GDPR

Lucky Day’s Explanation Of Types Of Processing Which Are Based Upon Contractual Necessity And Legal Compliance

  1. Updating and enhancing user profile information – User profile information is made private and not publically available (except with respect to the data subjects opt-in for the leader board). It is used to access information for data subjects for collecting prizes, purchasing virtual goods (i.e. game tokens) and participating in sweepstakes and other games and promotions. Data subjects may update their user profile information at any time. Also, Lucky Day may refer to the User profile information for fulfilling its contractual obligations such as taking and remitting payments to the data subject, tracking their awards and redemptions and responding to customer service inquiries. User profile information is encrypted and Lucky Day utilizes pseudonymous hash tagging of a user’s information to mitigate risk of loss.

  2. Behavioral Tracking and Analysis for improving the Services and its features for users – Lucky Day analyzes user behavior on the App to determine which promotions are preferred by different users, and make predictive determinations as to what games, prizes and sweepstakes will be most popular with its users to deliver a customized, enhanced user experience and provide more value.

  3. Fulfilling orders for virtual goods and services. Data subjects purchase tokens to play more games or may redeem cash and other prizes through the App. Lucky Day needs to refer to personal data in order to ensure that appropriate credits and debits are made to a data subject’s account. This function is automated, but subject to human review in the event of errors or customer service inquiries.

  4. Tracking user awards when using the Services. As an integral part of the Lucky Day services, it needs to track prize awards accumulated by data subjects in order to ensure it is meeting is contractual and regulatory obligations to those data subjects.

  5. Handle customer service or technical support questions. Lucky Day may refer to a data subject’s account profile, awards, purchases and other personal data to address customer service and technical support questions from data subjects.

  6. Legal and regulatory compliance. Lucky Day conducts sweepstakes on its App through games of chance. In order to comply with sweepstakes laws and the regulatory requirements associated with them, Lucky Day will need to process personal data for the purposes of ensuring compliance with sweepstakes rules and the regulatory requirements associated with such sweepstakes. Further, Lucky Day will need to process the data subject’s personal data in the establishment, exercise or defense of legal claims related to compliance and a data subject’s use of the App.

  7. Processing payments or other awards to winners. Lucky Day needs to collect and process certain payment information such as PayPal and Venmo in order to fulfill these contractual obligations to data subjects. This function is automated, but subject to human review in the event of errors or customer service inquiries. Data subjects may edit this data in their user profile. Payment Information is encrypted and Lucky Day utilizes pseudonymous hash tagging of a user’s associated personal information to mitigate risk of loss.

  8. Effectuating sweepstakes and winner selection. Lucky Day assigns a data subject a unique identifier with each sweepstakes entry, and that number is randomly selected by Lucky Day’s automated algorithm. Tracking winning identifiers with the data subject’s account is essential for tracking and crediting their prizes and awards.

  9. Communicating with users regarding their alternative method of entry. Lucky Day is required to provide an alternative method of entry to ensure that its sweepstakes comply with applicable laws. If a data subject desires to submit an alternative method of entry, and Lucky Day needs to communicate with them regarding their submission, the data subject’s personal data will be utilized for this purpose.

  10. Notifying users if they are a winner of any one of Lucky Day’s sweepstakes. Lucky Day’s systems automatically notify a data subject if they have won or lost a specific sweepstakes game. This process is automated.

  11. Processing for security, system integrity (the prevention of hacking, cheating and other improper or unlawful activities), or enforcement purposes. Lucky Day needs to monitor personal data and App usage to ensure against hacking, cheating or unlawful activities by data subjects. Further, Lucky Day tests accounts and audits winnings to ensure that security measures are working and there is no illicit activity on its platform. Further, Lucky Day will need to process the data subject’s personal data in the establishment, exercise or defense of legal claims related to compliance and a data subject’s misuse of the App.