Introduction

REALPLAY TECH INC and its Related Entities including Realplay Ltd (“RealPlay”, “we”, “our” or “us”) provide the websites located at https://www.realplayltd.com/; https://lonestarcasino.com/ (“Websites”) and all of their subdomains, subpages and successor sites thereof and the “RealPrize” mobile application (“App”) through which the RealPrize Services are provided (together – the “Services”).

RealPlay also includes Realplay EU Ltd., which is located at Madison Building Midtown, Queensway, Gibraltar – GX11 1AA.

RealPlay is dedicated to protecting your privacy rights and making our practices regarding your personal information more transparent and fairer. Please read this policy, as it includes important information in respect of your personal information.

This Privacy Policy (“Policy”) is designed to help you understand how we collect, store, use and share your personal information. This Policy applies whenever you visit our Websites, install or interact with our App, or otherwise access or use any of our Services.

For individuals located in Canada, we handle personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, substantially similar provincial laws (Quebec, Alberta, and British Columbia). When personal information is collected from or transferred to jurisdictions outside Canada, we comply with additional obligations under Canadian law, including ensuring that such personal information is protected by appropriate safeguards and contractual measures, and that you are informed of such transfers and any associated risks. The Website/App may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read and understand the privacy policy of every third-party website and/or mobile application you visit.

This policy DOES NOT apply to information that:

• We collect offline or through any other means, including on any other company or third-party website.
• You provide to or is collected by any third party, through any application or content that may link to or be accessible from or on the Website/App.
• To online websites or services that we do not own or control, including websites or services of other users of our Services.

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time.

This Policy is integrated into and forms part of the LoneStar Casino Agreement.

For any questions or concerns, please contact us via our email address: support@lonestarcasino.com.

This Policy describes the following –

• 1. What types of personal information we collect
• 2. Tracking technologies
• 3. Why we process your personal information
• 4. With whom we share your personal information
• 5. Sources of personal information
• 6. Marketing and advertising
• 7. Your privacy rights
• 8. Transfer of personal information
• 9. How we protect your data
• 10. Minors
• 11. Retention
• 12. Updates to this Policy
• 13. Controlling version
• 14. Contact us

1  What types of personal information do we collect?

We collect personal information about you. Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information generally does not include business contact information, including your name, title, or business contact information. Account information:

If you decide to register an account with our Services, we may collect your full name, email address, country, phone number, user nickname, and optionally, your profile picture. If you choose to log in or access our Services through a social networking service (e.g., Facebook, Twitter, Instagram), we collect your user ID, username associated with the social networking service, and any information you make public using that service or that the service permits us to access.

1.1. Payment information:

Our third-party payment processors will collect the billing and payment information required to process your charges. This may include your postal address, email address, or payment information. Our payment processors may collect, process, store, and share information with us related to your purchases and withdrawals.

1.2. Usage information:

When you use our Services, we collect information about your interaction with our Services. Such information includes gameplay recordings, purchase history and data pertaining to your activities on our Services, as well as information generated when you interact with our App (for instance, how and when you use our App) and with the advertising served in our App (for instance, number of ads served, potential clicks).

1.3. Identifiers and technical information:

When you use our Services, we collect technical information such as IP address, your Mobile Advertising ID (such as Apple IDFA or Google AAID – which are technical identifiers created by mobile operating systems for advertising purposes, which you can control, reset, or erase through your device settings), device identifiers (e.g., IDFV for iOS devices and Android ID for Android devices), information about your device and connection, including user agent, connection type, timestamp, system language, device model, screen resolution and settings, battery level, available storage space, time zone, and operating system.

1.4. Communication information:

When you contact us via email or through the support channels in our App or Websites, we collect the personal information you provide, which include your name, email address, and any other information you choose to provide.

We do not knowingly collect, process or disclose any sensitive personal information.

2  Tracking technologies

When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies (“Tracking Technologies”). These Tracking Technologies 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 Services’ performance, perform analytics, customize your experience and offer you, for example, tailored content and advertisements that better correspond with your interests.

2.1. What types of Tracking Technologies do we use?

When you use or access our Services, we use the following categories of Tracking Technologies:

• (a) Strictly necessary Tracking Technologies: these Tracking Technologies are automatically placed on your computer or device when you access or take certain actions on our Services. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services.
• (b) Tracking and advertising Tracking Technologies: these Tracking Technologies collect information about your browsing habits in order to make advertising more relevant to you and to 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 publishers. Publishers, advertisers, and third-party ad networks 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 the Company does not control;
• (c) 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; and
• (d) Performance Tracking Technologies: these Tracking Technologies collect information about your online activity (for example the duration of your visit on 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).

2.2. How and by who are Tracking Technologies stored on your device?

We store Tracking Technologies on your device when you visit or access our Services – these are called “First Party Tracking Technologies”. In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners and advertisers), who run content on our Services – these are called Third-party Tracking Technologies. Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.

