This Privacy Policy explains how the Apcity Limited (hereinafter referred to as "Lucky Trade", "we", "us" or "our") collects, uses and discloses information about you when you use our website, mobile application or in any other interaction with us. This privacy policy is subject to change. If we were to change this policy, we will note this by changing the date at the bottom of this policy. Additionally, we may provide you with additional notice (e.g. by displaying a statement on our website or in our application. This notice could also be delivered via push-notification service). We encourage you to review this Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy. Please also review our Terms of Use carefully before using Lucky Trade.

Collection, Storage and Processing of Information

We only collect information that you provide directly to us. This can be any interaction with our services, for example by creating an account, by using our services ("Lucky Trade") in any way or by requesting customer support. The types of information we may collect include your name, email address, profile picture and any other information you choose to provide. The Android application is connected and synchronized with your Google Account, so it is required to provide the Google ID in order to use it. The iOS application uses Apple iCloud to sync the portfolio and other settings of the user.

When accessing our services, we will collect information about you, including but not limited to the following:

• Creating or deleting orders
  
• Buying or selling stocks or assets
  
• Buying in game products, as virtual currency or the ad-free version
  
• Usage information (e.g. the number of orders, number of messages, last login…)
  
• A unique device token in order to send push-messages
  
  

All of this information is automatically tagged with the current date and time of the action.

Usage of Information

We only use the collected information about you to carry out the purpose it was collected for (providing a market simulation game)

Usage includes but is not limited to

• Sharing statistics (e.g. last time online)
  
• Sharing actions (e.g. current orders, bought stocks or assets)
  
• Sending messages
  
• Sharing your progress in the toplists
  
  

Lucky Trade uses a unique device ID to send push notifications or alerts to your device. If you don't consent, you can disable these notifications on your device at any time.

Sharing of Information

We reserve our right to use publicly accessible information of you, like screenshots of the leaderboard possibly containing your name, profile picture and progress to disclose them on our website or in the App Store or in Google Play.

We reserve our right to share personal data in response to legal process or a request for information if we believe disclosure is in accordance with any applicable law, rule, or regulation of the United Kingdom, or as otherwise required by any applicable law, rule or regulation.

Use of Web Analytics Services

The following web analytic service is used to improve the user experience of our services: We use Google Analytics, a service for the marketing analysis of this website, of Google Inc. ("Google") and AppsFlyer. Google Analytics and AppsFlyer use codes consisting of text and numbers, which will be stored on your computer and which allow for an analysis of the use of the Website ("Cookies"). The information generated by the Cookie about your use of the website (including your IP address) will be transferred to and stored by Google and AppsFlyer Servers. Google and AppsFlyer will use this information, to evaluate your use of the website and application, to prepare reports about the website activities for the website operators, and to provide further services connected to the use of websites and the use of the internet. Google and AppsFlyer may transfer this information to third parties, if legally obliged to do so or if third parties process these data on behalf of Google or AppsFlyer. In no case, Google will connect your IP address with other data from Google.

You can remove or deactivate such Cookies using the settings of your computer; in such a case you might not be able to fully use all functions of this website. By using this website or the Lucky Trade iOS or Android app, you agree to the processing of your personal data by Google and AppsFlyer to the extent and purpose stated above. You can refuse to allow your data to be passed on by using a deactivation add-on for browsers under https://goo.gl/1yuGP2.

Security

Lucky Trade cannot warrant security or privacy for any data transmitted from or to our services, because the transmission of information via the internet is not completely secure. Still, we encrypt any communication between the app and our servers with state-of-the-art SSL encryption.

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.

Lucky Trade is based in the United Kingdom. The information we collect is processed in the European Union and governed by the applicable United Kingdom law and European directives.

Rights of objection, access, erasure and blocking of data

If you object to the use of your data, or if we are obligated to do so (e.g. due to breach of contractual Terms, pursuit of claims, legal or governmental regulations), we will correct and/or delete your personal data at any time without any prior notice. In case a deletion is not possible due to legal, statutory or contractual retention periods, or if it requires disproportionate efforts or prejudices your legitimate interests, the data will be blocked instead of deleted.

Contact

If you have any further questions about the collection, use and processing of your personal data, please contact us directly at: adv@apcity-ltd.com

Last updated:

December 2020