1. INTRODUCTION AND SCOPE
1.1. Introduction
Welcome to Jackpot Sounds (the "Site"). Depending on your country of residence, the data controller responsible for your personal information ("Company," "we," "our," or "us") is:
- For users residing in the United States: Shotake Inc., a company registered in the State of Delaware, USA.
- For users residing anywhere else in the world (including the European Economic Area and the UK): Shotake Limited, a company registered in Cyprus.
This Privacy Policy explains how we collect, use, maintain, and disclose information collected from visitors and users of the Site.
1.2. Scope
This Privacy Policy explains how we collect, use, maintain, and disclose information collected from visitors and users ("User," "you," or "your") of the Site. This Privacy Policy applies to the Site, the Replay Hub, our Affiliate Directory, and all related services or features offered by the Company (collectively, the "Services").
By accessing or using the Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our policies and practices, please do not use our Site.
2. INFORMATION WE COLLECT
Because Jackpot Sounds operates without mandatory user account registrations, profiles, or payment processing, we collect a minimal, strictly necessary amount of personal data. We collect this information through your direct interactions with our Site and automatically through analytical tracking technologies.
2.1. Information You Provide Directly
Contact & Submission Data: When you use our contact forms or voluntarily submit a video replay ("Guest Submission"), we may collect your email address and a chosen nickname.
User-Generated Content: Any text, context, or additional data you voluntarily include or embed when uploading a replay or communicating with us.
Important Notice Regarding Public Content: Please be aware that any information you voluntarily submit for public display on the Site, specifically your chosen nickname and the Guest Submission, will be visible to all visitors of the Site. Once published, this becomes public information. We strongly advise you not to include any sensitive, private, or personally identifiable information within the video content itself or in your chosen nickname.
2.2. Information Collected Automatically
As you navigate through and interact with our Site, we automatically collect certain technical data to ensure the Site functions properly and to analyze traffic. We utilize Google Analytics 4 (GA4) exclusively for these analytical purposes:
Technical & Usage Data: Your IP address (which is anonymized/masked where required by applicable privacy laws), browser type and version, operating system, device type (mobile vs. desktop), and interactions with the Site (e.g., pages viewed, time spent on pages, links clicked).
3. HOW WE USE YOUR INFORMATION
We use the limited information we collect strictly for the following business and operational purposes:
- Providing and Maintaining Services: To process, review, and display your submitted replays, and to respond to your direct inquiries, feedback, or support requests.
- Analytics and Site Improvement: To analyze usage trends, monitor Site performance, and improve the overall functionality, design, and user experience of our Services.
- Security and Legal Compliance: To detect, prevent, and address technical issues, fraudulent activity, or unauthorized access to our Site, and to comply with applicable legal obligations (such as processing DMCA takedown requests).
Important Notice: We do not use your personal information to send unsolicited marketing emails (spam), telemarketing calls, or SMS messages. Your email is used strictly for transactional or support-related communication regarding your specific inquiries or submissions.
No Automated Decision-Making or Profiling: In accordance with GDPR requirements, we confirm that we do not use your personal data for automated individual decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you. All processing of your limited data involves human oversight or is strictly tied to basic technical delivery of our Services.
4. SHARING AND DISCLOSURE OF INFORMATION
4.1. No Sale of Personal Data
We want to be absolutely clear: Jackpot Sounds does not sell, rent, or lease your personal information to third parties. We do not act as a data broker, and we do not share your personal data with third-party advertising networks for the purpose of cross-context behavioral advertising.
4.2. No Sensitive Personal Information Collected
We do not collect, process, or disclose any "sensitive personal information" (such as social security numbers, precise geolocation, racial or ethnic origin, or biometric data) as defined by the CCPA/CPRA and other applicable U.S. state privacy laws. Therefore, the right to limit the use of sensitive personal information does not apply to our Services.
