1. Personal Data – any information about a natural person, identified or identifiable by one or several factors defining his/her physical, physiological, genetic, psychic, economic, cultural or social identity, including the IP of the device, location data, online identifier and information collected through cookie files and other similar technologies. This definition includes “Personal Information” as defined in the California Privacy Notice section below as well as any similar terms defined under applicable data protection law.
2. Policy – this Privacy Policy for VIP Shop.
3. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC.
4. Website – an online service “VIP Shop” run by Huuuge at the address https://vip.billionaire-casino.com/ and https://vip.huuugecasino.com/.
5. User – any natural person visiting the Website or using one or more Services or functionalities.
6. EEA – countries in the European Economic Area.
   

Any other definitions should have the same meaning as in the Terms of Use for VIP Shop.

In connection with the User’s use of the Website, Huuuge Global Limited as Website and Service provider, as described in the Terms of Use for VIP Shop together with Huuuge Games sp. z o. o as joint controllers (and jointly named “Huuuge”) collects data with the scope necessary to provide therespective Services and as the case may be, maintain the relation with the User or collects information about the User’s activity on the Website. The detailed rules and purposes of processing the Personal Data collected during the use of the Website by the User are described below.

USE OF THE WEBSITE

1. When the User enters a  Website, it has to be connected  via  Facebook account, as a result Huuuge will receive certain data about the User from Facebook: user ID (Facebook ID).
   Facebook Ireland Limited (“Facebook Ireland”) and Huuuge are joint controllers when it comes to using a Facebook tool which enables the User to connect User’s Facebook accounts to the Website (Facebook Login). The joint controller addendum can be found here.
   
2. Information on how Facebook Ireland processes Personal Data, including the legal basis Facebook Ireland relies on and the ways to exercise data subject rights against Facebook Ireland, can be found in Facebook Ireland’s Data Policy. Facebook Ireland is responsible for enabling data subjects’ rights with regard to the Personal Data stored by Facebook Ireland after using the Facebook tool.
3. Huuuge itself may also collect User’s Personal Data such as IP address or other identifiers and information collected through cookie files and other similar technologies.
4. Personal Data are processed:
   1. to provide Services (connected with running and maintaining an account, to identify the player)on this Website – the legal basis for the processing is that the processing  is necessary for the performance of a contract (Article 6(1)(b) of GDPR);
   2. to maintain relationships with Huuuge’s  players, to possibly determine and pursue claims or defend against claims – the legal basis for the processing is the legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR) to protect its rights.

   PLACING ORDERS (USING PAID SERVICES ON THE WEBSITE)
   

5. Placement of a purchase order (to purchase Virtual Goods such as in-game virtual currency, level boosts, skins, etc) by a Website User entails the processing of his/her Personal Data. Processing data such as User identifiers, User’s name, e-mail address, billing address, device ID, IP address/location, order ID,  information on transaction you are making, payment card details, bank account details, tax ID/status is necessary to accept and handle a purchase order.
6. Personal Data are processed:
   1. to fulfill a submitted purchase order and provide the Service – the legal basis for the processing is that processing is necessary for the performance of a contract (Article 6(1)(b) of GDPR);
   2. to perform the statutory obligations imposed on Huuuge, in particular those following from tax and accounting laws – the legal basis for the processing is legal duty (Article 6(1)(c) of GDPR);
   3. to maintain relationships with Huuuge’s  players, to possibly determine and pursue claims or defend against claims – the legal basis for the processing is the legitimate interest pursued by Huuuge (Article 6(1)(f) of GDPR) to protect its rights.
7. By purchasing our goods and services, submitting information to Huuuge  in connection with using our goods or services, an application and/or by visiting, interacting with and/or using our website, in some jurisdictions, it may mean that you are providing your consent to the collection, use and disclosure of personal information as set out in this Policy.
8. If the User purchases Virtual Goods, Huuuge’s third-party payment partner, Stripe Payments Europe, Ltd. (also as “Stripe”), will collect the billing and financial information it needs to process the User’s charges. This may include the User’s postal address, e-mail address, and data regarding credit cards and bank account details. Stripe’s privacy policy is available at https://stripe.com/privacy.
9. Stripe may share some data with Huuuge related to User’s purchases in order to enable the payments.

