Last updated: 10 September 2021, v1.0
If you are a California resident, please also see California Residents: Your Privacy Rights, in which we describe your rights under California’s privacy law.
We update this privacy notice from time to time in response to changes in applicable laws and regulations, to our processing practices and to the products and services we offer. When changes are made, we will update the date at the top of this document. Please review this privacy notice periodically to check for updates.
2 What information do we collect?
We collect information directly from you when you use our Platform(s), automatically as you use our Platform(s), and from other persons, as described below.
Information you provide to us:
We collect information that you voluntarily provide to us. The type of information that we collect from depends on your interaction with us and may include:
- Name, Contact Information, and Other Identifiers: Including name, e-mail address, postal address, telephone number, gender, username, and password;
- Bank or other payment details: if you win a cash prize, you may provide us with bank or other payment details so that we can send you the cash prize; and
- Correspondence: information that you directly send to
Automatically collected information:
We may collect certain Usage Data automatically when you visit the Platform(s) or use our app, including, but not limited to:
- Your Internet Protocol (IP) address;
- Geolocation data;
- Information collected through cookies, web beacons, local stored objects, and other technologies;
- Device details, including mobile device identification numbers, operating system version and type, and device carrier; information regarding your interaction with our website, application, or advertisements (e.g. IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, browsing data, first party cookies, and pixel tags;
- Sites you visited before and after visiting the Platform(s);
- Pages you view and links you click on within the Platform(s);
- Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were received, opened, or forwarded;
- Your Game entries on the Platforms; and
Information we collect from others:
We may also collect information about you from third party sources such as:
- Our brand partner to assist a single sign-on from their website/app to our Platform;
- Verification providers to verify the information you provide us on sign up is
3 How we use your information
We use information that we collect through the Platform(s) for a variety of purposes, including to:
- Provide you with access to our Platforms in accordance with the Player Terms;
- Advertising, marketing and promotional purposes: to send you email newsletters or other information we think may interest you; to contact you about our Platforms or information we think may interest you; to administer promotions and contests; and to enable third parties who we think may interest you to do the
- Personalizing Content and Experiences: To tailor content we send or display on our websites and other Platforms; to offer location customization and personalized help and instructions; and to otherwise personalize your
Improve our Platforms and the overall user experience.
- Auditing, Reporting, Corporate Governance, and Internal Operations: To assist us and our advisors in financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our
- Complying with Legal Obligations: Including to comply with the law, our legal obligations and legal process, search warrants, subpoenas, court orders, and regulatory or law enforcement
- Defending our Legal Rights: Including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, and the rights and interests of other persons, including in the context of anticipated or actual litigation with other
4 Sharing your information
- Low6 Group: We may share your information with other companies in the Low 6
- Service Providers: We share your information with service providers that perform certain functions or services on our behalf (such as to host the Platform(s), fulfill orders, provide products and services, manage databases; perform analyses, process credit card payments, provide customer service, or send communications for us).
- Select Business Partners: We may share your information with select business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to Where required by law, we will ask your permission or enable you to opt-out before we share your information in such manner. We take measures to help ensure that our partners protect the confidentiality, integrity, and security of any information we share with them. However, we are not responsible for the privacy practices of our business partners, which may use your information for their own purposes.
- Business Transfer: If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, a business reorganization, or similar event, we may transfer your information as part of such transaction and in the diligence process of such
- Administrative or Legal Process: We may disclose your information to other entities in order to protect the legal rights, safety, and security of our organization, our corporate affiliates, subsidiaries, business partners, and the users of our Platform; enforce our Player Terms; respond to and resolve claims or complaints; prevent fraud or for risk management purposes; and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.
- Geolocation Information: We may share your geolocation information with service providers that perform certain functions or services on our behalf. These companies are authorized to use precise geolocation information only as necessary to provide these services to us. If you wish to stop the further collection of your geolocation information, please opt-out using your device settings.
- Other Parties: We may share information with other entities when you consent to such sharing or we are permitted to do so by law. For example, if you win a Game, we may post publicly that you have done so.