4.3. Third-Party Service Providers
We may disclose the limited information we collect to trusted third-party service providers who perform critical technical functions on our behalf. These providers are contractually obligated to protect your data and are strictly prohibited from using it for any purpose other than providing services to us. These include:
- Hosting Providers: Our primary data servers and cloud infrastructure are securely located in Germany.
- Analytics and Consent Management: Providers such as Google (for Google Analytics 4) and Cookiebot (for managing user cookie consents according to EU regulations). Where we process de-identified data, we publicly commit to maintain and use such data only in a de-identified fashion and will not attempt to re-identify it.
4.4. Legal Requirements and Protection of Rights
We may disclose your information if required to do so by law or in good faith belief that such action is necessary to:
- Comply with a legal obligation, court order, or governmental request.
- Protect and defend the intellectual property rights, property, or safety of the Company, our users, or the public (including responding to DMCA takedown notices).
- Investigate or prevent potential fraud or violations of our Terms of Service.
4.5. Business Transfers (M&A)
If the Company is involved in a merger, acquisition, asset sale, or reorganization, your information may be transferred as part of that transaction. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.
4.6. Third-party Link and Affiliate Directory
Our Services, including the Affiliate Directory, contain links to third-party websites, platforms, or services that are not owned or controlled by the Company. Once you click on a third-party link and leave our Site, this Privacy Policy no longer applies. We are not responsible for the privacy practices, content, or data collection policies of those external sites. We strongly encourage you to review the privacy policies and terms of service of any third-party websites you visit before providing them with any personal information.
5. COOKIES AND TRACKING TECHNOLOGIES
5.1. Use of Cookies
We use cookies and similar tracking technologies to enhance your experience, analyze Site traffic, and manage your privacy preferences. Because we operate internationally, we utilize a specialized Consent Management Platform (Cookiebot) to ensure we collect and store your cookie preferences legally.
5.2. Types of Technologies
Strictly Necessary Cookies: Required for the core functionality and security of the Site (e.g., saving your cookie consent preferences).
Analytics Cookies: We use Google Analytics 4 (GA4) to understand how visitors interact with the Site. These cookies collect technical data (such as anonymized IP addresses and device types) to help us improve user experience.
5.3. Your Control and Cookie Policy
Upon your first visit to the Site, you will be presented with a Cookie Banner allowing you to accept or reject non-essential cookies. You can change your preferences at any time. For a detailed list of the exact cookies we use, their duration, and providers, please refer to our dedicated Cookie Policy.
6. INTERNATIONAL DATA TRANSFERS AND DATA RESIDENCY
Jackpot Sounds is based in the United States (Delaware); however, we have strategically structured our data hosting to prioritize user privacy.
6.1. Servers Located in Germany (EEA)
Our corporate operations are distributed between the United States and the European Union (Cyprus); however, we have strategically structured our data hosting to prioritize user privacy. Servers Located in Germany (EEA): The primary servers hosting the Site, the Replay Hub, and your submitted data are physically located in Germany. This means that if you are a non-US resident whose data controller is Shotake Limited (Cyprus), your personal data is collected and stored entirely within the European Economic Area (EEA), ensuring direct compliance with the GDPR without the need for cross-border transfer mechanisms to the US.
6.2. Occasional Transfers
While our servers are in the EEA, incidental access to this data may occur from other countries (e.g., when our corporate team or technical support accesses the servers for maintenance or customer service). When such international transfers occur, we rely on legally approved mechanisms, specifically the Standard Contractual Clauses (SCCs) approved by the European Commission, alongside appropriate technical and organizational safeguards. This ensures your data receives an adequate level of protection regardless of where it is accessed or processed.
7. YOUR PRIVACY RIGHTS (GLOBAL, EU, AND U.S. STATE LAWS)
Depending on your region of residence (including the European Economic Area, the UK, and specific U.S. states such as California, Texas, Virginia, Colorado, and others), you may have specific rights regarding your personal information. We extend these core privacy rights to all our users globally:
7.1. Your Core Rights
Right to Access / Know: You have the right to request confirmation of whether we process your data and obtain a copy of the specific pieces of personal information (e.g., your email or nickname) we have collected about you, provided in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance.
