LuckyShort Website Privacy Policy

Effective Date: September 11, 2024

Feedback Channel: service.luckyshort@outlook.com

Welcome to use the services provided by LuckyShort (hereinafter referred to as "we")! The services covered by this Privacy Policy (hereinafter referred to as "this Policy") include: the LuckyShort website.

We are committed to protecting the privacy rights of all users (hereinafter referred to as "you") who use our services. When you use our services, we may process your personal information. This Policy aims to help you understand how we collect, store, use, and manage information (including personal information) related to the services, as well as the rights and choices you have regarding your personal information held by us.

Please note that this Policy only applies to the information we process through your use of our services. This Policy does not apply to the information processing behaviors of other companies and organizations that advertise our services or place links on our website, nor are we responsible for their information processing behaviors. Any link to these third-party websites does not constitute our sponsorship, endorsement, or affiliation with these third parties.

By using our services, you confirm that you have read and understood this Policy, and agree that we will process your personal information in accordance with the provisions of this Policy.

Before using our services, please be sure to read and fully understand this Policy. If you do not agree to this Policy, it may cause our services to not function properly or fail to achieve the expected purpose, so please stop accessing/using our services immediately.

This Policy will help you understand the following contents:

1. Who determines why and how we process your personal information
2. How we collect and use your personal information
3. How long we will retain your personal information
4. How we protect your personal information
5. When we will share your personal information
6. How we protect children's personal information
7. International Transfers
8. How to manage your personal information
9. Notifications and Revisions
10. How to contact us

Appendix:

• Appendix 1: Supplementary Information for Residents of California
• Appendix 2: Supplementary Information for Users in the European Economic Area (EEA), the United Kingdom, and Switzerland

1. Who Determines Why and How We Process Your Personal Information

We determine the purposes and methods of processing your personal information and are responsible for your personal data. For residents of the European Union, when you use our services, we are the controller of your personal information.

2. How We Collect and Use Your Personal Information

We collect your personal information mainly to make your use of our services more convenient and satisfactory, and the information you provide helps us achieve this goal.

You understand and agree that we hope to provide improved products and services. Therefore, we will continuously improve our products and services, which means that with the iteration, expansion, and upgrading of services, we may launch new services or business functions, or readjust business functions, which may require collecting new types of personal information or changing the purposes and methods of processing personal information.

(a) Types of Personal Information We Collect from or About You

Personal information refers to various information recorded in electronic or other forms related to an identified or identifiable natural person, excluding information that has been anonymized. The definition of personal information may vary in different jurisdictions in accordance with applicable laws and regulations.

LuckyShort collects the following information about you. As described in more detail below, we use this information (in some cases in combination) to operate, customize content, personalize and adjust and improve our services, and send you information about new features, etc., or personalized information, including for marketing and promotional purposes based on your preferences.

(i) Account Creation and Login

You can log in to our services using third-party login services (such as Facebook Connect, Apple ID, or Google ID). These third-party login platforms will verify your identity and provide you with the option to share certain personal information (such as your account information, profile picture, and email address) with us to pre-fill our registration form. Third-party login platforms such as Facebook Connect will allow you to choose to post information about your activities on our services to your personal homepage on that platform to share with others in your network.

When you register to use our services, we will create a unique LuckyShort User ID (hereinafter referred to as "User ID") to track your use of our services. Specifically, this User ID will be associated with your profile information to track your operations on our website.

(ii) Browsing Our Services and Watching Videos

When you interact with or use our services, we automatically collect certain information about your device and your use of the services. This may include your browser type and language, IP address, device ID, hardware and software information, advertising ID, standard server log information, your connections and interactions with other users, your purchase records with us, and social media data (if you have linked your account and in accordance with your sharing permissions).

(iii) Recharge and Payment

When purchasing our services, you can choose payment services provided by third-party payment institutions (such as Apple Pay and Google Pay). When you make a payment through Google Pay, we may need to share your order number, User ID, and other information with Google Pay to allow it to confirm your payment instructions and complete the payment.

To display your account's order information and protect your after-sales rights and interests, we will collect order information, transaction and consumption records, and virtual property information generated during your use of our services to display such information to you and manage your orders.

In the event of a transaction refund, you can apply for a refund from the third-party payment institution, which may require you to provide personal information to process the refund request.

(iv) Contacting Us and Customer Service

When you contact our customer service or communicate with us in other ways, we may collect your email address and any other personal information you provide to us.

(v) Lottery Activities

We may provide you with opportunities to participate in lottery activities through our services. If you participate, we will ask you to provide certain personal information. Participation in these lottery activities is voluntary, so you can choose whether to disclose such information. The required information usually includes your User ID and registration information. We use this information to manage the lottery activities and notify the winners.

(vi) Providing You with Security Protection

To improve the security of your use of our services, protect the personal and property safety of you or other users or the public, better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, and network intrusions, and more accurately identify behaviors that violate applicable laws and regulations or the relevant rules of our services, we may collect, use, or integrate your account, transaction, device, and log information, as well as information shared by our partners with your authorization or in accordance with applicable laws and regulations, to comprehensively judge the risks of your account and transactions, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with applicable laws and regulations.

