Personal Information
Personal information means information that is specific to you and can be used to contact or identify you. By accessing the Service through a social network, mobile device or other third party platform or service or by connecting to such a third party network, platform or service via a Service, you are authorizing WinCity to collect, store, and use in accordance with this Privacy Policy any and all information that you agreed the social network, mobile device or other third party platform could provide to WinCity through the social network/mobile device/third party platform Application Programming Interface (API) based on your settings on the third party social network, mobile device or platform.

Your agreement takes place when you connect with the third party network, platform or service via the Service, and/or when you connect with a Service, or “accept” or “allow” (or similar terms) a Service to access your information through a social network, mobile device or other third party platform or service. If you choose to access the Service by using your Facebook account as your login, we may receive from Facebook certain categories of personal information about you that you authorize Facebook to disclose, such as your user name, date of birth, friend list, email address and profile picture, or you may voluntarily disclose information such as your gender or your play preferences to us through your use of the Services. Any information directly collected through your Facebook account and shared with us will be imported, used and stored in a manner consistent with the Facebook Platform Policy applicable to developers in effect at the time of collection (see https://developers.facebook.com/policy/) and in compliance with any specific privacy settings set by you of which we are aware.

We may also collect certain categories of personal information from vendors that help us to operate the Website and Apps and provide services such as processing credit card payments and sending emails on our behalf. For example, we may receive confirmation that you have made a payment by credit card and other information related to any of your gaming transactions associated with your use of the Services. To help keep our databases current and to provide you the most relevant content and experiences, we may combine personal information from you with information from public sources and our trusted partners, in accordance with applicable law and this Privacy Policy.Please note that because a third-party vendor manages your purchases of virtual currency for use the Services, we do not have access to your credit card or billing information. Be advised that this Privacy Policy does not apply to this and other third-party vendors.

ONLINE ADVERTISING

Third Party Advertising
WinCity permits third parties to place advertisements on our properties, including our Websites, Apps and the Services. When advertisers or advertising networks place advertisements on WinCity properties, they may collect or we may share the following types of information from within our properties:
• Performance data (like the number of clicks on an advertisement);
• Aggregated and/or de-identified information about you and other players collectively that is not intended to specifically identify you
• Certain technical information (for example, IP addresses, non-permanent and anonymous device identifiers such as Apple Identifier For Advertisers (IDFAs), and Google Advertising ID);
• Your social network ID;
• Other contextual data about your game play (for example, games played and session length).
After clicking on a third-party advertisement, you may no longer be on a website or other property hosted by WinCity or the social network through which you are playing our games. Be advised that any personal information that you disclose in connection with a third-party online advertisement is not governed by this Privacy Policy. See below for information on how to opt-out of being served online advertising by third parties.

Offer Walls
WinCity Services no longer display an "Offer Wall" hosted by a third-party provider. Past offer walls allowed third party advertisers to provide virtual currency to players in exchange for interacting with an advertisement or for completing a marketing offer that may have included signing up for an account with one of those advertisers. These offers are no longer available as part of our Services.

HOW YOUR INFORMATION IS USED

Use of Personal Information
WinCity will use personal information in the following ways:
• To fulfill your requests for our Services;
• To process and respond to your inquiries;
• To improve the Services, including diagnosis or problems with the Services;
• To help us better understand demographic characteristics of our users;
• To present advertising that is tailored to your interests;
• To offer you other opportunities that we think may be of interest to you.If you enter into a sweepstake, contest, or similar promotion, WinCity may use the information you provide to administer those programs. Your participation in tournaments or other online game events is conditional upon you granting WinCity permission to collect, use, store, transmit and display publicly statistical data, such as your scores, rankings and achievements, generated through your participation.

Email and Push Notification Marketing
In addition, WinCity may use personal information to communicate with you through email regarding new products, new features, product updates, enhancements, special offers, or promotions for the application services. These communications may also include offers from WinCity marketing partners. Emails we send you may include a web beacon that tells us whether and at what time you have received or opened the email or clicked a link within the email. If you do not want us to use your personal information in this way, or to provide your personal information to third parties for their marketing purposes, please uncheck the appropriate box when you register or you can opt out by contacting us at support@koolbit [dot] com. You can also opt out by clicking on the “unsubscribe” button on the emails or turning off the WinCity application notifications in the Services on your smartphone. You can also unsubscribe to marketing messages at any time by clicking “unsubscribe” on the emails you receive from us or third parties.

Use of Passive Information
WinCity collects passive information for purposes of tracking and analyzing user preferences and trends in order to improve the quality and design of the Services and to create new features, promotions, and functionalities; for editorial and feedback purposes; for marketing and promotional purposes; for content improvement; and to customize the Services. This information may also be shared with advertisers and our business partners on an aggregated anonymous basis.

