privacy policy

EFFECTIVE DATE: September 28, 2020

our commitment to privacy

Our customer's privacy is important to us. Lucra Sports ("Lucra", "we", "us", "our" or "Company") recognizes that people who use Lucra's Platform ("you" or "users") value their privacy. This Privacy Policy details important information regarding the collection, use and disclosure of user information collected from users of our Platform, participants in our fantasy sports contests ("Contests"), user networks ("Groups"), other content, products, services, and promotions (collectively the "Service") at our website located at www.lucrasports.com (the "Website"), the related mobile app ("Application") (together referred to as the "Sites"), and any other features, tools, or other services offered by Lucra. Lucra provides this Privacy Policy to help you make an informed decision about whether to use or continue using the Service.

information we collect

information you provide to us

By using our Service and by providing information to us through your use of our Platform, you consent to this Privacy Policy. As a user of our Service, you will provide certain personal information to Lucra when choosing to participate in the various activities on the Platform such as registering for an account, creating and participating in contests, creating and joining Groups, posting messages, taking advantage of promotions, or other related activities. The personal information we collect from you may include the following to use our Service:

  • Username and password, email address, phone number, date of birth, and the state in which you reside when you create an account to log in to our Platform ("Account").
  • When you request Services on our Sites, open an Account, or deposit or withdraw funds from your Account, or use our Sites for any reason, we may collect information you provide, including as necessary to complete the transaction, including your name, legal address, last four digits of your SSN, and credit or debit card billing information.
  • If you use our Application on your mobile device, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device, device information, default device language, the location of your device, and app usage information.
  • If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
  • If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to verify for eligibility to enter certain Contests and for fraud prevention purposes.
  • If you participate in a Contest or promotion conducted on our Sites, we may ask you for your email address and/or phone number (to notify you whether you win or not). We may also ask for your first and last names, and address details to verify your identity. In some situations, we may need additional information in connection with the Contest or promotion.
  • We may also collect information at other points in our Sites and Services where it is clear we are collecting such information.
  • Your subscriptions to our newsletters and services and responses to surveys offered by the Company.
  • In addition to the above, we may need to verify your identity in order for you to use some aspects of the Service. For purposes of verification, we may also collect the following personal information from you. If requested for compliance reasons, providing this information is mandatory to use our Service:
    • Valid government issued identification such as a passport or driver's license
    • Other identification documents as deemed appropriate
    • Tax-related information such as a tax identification number ("TIN") or social security number ("SSN")
    • Any other information as may be required to verify your identity in accordance with applicable laws and regulations

information collected via technology

information collected by our services

To make our Sites and Services more useful to you, our Sites automatically track certain information about the visits to our Sites, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, clickstream data, referring/exit pages, and/or a date/time stamp for your visit. We use this information to analyze trends, administer the Sites, gather demographic information about our user base as a whole, and to improve our Sites and Services and for product development purposes. For example, some of the information may be collected so that when you visit the Sites or Services again, it will recognize you and the information appropriate to your interests.

cookies

Like many online services, we use cookies to collect information. "Cookies" are small pieces of information that a website sends to your computer or other device which may enable us to uniquely identify your browser. We may use both session Cookies and persistent Cookies to provide you with a more personal and interactive experience on our Sites. Session Cookies are temporary and typically disappear after you close your browser. A persistent Cookie remains after you close your browser. Persistent Cookies may be used by your browser on subsequent visits to the site. Persistent Cookies can be removed by following your web browser help file directions. You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Site or Service may not function properly if the ability to accept Cookies is disabled.

collection of data in connection with advertising

We may use third parties to serve ads on the Sites. In connection with the delivery of advertising, certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP and the browser you use to visit our Sites. They do this by using Cookies, Pixel Tags, or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Sites and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, Cookies or Pixel Tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies.

mobile services

We may also collect non-personal information from your mobile device if you have downloaded our Application(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the Application(s), and information about the type of device you use. In addition, in the event our Application(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, that allows us to identify and fix bugs and otherwise improve the performance of our Application(s).

third party analytics

We use Google Analytics, to help analyze how users use our services. Google Analytics uses Cookies to collect information such as how often users visit our Sites, the pages they visit, and what other sites they used prior to coming to our Services. We use the information we get from Google Analytics only to improve our Sites, Application(s) and Services.

location information

If you have enabled location services on your phone, tablet, or other mobile device, we may collect your location information including for the purpose of verifying whether you are eligible to participate in a Contest, Group, service or promotion.

information collected from other sources

We may also collect information about you from third parties, such as marketing partners, identity verification services, anti-fraud services and other service providers. We may also supplement the information we have about you with information received from other sources such as commercially available sources (e.g., data brokers and public databases). The information we receive may include demographic data such as age, gender and income level, your interests and purchase data and other information that is necessary or useful to assist our marketing efforts or for user verification, authentication, fraud detection or to comply with regulatory requirements.