Right to Delete: You may request that we delete the personal information we have collected from you, including any Guest Submissions (Replays) associated with your email address.
Right to Correct: You may request that we correct inaccuracies in your personal information.
Right to Opt-Out: You have the right to opt out of the sale or sharing of your personal data for targeted advertising. As stated in Section 4, we do not sell your personal data or share it for cross-context behavioral advertising.
7.2. Specific Notice for EEA and UK Residents (GDPR)
If you are located in the EEA or the UK, our legal basis for collecting your limited data is your explicit consent (when you submit a form or accept cookies) and our legitimate interest (maintaining Site security and analyzing traffic). In addition to the Core Rights listed above, GDPR grants you the following specific rights:
- Right to Data Portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format, and have the right to transmit those data to another controller.
- Right to Restriction of Processing: You have the right to request that we restrict the processing of your personal data under certain conditions (for example, while we verify the accuracy of your personal data if you contest it).
- Right to Object: Where our processing is based on legitimate interests (such as site security or traffic analysis), you have the right to object to such processing at any time on grounds relating to your particular situation.
- Right to Withdraw Consent and Complain: You have the right to withdraw your consent at any time and the right to lodge a complaint with a supervisory authority (Data Protection Authority) in your country of residence. If you are a resident of the UK, you have the right to lodge a complaint directly with the Information Commissioner's Office (ICO).
7.3. Specific Notice for Residents of Australia
In accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988, we collect and process your minimal personal data (such as a pseudonym/nickname) primarily for providing our Services. If you are a resident of Australia and are not satisfied with our handling of your privacy request or complaint, you have the right to lodge a formal complaint with the Office of the Australian Information Commissioner (OAIC).
7.4. Specific Notice for Residents of Ukraine
If you are accessing the Site from Ukraine, your personal data is processed in accordance with the Law of Ukraine "On Personal Data Protection."
Notification of Processing: By interacting with our Site and providing your data, you acknowledge that you have been informed through this Privacy Policy about the Owner of the personal data (the Company), the composition and content of the collected data, the purpose of its processing, and your rights under Article 8 of the Law.
Your Specific Rights: In addition to the Core Rights listed above, Article 8 grants you the right to know the sources of collection and location of your personal data; to receive a response on whether your data is being processed within 30 days; to present a motivated demand to object to processing or require modification/destruction of your data if processed illegally; and to protect your data from unlawful processing or accidental loss.
Right to Complain: If you believe your privacy rights have been violated, you have the right to lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights (the Ombudsman) or file a lawsuit in court.
Cross-Border Transfer: As stated in Section 6, our primary servers are located in Germany. In accordance with Article 29 of the Law, the transfer of personal data to states within the European Economic Area (EEA) is permitted without restriction, as these states are recognized as ensuring an adequate level of personal data protection.
7.5. Specific Notice for U.S. Residents (Including Texas and California)
No Discrimination: We will not discriminate against you for exercising any of your privacy rights.
California "Shine the Light" Law: We do not share your personal information with third parties for their direct marketing purposes.
Right to Appeal (Virginia, Colorado, Connecticut, Texas, etc.) If we decline to take action regarding your privacy request, you have the right to appeal our decision within a reasonable period after you receive our decision. To submit an appeal, please reply to our decision email with the subject line "Privacy Request Appeal." If your appeal is denied, we will provide you with information on how to contact your state attorney general (such as the Texas Attorney General or the Connecticut Attorney General) to submit a formal complaint.
Texas Attorney General Notice: If you are a resident of Texas and your appeal is denied by us, you have the right to submit a formal complaint to the Texas Attorney General online at https://www.texasattorneygeneral.gov/ or by contacting their Consumer Protection Division.