Use of Information Collected by Third Party Advertising
The information collected may be used to:
• Measure how effective advertisements are, to offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising);
• To analyze traffic and other player activity to improve your experience; and/or
• To engage in activities such as ad attribution, conversion events, estimating the number of unique users, advertising fraud detection, and debugging.
Advertisers or advertising networks may collect the foregoing information through the use of tracking technologies like tracking pixels, browser cookies, and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time.If you do not want to receive tailored in-application advertisements from third parties that relate to your interests in apps on your mobile device, you may opt-out by adjusting the ad tracking settings on your device. You can also reset the "Advertising Identifier" (like an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous "Advertising Identifier. "WinCity will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that WinCity no longer use your information contact WinCity at support@koolbit [dot] com. Note that there may be instances where WinCity is legally required to retain your information.

Third Party Service Providers
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WinCity may employ third party companies and individuals to facilitate its Services, to provide the Services on its behalf, to perform tasks (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Services) or to assist WinCity in analyzing how its Services are used.

From time to time, WinCity employs third party contractors to collect personal information on its behalf to provide email delivery, product, prize or promotional fulfillment, contest administration, credit card processing or other services through the Service. When requesting these services, you may be asked to supply your name or email address to its contractors. 

BUSINESS STRUCTURE CHANGES

We reserve the right to disclose and transfer all information related to our Sites, including personal data:
To a subsequent owner, co-owner, or operator of one or more of the Sites; orIn connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

Disclosure of Your Personal Information
You understand and agree that WinCity may be required to disclose any personal information if required to do so by law or in the belief that such disclosure is reasonably necessary to avoid liability, to comply with legal process, including, but not limited to a subpoena, statute, search warrant, or court order, or to protect the property and rights of WinCity or a third party, to protect the safety of the public or any person, or to prevent or stop activity WinCity may consider to be, or to pose a risk of being, illegal, unethical or legally actionable. Note that WinCity is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that it may receive. WinCity may also disclose information about you if it determines that such disclosure is reasonably necessary to enforce the terms and conditions of the Service or to protect its operations or users. Additionally, WinCity may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Managing Your Information
Access to and Ability to Correct Personal Information
If you have questions or requests about this Privacy Policy, you may contact us by e-mail at support@koolbit[dot]com. Upon request via email, we will provide you a summary of your personal information, if any, retained by us. We will respond to requests to correct, amend, delete, update or delete personal information that is inaccurate within a reasonable timeframe. You can help us maintain the accuracy of your personal information by notifying us of any changes to your information. We will only send personal records to the e-mail address on file for the username associated with it.

Users may also modify, correct, change, or update their personal record through their Facebook account or request that their personal information be removed from our database.

Access Through Third-Party Sites
‍The privacy controls for your personal information that is transmitted to us from Facebook are managed through your Facebook account. You should carefully consider and establish your own privacy preferences for the Services through your Facebook account. We are not responsible for personal information, your profile, your location information or other information that you choose to disclose on the Services through synchronization with your Facebook account. Any personal data or other information obtained from your Facebook account will be shared publicly in the Services in accordance with the privacy settings you have applied to such data through your Facebook account.

Opt Out
‍If you wish to change how the personal information that you provide to Facebook is used by us, including opting out of using your personal information to send promotional messages to you, you may change your settings on your Facebook account or contact us at support@koolbit[dot]com.
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In the event you want to opt-out of WinCity marketing emails or texts, you may do so at any time by clicking on the unsubscribe links located within each WinCity email or turning off the application notifications on your smartphone for texts. You can also contact us via email at support@koolbit[dot]com.
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Please note that opting out may affect your ability to receive information from WinCity or to have access to all of the Services.

You may "opt out" of the use of your personal information for third party analytics purposes by emailing (using the same email address as when you registered) your request to support@koolbit[dot]com.
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Security
WinCity has made reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, WinCity cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so WinCity discourages you from sending WinCity personal information through these media.

When you sign into your WinCity account or enter payment information, we and our third-party payment processor use encryption to transmit that information.

How Long We Retain Your Information
How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.

We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.

Policy Regarding Persons Under 21
WinCity's slots games, “1Up Casino Slot Machines,” “Slots to Vegas: Slot Machines,” and “Slots Boss: Tournament Slots” are intended for use by those 21 or older for amusement purposes only. Without derogating from the foregoing, WinCity does not knowingly collect personal information from people under the age of 13. If WinCity learns that a person under the age of 13 has provided it with personal information, WinCity will take steps to delete such information as soon as possible.

