Privacy Policy

Privacy Policy

Engaged Nation, Inc. ("Engaged Nation", "we", "us", or "our") operates the Promo on Demand platform, which powers projects and promotional campaigns. We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains what information we collect when you participate in a promotion, how we use it, and the choices you have.

By participating in Engaged Nation projects or campaigns you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

When you register for or participate in Engaged Nation projects or campaigns, we may collect the following categories of personal information:

• Identity information: First name, last name, or full name.
• Contact information: Email address, phone number.
• Loyalty program information: Casino or venue loyalty card number / membership number.
• Device and usage information: IP address, browser type, device identifier, and timestamps associated with your participation.
• Gameplay information: Game results, prizes won or received, and participation timestamps.

Providing this information is voluntary, but certain fields may be required to participate in the promotion. Any fields marked as required on the registration form are necessary for eligibility verification purposes.

2. How We Use Your Information

We use the personal information we collect for the following purposes:

• To verify your eligibility to participate.
• To administer the promotion, including awarding and tracking prizes.
• To prevent duplicate or fraudulent participation.
• To communicate with you regarding your participation or prize redemption, if applicable.
• To comply with applicable laws and regulations, including gaming and promotional regulations.
• To generate aggregated, anonymized analytics about projects or campaigns performance (no individual is identifiable in these reports).

We use your information only for the purposes of Engaged Nation projects or campaigns. We do not use your information for unrelated marketing without your separate, explicit consent.

3. Sharing & Disclosure of Your Information

We do not sell, rent, trade, or otherwise transfer your personal information to third parties for their own marketing purposes. We do not share your personal information with unrelated businesses for commercial gain.

We may share your information only in the following limited circumstances:

• With the sponsoring organization: The casino, venue, or business operating a project or campaign (the "Sponsor") receives your participation data for the purpose of prize fulfillment and eligibility verification. The Sponsor is subject to their own privacy obligations under applicable law.
• With service providers: We engage trusted technology partners to operate our platform (e.g., cloud hosting, database services). These providers are contractually obligated to protect your data and may not use it for any purpose beyond providing services to us.
• As required by law: We may disclose information if required to do so by a court order, subpoena, or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

4. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include encrypted data transmission (HTTPS/TLS), access controls, and regular security reviews.

However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

5. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, to administer the promotion, to comply with applicable laws, and to resolve disputes. Gameplay and participation records are typically retained for a period of up to two (2) years following the end of the project or campaign, after which they are deleted or anonymized.

6. Your Rights & Choices

Depending on where you live, you may have specific legal rights regarding your personal information. Regardless of jurisdiction, you may always contact us to request access to, correction of, or deletion of your personal data. We will respond in accordance with applicable law and within a reasonable timeframe. Specific rights for EU/EEA and California residents are described in the sections below.

7. GDPR - Rights of EU/EEA Residents

If you are located in the European Union or European Economic Area, the General Data Protection Regulation ("GDPR") grants you specific rights over your personal data. Our legal basis for processing your data in connection with Engaged Nation projects or campaigns is your participation (contractual necessity) and, where applicable, our legitimate interest in fraud prevention and campaign administration.

Under GDPR you have the right to:

• Access (Article 15): Obtain a copy of the personal data we hold about you and information about how it is processed.
• Rectification (Article 16): Request correction of inaccurate or incomplete personal data.
• Erasure / Right to be Forgotten (Article 17): Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent, subject to our legal obligations.
• Restriction of Processing (Article 18): Request that we limit how we use your data while a dispute is resolved.
• Data Portability (Article 20): Receive a copy of your personal data in a structured, commonly used, machine-readable format.
• Object to Processing (Article 21): Object to processing based on legitimate interests.
• Withdraw Consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

72-Hour Breach Notification: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, in accordance with Article 33 of the GDPR. Where the breach is likely to result in a high risk to you, we will also notify you directly without undue delay.

You also have the right to lodge a complaint with your local data protection supervisory authority (e.g., your country's Data Protection Authority). To exercise your GDPR rights, please contact us at the address in the Contact section below. We will respond within 30 days, extendable by a further two months where necessary for complex requests.

8. CCPA/CPRA - Rights of California Residents

If you are a California resident, the California Consumer Privacy Act ("CCPA") and the California Privacy Rights Act ("CPRA") provide you with specific rights regarding your personal information.

Categories of personal information we collect (for CCPA disclosure purposes):

• Identifiers: name, email address, phone number, IP address.
• Commercial information: records of promotional activity and prizes received.
• Internet/electronic activity: device identifiers and participation timestamps.
• Sensitive personal information (as defined by CPRA): loyalty card / membership numbers.

We collect this information for the business purposes described in Section 2 of this Privacy Policy. We do not sell or share your personal information with third parties for cross-context behavioral advertising. Because we do not sell personal information, no opt-out of sale is required; however, we provide that right below as a matter of transparency.

Under CCPA/CPRA, California residents have the right to:

• Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, our business purposes, and the third parties with whom we share it.
• Delete: Request deletion of personal information we have collected, subject to certain exceptions (e.g., completing a transaction, legal obligations, fraud prevention).
• Correct: Request correction of inaccurate personal information.
• Opt Out of Sale or Sharing: We do not sell your personal information. If our practices ever change, we will provide a "Do Not Sell or Share My Personal Information" link before doing so.
• Limit Use of Sensitive Personal Information: Request that we limit our use of sensitive personal information (such as loyalty card numbers) to the purposes for which it was collected.
• Non-Discrimination: We will not discriminate against you - including by denying goods or services, charging different prices, or providing a different quality of service - for exercising any of your CCPA/CPRA rights.

To submit a verifiable consumer request, please contact us using the information in the Contact section below. We will acknowledge your request within 10 business days and respond within 45 calendar days. If we require more time (up to 90 days), we will inform you of the reason and the extension in writing. You may designate an authorized agent to make a request on your behalf; we will require written proof of authorization.

9. Children's Privacy

This campaign is intended for individuals who meet the minimum age requirements set by the Sponsor and applicable law (typically 21 years of age or older for casino promotions). We do not knowingly collect personal information from individuals under the age of 18. If you believe a minor has submitted information through this campaign, please contact us immediately.

10. Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time. Changes will be effective upon posting to this page. We encourage you to review this page periodically for the latest information on our privacy practices.