1. When the User visits the Website, we may collect and store some information using cookies and similar technologies, however, those are only necessary cookies and similar technologies to enable you to use this Website properly, for authentication and for security. These are indispensable for providing you the Services and you cannot opt out.
2. For this Website, we do not use cookies for marketing reasons nor for analytics. To learn more please visit our Cookies Policy. 
3. Please note, however, that our third-party payment partner may use cookies for their own purposes, which is described in Stripe cookies policy, please check here. 

1. The period of data processing (including retention) by Huuuge depends on the type of service provided and the purpose of the processing. In principle, data are processed for the entire period of providing the service or fulfilling a purchase order or until the moment of filing an effective objection to the data processing in the cases where the legal basis for the processing is Huuuge’s legitimate interest.
2. The data processing period may be extended if processing is necessary to determine and pursue possible claims or defend against claims and, after that time, only when and to the extent required by law and/or authorized by law. After the processing period, the data are deleted or as permitted by law anonymized/deidentified.

The User may have the following rights depending on jurisdiction:

1. right to information about the processing of Personal Data – on this ground Huuuge provides a natural person submitting the request with information on the processing of data, including in particular the purposes and legal grounds for processing, the scope of available data, the entities to which the data are being disclosed, as well as the planned date of data erasure;
2. right to obtain a copy of data – on this ground Huuuge provides a copy of processed data to the natural person submitting the request;
3. right to rectification – Huuuge is obliged to remove any inconsistencies or errors in the processed Personal Data and to complete them if they are incomplete;
4. right to data erasure – on this ground one may request the erasure of data whose processing is no longer necessary for any of the purposes for which the data were collected;
5. right to restriction of processing – if such a request is submitted, Huuuge shall cease to carry out operations on the Personal Data – except for operations with regard to which the User has given consent – and to store them, in accordance with the applicable retention principles or until the reasons for the restriction of data processing cease to exist (e.g. the supervisory authority issues a decision authorising further processing);
6. right to data portability – on this ground – to the extent to which the data are processed by automated means in relation to the concluded agreement or the consent given – the User issues the data provided by the data subject in a computer readable format. It is also possible to request the data to be sent to another entity, provided that this is technically practicable on the side of both the Huuuge and the designated entity;
7. right to object to processing for marketing purposes – if applicable, the User may at any time object to the processing of Personal Data for marketing purposes, without having to justify such objection;
8. right to object to other processing purposes – the User may at any time object – on grounds relating to his or her particular situation – to the processing of Personal Data that is carried out on the basis of a legitimate interest of Huuuge (e.g. reasons related to property protection); such objection should be justified;
9. right to withdraw consent – if the data are processed on the basis of the consent given, the User has the right to withdraw it at any time, which, however, does not affect the lawfulness of processing based on consent before its withdrawal;
10. right to complain – You have the right to complain to a data protection authority about our collection and use of your personal information which is to be in Huuuge’s case –the leading protection authority is the Polish President of the Office of Data Protection. You may also contact your local data protection authority. For more information, please contact such authority, however, we always encourage you to first contact Huuuge at dpo@huuugegames.com.

1. In connection with provision of Services, Personal Data may be disclosed to external entities, including in particular the payment operator (Stripe Payments Europe, Ltd.), service providers and vendors responsible for maintenance of IT systems, banks, entities providing accounting services and entities related to Huuuge, including companies from its group. We may also share your Personal Data with any other corporate entities within the same corporate group (including parent company and subsidiaries) (“Affiliated Entities”)  if it is necessary to provide Services.
2. Personal Data may also be disclosed in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
3. Huuuge reserves the right to disclose Personal Data to relevant authorities or third parties which will demand that they are provided such information pursuant to an appropriate legal basis and in compliance with prevailing laws. Personal Data also may be shared to protect the rights, property, life, health, security and safety of us, the Website or anyone else or to detect and prevent fraud.