Categories of Personal Information Collected and Disclosed (California CCPA/CPRA) In the preceding 12 months, we have collected and disclosed for a business purpose the following categories of personal information: Identifiers (such as email address and nickname) and Internet or other electronic network activity information (such as interaction with our Site). We have not sold any personal information, nor have we shared any personal information for cross-context behavioral advertising in the past 12 months.
Oregon right to know right: If you are a resident of Oregon, you have the right to obtain a list of the specific third parties (other than our service providers) to which we have disclosed your personal data.
Opt-Out Preference Signals and Global Privacy Control (GPC)
Certain state laws require us to recognize Opt-Out Preference Signals, such as the Global Privacy Control (GPC) broadcasted by your browser. Because we do not sell your personal data or share it for targeted advertising, our baseline practice already treats all users as opted-out of such activities. However, our consent management platform is configured to detect and respect valid GPC signals as a request to opt out of any non-essential cookies and tracking automatically.
7.6. How to Exercise Your Rights
To exercise any of these rights, please contact us at: [Email Address]
US residents may designate an authorized agent to make a request under applicable state laws on their behalf. We may require you to verify your identity directly with us and provide proof of your written authorization before processing the agent's request.
We endeavor to respond to all verifiable consumer requests within the specific timeframes required by your applicable local jurisdiction:
- US Residents: Within forty-five (45) days of receiving your verifiable request (with a possible extension of an additional 45 days where permitted by applicable state law).
- EEA, UK, and Swiss Residents: Within one (1) month of receiving your request (with a possible extension of two further months for complex or multiple requests, as permitted by the GDPR/UK GDPR).
- Argentine Residents: Within ten (10) calendar days for right of access requests, and within five (5) business days for requests to correct, update, or delete personal data.
- Other Jurisdictions: Within thirty (30) days, or as otherwise required by applicable local law.
We may need to request specific information from you (such as verifying your email address) to confirm your identity before processing your request.
8. DATA RETENTION AND SECURITY
8.1. Data Retention
We retain your personal information strictly for as long as necessary to fulfill the purposes outlined in this Privacy Policy.
Guest Submissions (Replays) and Emails: Retained as long as the content is published on the Site, or until you exercise your Right to Delete.
Analytics Data: Non-identifiable or aggregated technical data collected via Google Analytics 4 is typically retained for up to 14 months before being automatically deleted.
8.2. Data Security
We implement commercially reasonable technical and organizational measures to protect your data, including the use of SSL encryption for data in transit and secure hosting environments in Germany. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.
In the event of a data breach that compromises your personal information, we will notify affected users and the relevant supervisory authorities without undue delay, in accordance with applicable data protection laws.
9. CHILDREN'S PRIVACY
Our Site and Services involve simulated and real-money gambling content and are intended strictly for adults. You must be at least eighteen (18) years of age (or the legal age for gambling in your jurisdiction) to access the Site. We do not knowingly collect personal information from individuals under the age of 18. If we learn that we have inadvertently collected personal information from a minor, we will delete that information immediately.
10. CHANGES TO THIS PRIVACY POLICY
We reserve the right to update or modify this Privacy Policy at any time, but at least once a year, to reflect changes in our legal obligations, business practices, or technical processes. Any changes will be posted on this page, and we will update the "Date updated" at the top of this document. We encourage you to review this Privacy Policy periodically. Your continued use of the Site after any such changes constitutes your acknowledgment and acceptance of the updated policy.
11. CONTACT US
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact the applicable Data Controller:
For US Residents:
- Data Controller: Shotake Inc.
- Email Address: [email protected]
- Mailing Address: 525 Route, 73 North Suite, 104 Marlton, New Jersey 08053
For Non-US Residents (including EEA & UK):
- Data Controller: Shotake Limited
- Email Address: [email protected]
- Mailing Address: 170 Franklin Roosevelt, Limassol Chamber, Floor 2, Omonoia 3048, Limassol, Cyprus