There are various ways in which you can manage and control your Tracking Technologies settings. You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). Other methods of managing your Tracking Technology preferences include changing your browser settings to send a “Do-Not-Track” signal. In such case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Services may not work properly or effectively if you delete or disable cookies.

Below is a list of useful links that can provide you with more information on how to manage your cookies:

• (a) Google Chrome;
• (b) Mozilla Firefox;
• (c) Safari (Desktop);
• (d) Safari (Mobile);
• (e) Android Browser; and
• (f) Microsoft Edge

You can learn more and turn off certain third-party targeting and advertising cookies by visiting the following third-party webpages:

• (a) The Interactive Advertising Bureau (EU); and
• (b) European Interactive Digital Advertising Alliance (EU)
• (c) The Digital Advertising Alliance of Canada (DAAC) AdChoices program
• (d) Network Advertising Initiative (NAI)

If you are accessing our services through a mobile device app, you can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:

• (a) On iOS, depending on the applicable iOS version, you may withdraw consent across all App by either enabling the “Limit Ad Tracking” setting or disabling the “Allow App 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 App that appear under the “Allow App to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).
• (b) On Android devices, you may 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).

3  Why we process your personal information

Any personal information we collect is being used in a way that is consistent with this Policy, and is used as follows:

4  With whom do we share your personal information?

All third-party service providers and partners with whom we share your personal information are contractually required to protect such information and to use it solely for the purposes specified by us and in accordance with applicable privacy laws. We ensure that these third parties are bound by confidentiality and data protection obligations that are no less protective than those set out in this Policy. We may share your personal information with:

4.1. Payment processors:

Third-party payment processors, for the purpose of facilitating your payments when using our Services. These third parties have access to your personal information, so they perform these tasks on our behalf.

4.2. Service providers:

Service providers working on our behalf and who need access to certain personal information in order to provide their services to us. These companies include, but are not limited to, cloud storage providers, analytics services, fraud prevention etc. Some service providers may be located outside your province or outside Canada. See Section 8 (Transfer of personal information).

4.3. Advertising partners:

Advertising partners to either display advertising on our Services or to manage our advertising on other websites or App. Our third-party advertisers use Tracking Technologies to gather information about your activities on our Services and other websites and App in order to provide you with advertising based upon your browsing activities and interests.

4.4. Third-party integrations:

Our Services allow you to integrate with certain third-party services, in order to connect your account to our Services or to place purchases (e.g., Apple, Google or Facebook accounts).

4.5. Law enforcement agencies:

We may disclose some data about you to government or law enforcement officials or private parties. The disclosure will be made in our sole discretion, as we believe it necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third-party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

4.6. Auditors and advisers:

We share your data with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers etc.) to ensure our compliance with regulatory requirements and industry standards, auditing, managing disputes etc.

4.7. Mergers and acquisitions:

We may transfer or otherwise share your data in case of entering into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.

In the 12 preceding months, we have collected, disclosed or shared the following categories of personal information:

5  Sources of personal information

The above-mentioned personal information was collected and obtained from the following categories of sources:

• Consumers directly;
• Advertising networks;
• Social networks;
• Payment processors;
• Analytics providers.

6  Marketing and advertising

We use your personal information ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, ads, products, services, websites and applications which relate to our affiliated companies or our business partners (collectively: “Marketing Affiliates”), which we believe may interest you.

You can decline receiving further marketing offers from us or from our business partners and Marketing Affiliates at any time, by contacting us at support@LoneStarCasino.com.

For Canadian users, we send commercial electronic messages (such as email or SMS) in accordance with Canada’s Anti Spam Legislation (CASL). Our messages identify us, include our contact information, and provide an unsubscribe mechanism that we honor without delay and no later than 10 business days.

Please note that even if you unsubscribe from our marketing-mailing list, we can continue to send you service-related updates and notifications.

7  Your privacy rights

7.1. Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your personal information. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.

Privacy Officer: We have appointed a Privacy Officer to oversee our privacy practices. For any privacy-related inquiries, concerns, or requests, please email support@lonestarcasino.com with the subject line “PRIVACY INQUIRY”.

7.1.1. Rights of access to your personal information:

You have the right to receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.

7.1.2. Right of data portability:

You have the right to request us to move, copy and transfer your personal information easily from one IT environment to another, in a safe and secure way, without affecting its usability.

7.1.3. Right of rectification:

You have the right to request rectification of your personal information in our control in the event that you believe the personal information held by us is inaccurate, incomplete or outdated.

7.1.4. Right of deletion/erasure:

You have the right to request that we erase or delete personal information held about you at any time.

7.1.5. Right to restriction or objection to processing:

You have the right to request that we restrict or cease to conduct certain personal information processes at any time.