User’s Personal Data collected in connection with the provision of services may be transferred across jurisdictions and outside the country or province in which you reside (to our “Affiliated Entities”, business partners or service providers located in the EEA or outside, including the United States, Israel  and possibly other countries), in which case, your information will be subject to the laws of that foreign jurisdiction which may differ from those in your jurisdiction and may be available to government authorities under lawful orders and laws applicable there. For example, Personal Data may be transferred by the payment operator Stripe Payments Europe, Ltd. to its affiliate Stripe, Inc. in the US. Where required by applicable law, Huuuge takes reasonable steps to ensure that such User’s data is treated securely and lawfully and that transferred Personal Data is subject to suitable safeguards, such as application of standard contractual clauses issued by the European Commission  or transfer to “approved” territories.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. The personal data we receive are often encrypted.

Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

1. Data Protection Officer (the “DPO”) at Huuuge, who is the person responsible for all matters related to data protection and privacy matters. You can reach Huuuge’s DPO at the following address:ATTN: Data Protection Officer
   Huuuge Games sp. z o.o.
   Storrady Świętosławy 1/501, 71-602 Szczecin, Poland
   dpo@huuugegames.com
2. If you have any service-related issue, please contact us at support@huuugegames.com instead of contacting the Data Protection Officer.

Huuuge may update its Privacy Policy from time to time with or without notice,  in compliance with applicable laws. When Huuuge makes changes to the Privacy Policy, Huuuge will change the “Last Updated” date. All changes shall be effective from the date of publication unless otherwise provided in any notification of the changes.

1. 1. These additional disclosures apply only California residents and provide information on how Huuuge collects, uses, discloses and otherwise processes Personal Information of residents of the State of California, as well as information about the additional rights to know and delete within the scope of the California Consumer Privacy Act of 2018 (the CCPA) and the means to exercise those rights.
   2. Terms in this California Privacy Notice section of Policy mean the same as they are defined elsewhere in the Policy, if not defined in this policy, as defined in the CCPA.COLLECTING PERSONAL INFORMATION
   3. The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household” and the use of Personal Information in this Section has this meaning.
   4. Huuuge has collected the below the categories of Personal Information, as well as the source of the Personal Information, and Huuuge business purposes for collecting the Personal Information:
      

      Category of Personal Information	Source of the  Personal Information
      Identifiers (For example: real name, alias, postal address, unique personal identifier, online identifier, IP address, device or WiFi location)	Huuuge Users Huuuge Users’ devices Social networks (for example, Facebook) Partners (e.g. payment partners)
      Customer records: (For example: mailing address, telephone number)	Huuuge Users Huuuge Users’ devices Social networks (for example, Facebook)
      Commercial or Transaction information (For example, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, bank account details, payment card details)	Huuuge Users  Huuuge Users’ devices Partners (e.g. payment partners)
      Geolocation data (For example,  IP address)	Huuuge Users  Huuuge Users’ devices Partners (e.g. payment partners)

   5. Huuuge uses  the Personal Information collected above for the following business purposes:
      1. providing Services to Users connected with this Website and possible sharing with third-party payment partners,
      2. complying with the laws (tax and accounting obligations with respect to the Services);
      3. protecting the safety and security on this Website protecting Huuuge rights and property in connection with the Services and this Website preventing fraud or potentially illegal activities, and to enforce Huuuge Terms of Use for the VIP Shop.;

      DISCLOSURE OF PERSONAL INFORMATION

   6. Huuuge discloses the Personal Information collected above with the following categories of third parties:
      1. entities within Huuuge corporate group;
      2. software providers (e.g., storage providers);
      3. payment partner;
      4. payment partner;

      as required by law.
      Huuuge does not sell and has not sold Personal Information of California residents to third parties for a commercial purpose, regardless of a User’s age.