USERS IN CALIFORNIA
California Do Not Track DisclosuresThe California Online Privacy Protection Act (“CalOPPA”) requires that online privacy notices disclose how a site responds to "Do Not Track" signals ("DNT"). We currently do not honor DNT signals.
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California “Shine The Light”
If you are a California resident, California Civil Code Section 1798.83 (“Shine-The-Light” law) permits you to request information regarding the disclosure of your personal information by us, or our subsidiaries or affiliates, to a third party for the third party’s direct marketing purposes. To make such a request, please contact us as provided below. Except as may be provided in this Privacy Policy, we do not trade, sell, lease or otherwise provide any personal information regarding our users to any third parties for their direct marketing purposes.

California Consumer Privacy Act (“CCPA”)
The California Consumer Privacy Act (as amended by the California Privacy Rights Act) (together, the CCPA) gives California consumers enhanced rights with respect to their personal information that is collected by businesses. The CCPA provides California consumers with three rights regarding their personal information. At or before the time of collection, you have a right to receive notice of our practices, including the categories of Personal Information and any sensitive Personal Information to be collected, the purposes for which such information is collected or used, whether such information is "sold or shared" as defined under the CCPA and how long such information is retained. You can find those details in this Privacy Policy.

First, California consumers can opt out of the sale or sharing of their personal information with third parties under certain conditions. See below for more information. Second, California consumers can request to know:
-What specific pieces of information a business has collected about the consumer;
-Categories of personal information it has collected about the consumer;
-Categories of sources from which the personal information is collected;
-Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
-Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
-The business or commercial purpose for collecting or selling personal information.
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Third, California consumers can request that a business delete personal information about the consumer that a business has collected from the consumer and, fourth, request that their personal information be corrected.

The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the CCPA.

In the preceding twelve (12) months we have: (1) collected the following categories of personal information; and (2) disclosed such categories of Personal Information for a business purpose. (For the categories of third parties with whom we may disclose or sell or share Personal information, please see the section above, “Information Sharing and Disclosure”.)

To make a “request to know” or “request to delete” your personal information, send us an e-mail at support@kooblit[dot]com.  Please put either “Request to Know” or “Request to Delete” in the subject heading of your email.

California consumers can use an authorized agent to submit a request on their behalf. We may request proof that the consumer gave the agent signed permission to submit the request.

We will confirm receipt of your request within 10 business days. We must provide the requested information or delete your personal information within 45 days of receipt of your request, but we can use up to an additional 45 days if we let you know that additional time is needed.

Also, before responding, we must verify that the person making the request is the person about whom we have collected their personal information. We may ask you to provide certain, limited personal information, such as your name and email address to verify and match your identity with our records and systems. If you have an account with us, we may ask that you verify your identity through our account authentication process. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose.

Also please be advised that we need to search our records and systems only for the preceding 12 months. There may be cases where we do not have any personal information about you or we are not able to verify your identity for matching purposes. Deleting your personal information may result in the closing of your account and inability to access certain areas of Website, Apps or Services. However, you can always re-register at any time.

WinCity does not sell any personal information to third parties for any purpose.

To make a “request to know” or “request to delete” your personal information, send us an e-mail at support@koolbit[dot]com.  Please put either “Request to Know” or “Request to Delete” in the subject heading of your email and indicate which of WinCity apps/websites pertains to your inquiry. Before responding, we must verify that the person making the request is the person about whom we have collected their personal information. Therefore, we may ask you to provide certain, limited personal information, such as your name and email address to verify and match your identity with our records and systems. If you have an account with us, we may ask that you verify your identity through our standard account authentication process. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months. There may be cases where we do not have any personal information about you or we are not able to verify your identity for matching purposes. Deleting your personal information may result in the closing of your account and inability to access the Services. However, you can always re-register at any time.

RESIDENTS IN OTHER STATES
‍Several other states have enacted consumer privacy laws similar to the CCPA. Like the CCPA, these other state consumer privacy laws may provide certain privacy rights to their residents. To the extent applicable, we will honor privacy rights requests under these other US state consumer privacy laws. Please email us at support@koolbit[dot]com.
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For EU and EEA Residents
For our users residing within the EU or EEA, please review the following:
Data controller. 
With respect to the data we collect about you through your use of our Services, we are the data controller.
Lawful bases.
When collecting, using, sharing, or otherwise processing data about you, we do so on the basis of your explicit consent, our need to fulfill this or a related agreement we have with you, including our Terms of Use, our or a third-party partner’s legitimate business interests, or to comply with our legal obligations, as applicable.
Cross-border transfers. 
As a California-based company, we store and use data outside the EU. To ensure adequate protection of personal data in cross-border transfer and/or processing, we use appropriate safeguards as allowed under applicable law or regulation.
Remedies. If you feel you haven’t received a timely or satisfactory response from us in connection to a question or complaint related to this Policy, you can raise the issue with your local supervisory authority without prejudice to any other rights you may have.