7.1.6. Right to withdraw your consent:

To the extent we process personal information on the basis of your consent, you have the right to withdraw your given consent at any time. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

7.1.7. Right not to be subject to automated decision making:

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects on you

7.1.8. Right to opt-out of the sale or share of personal information:

In the event that we sell or share your personal information for behavioral advertising purposes, you have the right to submit a request to opt-out of the sale or share of your personal information. After you opt-out, we may continue disclosing some personal information to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.

7.1.9. Right to non-discrimination:

You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.

7.1.10. Right to lodge a complaint:

All requests, complaints or queries may be addressed to the Company to the following email address: support@LoneStarCasino.com. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns be brought to our attention first, so that we can try to resolve them.

If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

For Canada, you may contact the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca) or, where applicable, your provincial privacy commissioner.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.

7.2. Verification and authorized agent

7.2.1. You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

• i) The authorized agent is a natural person or a business entity; and
• ii) You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

7.2.2. The request must:

• i) Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or an authorized agent. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you; and
• ii) Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

7.2.3. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

7.2.4. Making a verifiable consumer request does not require you to create an account with us.

8  Transfer of personal information

Certain aspects of our operations, such as our payment processing, are handled globally. Thus, any information that we collect, disclose or share, including your personal information, can be stored and processed in various jurisdictions around the world, including (but not limited to) Gibraltar, the European Economic Area, United Kingdom, Israel and United States, for the purposes detailed in this Policy. We may update this list from time to time to reflect additional countries where your personal information may be transferred or processed. To the extent that the Gibraltar GDPR is applicable, we will only transfer or share your personal information to data recipients: located in Gibraltar, the EEA or in the UK; located in other countries which have been approved as providing adequate level of data protection; or who have entered into legal arrangements ensuring an adequate level of data protection. . Whenever we engage a service provider/partners, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy laws. Please note that personal information transferred to other jurisdictions may be subject to access by foreign governments, courts, law enforcement or regulatory agencies in accordance with the laws of those jurisdictions.

9  How we protect your data

We are strongly committed to the protection of your personal information and information, and we will take reasonable technical steps, which are accepted in our industry, to keep your Information secured and protect it from loss, misuse or alteration. These steps include, but are not limited to, the use of encryption, access controls, and intrusion detection systems to safeguard your personal information. However, if you notice a risk or any security violations, we advise you to report to us on support@LoneStarCasino.com, so we can resolve it as soon as possible.

10  Minors

We do not knowingly collect or solicit personal information from anyone under the age of 18. By accessing, using or interacting with our Services, you certify to us that you are not under the age of 18. In the event we learn that we have inadvertently gathered personal information from minors under the age of 18, we will take reasonable measures to promptly delete such information from its records in a secure manner. If you believe that we may have any information from or about minors under the age of 18, please let us know at support@LoneStarCasino.com.

11  Retention

We will retain your personal information for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined while taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Where possible and appropriate, we will anonymize or aggregate personal information so that it can no longer be associated with you, and we will do so as soon as the information is no longer required for the purposes for which it was collected or as required by applicable law. Specific retention periods may vary depending on the category of personal information and applicable legal requirements; you may contact us for further details regarding retention periods for particular types of data.

12  Updates to this Policy

From time to time, the Company reserves the right to modify the Policy through:

• (i) posting a modified version on the Services. Such modified version will take effect immediately upon being posted and you agree to be bound by such modifications;
• (ii) asking that you accept the modified Policy. Such modified version will take effect immediately upon your acceptance;
• (iii) posting a notice about the modifications on the Services. Such modifications will take effect immediately upon the notice being posted and you agree to be bound by such modifications; or
• (iv) sending you a notification via the e-mail address associated with your User Account at the time of such modification Such modification will take effect upon your continued use of the RealPrize Services.

If you do not agree to the modified Policy your sole remedy will be to terminate your User Account in accordance with Clause ‎13.1 (TERMINATION OF YOUR USER ACCOUNT) in the General Terms and Conditions and immediately cease accessing and using the Services and the Services Content and if you have downloaded the RealPrize application, you must delete the RealPrize application from your device.

We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the “Last Updated” heading). 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. For transparency, we maintain an archive of all previous versions of this Privacy Policy. Archived versions are available upon request for your reference.

13  Controlling version

This Policy has been drafted in English, serving as the original and controlling version of this Policy. Any translations of this Policy into other languages are provided for convenience only and shall not dictate the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the interpretation of the English language version shall prevail.

14  Contact us

If you have any questions about this Policy, please contact us at:

Privacy Officer

support@lonestarcasino.com (please include the headline “PRIVACY INQUIRY” in your email subject)

You may also write to us at:

Att. Privacy Officer

8 The Green Suite B, Kent, Delaware, USA

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.