how we use information

general use

In general, the personal information you submit to us is used either to respond to the requests you make, or to aid us in serving you better. We use your personal information to operate, maintain, and provide to you the features and functionality of the Service, including but not limited to the following:

  • To provide you with our products and services, including our Contests and Groups;
  • To facilitate the creation and security of your Account on our network;
  • To identify you as a user in our system and to otherwise administer and operate our Sites and Service;
  • To improve the quality of your experience of our Sites and Service;
  • To send you administrative email notifications, such as security or support and maintenance advisories;
  • To deliver customized or personalized content, information, or advertising;
  • To enforce the legal terms that govern the use of our Service;
  • To protect the integrity of our platform, Contests, and Groups;
  • For the investigation of suspected unlawful, fraudulent, or other inappropriate activity connected with the use of our products and services;
  • To comply with our legal obligations in relation to customer identity verification and reporting obligations in accordance with anti-money laundering laws and regulations such as the Bank Secrecy Act and the USA PATRIOT Act and other applicable laws relating to the acceptance of bets on sporting events;
  • To respond to your inquiries and other requests; and
  • To send newsletters, surveys, offers and other promotional materials related to our Service or on behalf of third parties and to monitor the effectiveness of our marketing programs.

We may use your information to communicate with you about:

  • Our products and services in which you may be interested provided that you have not requested otherwise;
  • Newsletters and information for which you have signed up; and
  • Non-marketing or administrative purposes (such as notifying you of major changes to the Service or for customer service purposes).

We use your information to improve the quality and design of our Service and to create new features, promotions, functionality, and services such as by storing, tracking, and analyzing user preferences and trends.

We will retain personal information as long as necessary to fulfill these purposes unless the law requires us to keep it for a longer period of time. To provide security and business continuity for the activities described here, we make backups of certain data, which we may retain for longer than the original data.

disclosure of your personal data

We disclose your personal information as described below and as described elsewhere in this policy.

third parties designated by you

When you use the Services, the personal information you provide will be shared with third parties that you designate to receive such information. For example, you may elect to communicate with other users who are participating in the same Contest as you.

third party service providers

We may disclose the information we collect or receive from you with third parties such as partners, service providers or other businesses who process your information on our behalf in order to provide or operate the Service. For instance, these entities may have access to your information for purposes including, but not limited to, facilitating the creation of accounts, providing account authentication and user verification services, billing and accounting, hosting, marketing, promotional and email services, customer and technical support, conducting quality assurance testing, facilitating the back-office support for the Services, and for the purpose of accepting deposits and paying withdrawals and processing such information on our behalf, and in each case, may use the information to make improvements to the services they provide to us. Our agreements with these service providers limit the kinds of information they can use or process and require them to use reasonable efforts to keep your personal information secure.

profiles and players

When you participate in a Contest, we may make your Profile available to other Players of the Contest and enable you to communicate with other Players, in which case your communications will be disclosed.

In the event that you win a prize we may use your personal information (such as your name and photo) in connection with publicity purposes.

When you participate in a Contest, we may publish your username on a list of the contest participants, along with a link to your profile page.

disclosures

Where you have provided your consent, we may share your personal information with selected third parties for their commercial or marketing use in conjunction with your relationship with us or as part of a specific program or feature.

In addition, we may disclose to third parties various types of your information for targeted online or mobile advertising, as further described in the Section titled "Third Party Analytics".

We also may share personal information in other situations with your consent. Regardless of the choices you make regarding your personal information (as described below), we may disclose personal information if we believe in good faith that such disclosure is necessary:

  1. to comply with relevant laws or to respond to subpoenas or warrants;
  2. in connection with any legal or other official investigation;
  3. to protect or defend the rights or property of the Company or users of the Sites or Service; and/or(b) in connection with any legal or other official investigation;
  4. to investigate or assist in preventing any violation or potential violation of law, this Privacy notice, or our Terms of Use.

your choices regarding your information

email communication

We will periodically send you free newsletters and emails that contain information about our various products and services, or other products and services we feel may be of interest to you. At any time you can easily indicate your preference to stop receiving further communications from us and you may opt out of receiving further marketing by emailing us at support@lucrasports.com or by following the unsubscribe instructions provided in the email you receive. Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use and Privacy notice.

changing or deleting your personal information

You may change any of your personal information in your Account by editing your "personal information" within your Account or by sending an email to us at the address listed below. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.

applications

You may stop all collection of information by the Application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

third party links

Our Sites may contain links to websites operated and maintained by third parties over which we have absolutely no control. These third party websites are not subject to this privacy policy or our privacy standards and procedures. Any information you provide to third party websites will be governed by the terms of the websites' privacy policies. We have no responsibility or liability whatsoever for the content, actions, or policies of third party websites. The inclusion of third party links on our Sites in no way constitutes an endorsement of such websites' content, actions, or policies.

information security

We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure.

While we cannot guarantee the security of information processed online, we do have appropriate security measures in place to protect your personal information. For example, we store the personal information you provide on computer systems with limited access that are located in facilities to which access is limited. In addition, our employees, agents, and contractors are required to maintain the confidentiality of your personal information.