- Aggregate Information: We may share aggregate information, such as demographic and usage statistics, with advertisers, sponsors or other
In addition, we may allow service providers to place and read their own cookies, web beacons, Local Stored Objects, and similar technologies to collect information through the Platform(s). For example, our service providers may use these technologies to collect information that helps us with traffic measurement, research, and analytics.
5 Cookies and similar
As is true of most web sites, we, or our service providers, gather certain information about your use of our website and mobile applications automatically and store it in log files. As stated above, this information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We do not link this automatically collected data to other information we collect about you.
The Platform(s) use technologies such as cookies, beacons, tags and scripts. We use these technologies for a variety of purposes, such as analyzing trends, administering the Platform(s), analyzing how users interact with the Platform(s), and gathering demographic information.
We have adopted security procedures to help protect against loss, misuse, and unauthorized access to the information you provide to us. For example, if we collect financial information, we will use encryption software to help protect this information when it is in transit. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to the Platform(s) and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.
7 Children’s Privacy
The Platform(s) do not knowingly collect, use, or disclose personal information from children under the age of 13. If we are made aware that we have collected personal information from a child under 13 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act (“COPPA”), we will delete this information as soon as possible.
8 Data Retention
We will retain your personal data for as long as is necessary to provide you with our products and ongoing services and for a reasonable period thereafter, to enable us to meet our contractual and legal obligations and to deal with complaints and claims.
In some circumstances we are legally obligated to retain information to comply with legal obligations relating to crime prevention or gambling specific regulations.
You can contact Low6 in relation to data protection and this privacy notice by emailing [email protected]
10 Users from California
Under the California Consumer Privacy Act (“CCPA”), we are required to provide specific information to California residents about our practices related to personal information.
Categories of Personal Information that We Collect, Disclose, and Sell
We collect these categories of personal information from the sources described in the Information Collection section above, and for the purposes described in the Use of Information section above. Our collection, use and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with such resident.
California Consumer Rights
California law gives certain California residents the right to make the following requests with regard to certain personal information that we collect, at no charge, up to twice every 12 months:
- the right to opt-out of sale of their personal
- the right to request deletion of certain personal information that we have collected, subject to certain exemptions (for example, where the information is used by us to detect fraud or security incidents, debugging or to comply with a legal obligation).
- the right to request a copy of certain pieces of personal information that we have collected in the prior 12 months.
- the right to request that we disclose how we have handled their personal information in the prior 12 months, including the:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting and selling their personal information;
- categories of third parties with whom we have disclosed or shared their personal information;
- categories of personal information that we have disclosed or shared with a third party for a business purpose;
- categories of personal information collected; and
- categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party (if sold).
You can submit a copy, deletion, and right-to-know request online or an opt-out from future sales request by emailing [email protected].
Financial Incentives and the Right to Non-Discrimination
The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data. We do not offer any such incentives at this time and we do not discriminate against consumers for exercising their rights.
Shine the Light
You have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes (see California Civil Code Section 1798.83). To make such a request, please send an email to [email protected].
Please note that the Platform(s) are directed towards users who reside in the United States (but accept users worldwide). By using the Platform(s), you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States. While some of these countries may not offer the same level of privacy protection as your own, we commit to uphold the privacy protections as explained in this Policy.
11 Users from Europe
For users from Europe, the GDPR provides you with certain rights in relation to the processing of your personal data, including to:
- Request access to personal data about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you, and to check that we are lawfully processing
- Request rectification, correction, or updating to any of the personal data that we hold about This enables you to have any incomplete or inaccurate information we hold about you corrected
- Request personal data provided by you to be transferred in machine-readable format (“data portability”)
- Request erasure of personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove personal data where you have exercised your right to object to processing (see below)
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you (e.g. if you want us to establish its accuracy or the reason for processing it)
- Object to the processing of your personal data in certain This right may apply where the processing of your personal data is based on the legitimate interests of Low6
Some of these rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the laws and regulations to which we are subject. If at any time you decide that you no longer wish to be contacted for marketing purposes, or if you would like to exercise any of your rights as set out above, you can contact us at [email protected] . You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
In addition to the above, please note that you have the right to make a complaint at any time to the Information Commissioner’s Office if you are concerned about the way in which we are handling your personal data.