1 · Who we are
Neon Luck Club ("we", "us", or "our") operates a pure social casino site that offers casino-style games for entertainment only. We do not offer real-money gambling, sweepstakes, prizes, or cash redemption. Our principal place of business is 1209 Orange Street, Wilmington, DE 19801.
2 · Information we collect
We collect information in the following categories (using the categories defined by the CCPA):
- Identifiers. Name, email address, phone number, IP address, and a platform-assigned member ID.
- Account & profile information. Display name, password (stored as a one-way hash), age-gate confirmation, and optional state of residence.
- Gameplay & activity data. Virtual coin balance, rooms visited, game-session timestamps, and feature-interaction events. This data has no monetary value and is used solely to operate the Site.
- Device & technical data. Browser type, operating system, approximate location derived from IP (used for age and geographic access enforcement only), and basic usage metrics such as pages viewed and session duration.
- Purchase records. If you buy an optional virtual credit pack, our payment processor (not us) receives your payment-card information directly. We retain only a transaction reference ID and the pack type purchased. We do not store full payment-card numbers.
- Communications. Messages and attachments you send to our support team, and our replies.
- Cookie & localStorage data. As described in our Cookie Policy, including age-gate status, local coin balance, and — with your consent — aggregate analytics data.
We do not collect Social Security numbers, driver's license numbers, financial-account credentials, biometric data, health or medical information, or precise geolocation.
3 · How we use information
- To create and maintain your account and authenticate your identity.
- To enforce the 21+ age requirement and geographic access restrictions required by law.
- To operate and improve the Site, including debugging, performance monitoring, and A/B testing.
- To detect and prevent fraud, abuse, cheating, and security incidents.
- To process optional virtual credit pack purchases and handle refund requests where required by law.
- To send transactional emails (account confirmation, password reset, security alerts). With your explicit opt-in, we may send promotional messages; you can unsubscribe at any time.
- To respond to your support requests and responsible-play inquiries.
- To comply with applicable law, legal process, and regulatory requirements.
4 · How we share information
We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising. We share information only as follows:
- Service providers. Cloud hosting, email delivery, fraud detection, and payment processing vendors who process information on our behalf under written contracts that prohibit them from using it for their own purposes.
- Legal compliance. Law enforcement agencies, courts, or regulators when required by law, subpoena, or to protect the rights, property, or safety of Neon Luck Club, our members, or the public.
- Business transfers. A successor entity in connection with a merger, acquisition, or asset sale. We will notify you before your information becomes subject to a materially different privacy policy.
5 · Cookies & similar technologies
We use first-party cookies and localStorage to keep you signed in, remember your age-gate confirmation, and — with your consent — measure aggregate site usage. See our Cookie Policy for a full breakdown. You can manage your cookie preferences using our consent banner or your browser settings.
6 · Security
We use industry-standard safeguards including encryption in transit (TLS 1.2+) and at rest, hashed passwords, principle-of-least-privilege access controls, and audit logging. No system is perfectly secure; in the event of a data breach affecting your rights we will notify you as required by applicable law.
7 · Children
The Site is intended for users aged 21 and older. We do not knowingly collect information from anyone under 21. If you believe a minor has submitted information to us, please contact us immediately and we will delete it promptly.
8 · Retention
We retain account and gameplay information for as long as your account is active and for a reasonable period afterward (generally up to three years) to satisfy legal, fraud-prevention, and dispute-resolution requirements. You may request deletion at any time as described in Section 9.
9 · Your choices & general rights
- Access & correction. You may access or update your account information by signing in or contacting us.
- Deletion. You may request that we delete your account and associated personal information. We will comply within 45 days unless retention is required by law.
- Marketing opt-out. Every promotional email includes an unsubscribe link. You can also opt out via the contact page.
- Cookie opt-out. Manage optional analytics cookies through the banner at the bottom of any page, or via our Cookie Policy page.
10 · California Privacy Rights (CCPA / CPRA)
10.1 · Categories of personal information collected
In the preceding 12 months we have collected the following categories of personal information (as defined by the CCPA):
- A · Identifiers — name, email address, phone number, IP address, member ID. Source: directly from you at registration. Business purpose: account creation, authentication, age and geographic enforcement.