To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your password) to verify your identity before granting you profile access or making corrections.

Additionally, you should ensure your password is kept secret at all times. You will be responsible for maintaining the secrecy of your password and account information.

how you can access or correct your information

You can request a copy of the personally-identifiable information that Lucra has collected about you via the Service by contacting us at the e-mail address listed in the "How to Contact Us" section below. Once we receive your request for access or correction, we will respond to your request within a reasonable period (usually no more than 30 days) after the request is made. There are some circumstances specified by law where we may refuse your request for access to or correction of your personal information. If one of those circumstances applies, we will provide you with a written explanation of the reasons for refusal, unless it would be unreasonable to provide that notice.

state-specific privacy rights

Shine the Light Disclosures. If you reside in California, you may request certain general information regarding our disclosure of personal information during the preceding year to third parties for their direct marketing purposes. To make such a request, please contact us at support@lucrasports.com.

california consumer privacy act

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your "personal information" (as defined in the California Consumer Privacy Act ("CCPA")).

Categories of personal information we collect. Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about users. Under the CCPA, we are also required to provide you with the "categories" of personal information we collect. The categories we may collect are: identifiers (such as name, address, email address, driver's license); commercial information (such as deposit or contest entry data); financial data (such as payment information); internet or other network or device activity (such as browsing history or Services usage); geolocation information (e.g., your city and state based on IP address); professional or employment related data (e.g., as part of your profile); audio information (e.g., if you participate in a customer support call and do not opt out of call recording); in certain circumstances, information used to manage potential fraud or legal risk (such as employment status and criminal history); inference data about you; and other information that identifies or can be reasonably associated with you.

How we use and disclose these categories of personal information. We use and disclose the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Policy, and how you engage with the Service. Please see the relevant section(s) above for more information.

your california privacy rights

CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request:

  1. Information about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information. Such information is also set forth in this Privacy Policy.
  2. Provide access to and/or a copy of certain information we hold about you.
  3. Delete certain information we have about you.
  4. Provide you with information about the financial incentives that we offer to you, if any.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information or to comply with a legal obligation. We will let you know where this is the case or if certain rights don't apply in your country or state of residence. We also will take reasonable steps to verify your identity before responding to a request, which might include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and date of birth. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such request or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request.

Additionally, exercising your deletion right may mean that you may no longer be able to use the Service.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at 201-781-5977 or via support@lucrasports.com.

Notice of Right to Opt-Out of Sale of Personal Information

California residents may opt out of the "sale" of their personal information. California law broadly defines "sale" in a way that includes when we share your information with third parties, such as sports leagues or teams, to provide you with offers and promotions that we believe may be of interest to you. It also may include allowing third parties to receive certain information, such as cookies IP address and/ or browsing behavior, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.

Depending on what Services you use, we may provide the following categories of information to third parties for these purposes:

  • For online targeted advertising purposes: demographic and statistical information, usergenerated content, device information and identifiers, connection and usage data, geolocation, and social media information.
  • For sharing with third parties to send you relevant offers and promotions: contact and account registration information; demographic and statistical information, user-generated content, and geolocation.

If you would like to opt out of our use of your information for such purposes that are considered a "sale" under California law, you can submit a sale opt-out request by emailing us at support@lucrasports.com.

complaints

If you have any concerns or a complaint about a breach of your privacy or the way we have handled your personal information, please email details of your complaint to support@lucrasports.com. We will then investigate your complaint and provide you with our response within a reasonable timeframe.

how we respond to "DO NOT TRACK" signals

Some web browsers may transmit "do not track" signals to the Sites and other online services with which your web browser communicates. There is no standard that governs what, if anything, the Sites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise our policy on responding to these signals.

prohibited users

As indicated in our Terms of Use, employees, operators, or consultants of a sports governing body are prohibited from participating in certain Contests where such employee, operator or consultant is prohibited from participating in Contests by such governing body ("Prohibited Users"). For clarity, we say that examples of sports governing bodies are the National Football League, Major League Baseball and the National Basketball Association. We may report any participation in the Services or in any Contests by any Prohibited Users to the applicable sport's governing body.

how to contact us

If you would like to contact us for any reason regarding our privacy practices, our privacy notice, or to make a privacy complaint or if you want to report any security violations to us, please e-mail us at the following address: support@lucrasports.com.

changes and updates to this privacy policy

This Privacy Policy may be revised periodically, and this will be reflected by the "Last Updated" date below. Please revisit this page to stay aware of any changes. If a revision to this Privacy Policy, in our sole discretion, is material, we will notify you by contacting you through the email address associated with your account. Please note that at all times you are responsible for ensuring that the personal information provided to us is up to date.

If you do not wish to permit changes in our use of your personal information, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Your continued use of the Sites, Application or Service following notice of such changes will indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes, with the understanding that the modified terms and conditions applies to all of your personal information, including the personal information collected before the change went into effect.

Last Updated: October 6, 2020