      USER’S CALIFORNIA PRIVACY RIGHTS

   7. In addition to any other rights under the law or elsewhere in the Privacy Policy, California residents have the right to the following:

   Right to Know

   1. California residents have the right to request that Huuuge discloses certain information about Huuuge collection and use of User personal information over the past 12 months.
      1. The categories of personal information Huuuge collected about the User.
      2. The categories of sources for the personal information Huuuge collected about the User.
      3. Huuuge business or commercial purpose for collecting that personal information.
      4. The categories of third parties with whom Huuuge share that personal information.
      5. The specific pieces of personal information Huuuge collected about the User (also called a data portability request).
      6. If Huuuge disclosed the User personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
      7. Identifying the personal information categories that each category of recipient obtained.
   2. Huuuge can only provide User with this information if User send a verified request, which is explained further below.
      

   Right to Delete

   3. User have the right to request that Huuuge deletes User’s Personal Information that Huuuge has collected from User and that Huuuge have retained, subject to certain exceptions.
   4. Once Huuuge receives and confirms User verified request, Huuuge will delete (and request to Huuuge service providers the same) User Personal Information that Huuuge has collected and retained, unless an exception applies.
   5. Huuuge can only delete User’s Personal Information if User send Huuuge a verified request, which Huuuge explains further below.
      

   Other Rights

   6. User also has the right to designate an authorized agent to make a request under the CCPA on its behalf and the right not to be discriminated against if User exercise any of its rights with Huuuge under the CCPA.
   7. In order to be authorized to act on User behalf, User authorized agent will need to provide Huuuge with proof that they have written permission to act on User behalf. The request will also need to be a verified request.
   8. Users have the right not to receive discriminatory treatment by us for the exercise of any your rights.
      

   Making a Verified Request

   9. In order to exercise User rights under the CCPA, Huuuge will need to get from User a verified request. There are two ways to send Huuuge a verified request:
      1. The first way is to send Huuuge the request through its games. Please reference “CCPA” in User request.
      2. The second way is to send an email to dpo@huuugegames.com. Please reference “CCPA” in User request.
   10. Please makes sure that User includes sufficient information in its request as to what User wants from Huuuge. For example, if User wants Huuuge to delete its data, please tells Huuuge that. If User wants to request a copy of its data, please tells Huuuge that.
   11. Huuuge will confirm receipt of your request within 10 days. Huuuge may need to verify User identity before processing any request; but Huuuge will try to limit the additional Personal Information that Huuuge collects in order to process User request. Huuuge reserves the right to decline a request to exercise rights under CCPA, particularly if Huuuge is unable to verify User identity, in accordance with the CCPA.
   12. If User is using an authorized agent, the authorized agent will still need to submit a request as above along with proof of the authorization.

   SHINE THE LIGHT REQUESTS

   8. Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. Personal Data The company is required to respond to this request once per calendar year. Inasmuch as the above information is not already provided by Huuuge, Huuuge California-resident Users should make any such request through the Contact Us link found in Huuuge games or by contacting the DPO using the contact information in this Privacy Policy. When User contacts Huuuge, please makes sure to reference “Shine the Light” in its request.
   9. If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at the email address set out in “Contact Us” section with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Huuuge California-resident Users should make any such request through the “Contact Data” information above. When User contacts Huuuge, please makes sure to reference “California Under 18 Content Removal Request” in its request.

ADDITIONAL IMPORTANT INFORMATION

1. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

1. Huuuge does not sell personal information of Nevada residents to third parties and Huuuge websites do not allow Users to play the games directly (the games must be downloaded or played on Facebook); however, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident and Huuuge provides Nevada residents the opportunity to opt out nonetheless.
2. To submit such a request, please contact Huuuge by email to dpo@huuugegames.com and make sure User includes the words “Nevada opt-out” in the subject of its message as well as its PlayerID.