- B · Personal information under Cal. Civ. Code § 1798.80 — name, address (if provided), telephone number, payment-card transaction reference. Source: directly from you. Business purpose: account operation, optional purchase processing.
- F · Internet or other electronic network activity — pages visited, session duration, game rooms accessed, browser type, device type. Source: automatically collected during your use of the Site. Business purpose: Site improvement, security, fraud prevention.
- G · Geolocation data — approximate location (state/region level) derived from IP address. We do not collect precise geolocation. Source: automatically collected. Business purpose: geographic access enforcement required by law.
- K · Inferences — game preference inferences drawn from gameplay activity (e.g., preferred game category). Source: derived from your gameplay data. Business purpose: personalizing your experience on the Site.
We have not collected sensitive personal information (as defined by CPRA, such as SSN, precise geolocation, racial origin, health data, or account log-in credentials in combination with security details) in the preceding 12 months.
10.2 · Categories of personal information disclosed for a business purpose
In the preceding 12 months we have disclosed the following categories of personal information to service providers for business purposes: Identifiers (A), Internet activity (F), and approximate geolocation (G). We have not disclosed personal information to third parties for their own commercial purposes.
10.3 · No sale or sharing for behavioral advertising
We do not sell personal information as defined by the CCPA. We do not share personal information for cross-context behavioral advertising. Because we do not sell or share personal information, there is no opt-out required under Cal. Civ. Code § 1798.120; however, you may contact us to confirm this at any time.
10.4 · California consumer rights
California residents have the following rights under the CCPA. You may exercise these rights yourself or through an authorized agent. We will not discriminate against you for exercising them.
- Right to know. You may request disclosure of: (i) the categories and specific pieces of personal information we have collected about you; (ii) the categories of sources; (iii) the business or commercial purposes for collection; and (iv) the categories of third parties with whom we share information.
- Right to delete. You may request deletion of personal information we have collected from you, subject to certain exceptions (e.g., completing a transaction, complying with a legal obligation, detecting fraud).
- Right to correct. You may request correction of inaccurate personal information we maintain about you.
- Right to opt out of sale/sharing. As stated above, we do not sell or share personal information for behavioral advertising. No opt-out is required, but you may confirm this by contacting us.
- Right to limit use of sensitive personal information. We do not collect or use sensitive personal information beyond what is necessary to perform the services you request.
- Right to non-discrimination. We will not deny service, charge different prices, or provide a different level of quality because you exercised a CCPA right.
10.5 · How to submit a CCPA request
To exercise any of the rights above, submit a request using one of these designated methods:
- Online: Contact form — select "Privacy request" as the topic.
- Email: [email protected] — include "CCPA Request" in the subject line.
We will verify your identity before responding (at minimum, we will match the email address on your request against our records). We will acknowledge your request within 10 business days and respond within 45 calendar days. If we require additional time (up to 90 days total), we will notify you of the extension and the reason for it.
Authorized agents: A California resident may designate an authorized agent to make a CCPA request on their behalf by providing written permission signed by the resident, or by establishing power of attorney. We may require direct verification from the consumer even when an agent submits a request.
10.6 · California "Shine the Light" (Cal. Civ. Code § 1798.83)
California residents who have an established business relationship with us may request, once per calendar year, information about any personal information we have shared with third parties for their own direct-marketing purposes. As stated above, we do not share personal information for third-party direct marketing. You may confirm this by contacting us at [email protected].
11 · International users
Neon Luck Club is operated from the United States. If you access the Site from outside the U.S., you acknowledge that your information will be transferred to and processed in the U.S., where data-protection laws may differ from your home jurisdiction.
12 · Changes to this policy
We may update this policy from time to time. We will post the revised policy on this page and update the "Last updated" date. Material changes will be communicated by email or via a prominent notice on the Site. Your continued use of the Site after a material change constitutes acceptance of the updated policy.
13 · Contact & data controller
Data controller: Neon Luck Club, Inc., 1209 Orange Street, Wilmington, DE 19801.
Privacy questions or requests: contact page or [email protected].