(vii) Improving Our Services

In the process of your using our services, we may track your operations to provide you with better services. We or our third-party partners and analytics service providers may use standard tracking technologies (such as web beacons, APIs, scripts, and tags) to identify your computer/device, "remember" information about your access to or use of our services (such as your preferences or User ID), and help us understand the pages and functions you use, etc. Such information may be associated with or combined with other personal information of yours that we process (such as your User ID, unique device ID (persistent/non-persistent), hardware type, device manufacturer, type and version of operating system (OS), operating system language, your unique device ID, your time zone, device screen size, general geolocation information (based on your Internet Protocol (IP) address), your email address (if you have connected Facebook or Google+), the frequency of your use of the services, function usage, usage statistics, events occurring within the services, aggregated usage and performance data, etc.), for purposes including improving service quality, customizing recommendations based on your interests, providing and personalizing our services (including making our services easier to use), and for fraud prevention, security, and identity verification purposes.

Device identifiers/information (such as device type, hardware model, device manufacturer, device operating system and its language, or other technical data (such as screen size)) or combinations of such data will also be collected and used to determine device compatibility and optimal settings.

If you need help managing preferences related to tracking technologies used on our services, please refer to the guidelines provided by your device manufacturer, operating system developer, or personal web browser. We will not associate the information stored in the analytics software with any information that can identify you personally in the mobile application.

(viii) Advertising for Our Services

Some of our services adopt advertising delivery technologies that use Cookies, transparent GIFs, web beacons, tracking pixels, and other similar technologies to deliver interest-based advertisements about third-party products and services to you. We may also promote our services on third-party websites through our third-party advertising partners. You may also see advertisements for our website on other services (such as Facebook). After clicking one of these advertisements and visiting our website, you will become a user of our services.

(b) How We Collect and Obtain Your Personal Information

(i) Information You Provide

When you pay for our services, create a LuckyShort account, or use our services in other ways, we may ask you to provide certain personal information, such as your email address, account name and number, and transaction information.

Please note that continuing to use our services means you acknowledge that we cannot guarantee the privacy of personal information you choose to publicly post on the Internet (including social media pages).

(ii) Information We Automatically Obtain About You

When you use our services, the information we collect, aggregate, track, and record includes but is not limited to logs, location, and device information.

(iii) Activity Information When You Communicate with Us

When you call us, send us an email, or provide comments, chat messages, and opinions to us through our services, we may ask you to provide personal information.

(iv) Information We Obtain from Third Parties

You can log in to our website using third-party social networks or authentication services (such as Apple or Google). These services may share your personal information with us, such as your account name and email address.

The data we obtain from these third-party services depends on your privacy settings on the social network. Before linking or connecting third-party websites and services to our services, you should always check and adjust your privacy settings on third-party websites and services if necessary.

You may interact with links or social media features of third parties. If you click on a link to any of these websites, please note that your interaction with these websites is governed by their privacy policies, not this Policy. We recommend that you review the policies and terms of use of these third parties before submitting any information to these websites.

If you click on a link to any of these websites, please note that we are not responsible or liable for their services or practices.

(c) How We Use Your Personal Information

The information we collect through our services (whether used alone or in combination) is used for the purposes described in this Policy or the purposes disclosed to you when providing the services. For example, we may use your information to:

• Create user accounts to allow users to use our website services;
• Identify and recommend you to connect with other users of our services;
• Facilitate sharing on social networks;
• Operate, develop, and improve our website and other services;
• Understand you and your preferences to enhance and personalize your experience and enjoyment of using our services;
• Provide you with personalized service recommendations;
• Respond to your comments and questions and provide customer service;
• Set up and maintain the account you registered;
• Identify, repair, and fix vulnerabilities and service or function errors;
• Deliver advertisements and measure advertising effectiveness;
• Send you service-related information, including confirmation information, invoices, technical notifications, updates, security alerts, and support and management information;
• Provide you with personalized advertisements;
• Communicate with you via email about promotions, rewards, upcoming events, and other news about products and services provided by LuckyShort and our selected partners in accordance with your marketing preferences. If you no longer wish to receive our marketing or promotional communications, you can unsubscribe at any time using the details listed in "How to Contact Us";
• Personalize the content and experience on our services, including providing you with reports, recommendations, and feedback based on your preferences;
• Optimize or improve our products, services, and operations;
• Protect the integrity of our services, enforce our Terms of Service and other applicable terms, including detecting and preventing fraud and unauthorized activities, protecting our systems and services, preventing hacking, cheating, and spam, maintaining the security and fairness of our services overall, and detecting, investigating, and preventing activities that may violate our policies or be illegal;
• Detect security incidents, prevent malicious, fraudulent, deceptive, or illegal activities, and prosecute those responsible for such activities;
• Conduct statistical, demographic, and marketing analysis of users of our services.

We may use the information collected from or about you to create aggregated data or anonymized data that does not specifically identify you.

3. How Long We Will Retain Your Personal Information

We will retain the personal information we collect for different periods of time based on the type of personal information collected, the way it is used, and the configurations you set for our services. The details are as follows:

• (a) Some personal information can be deleted by you yourself: for example, the personal information you save in your account, or choose to be automatically deleted after a set period of time. We will retain this personal information until you delete it or choose to have it deleted.
• (b) Other personal information will be automatically deleted or anonymized after a set period of time, such as advertising data in our system.
• (c) We will retain some personal information for a longer period of time when necessary for legitimate business or legal purposes (such as security, fraud and abuse prevention, or financial record keeping).
• (d) If we terminate our services or operations, we will immediately stop collecting your personal information, notify you in advance in accordance with applicable laws and regulations, and delete or anonymize your personal information after the termination of services or operations, unless otherwise specified by applicable laws and regulations or regulatory authorities.
• (e) When you delete personal information, we will make every effort to ensure that your personal information is safely and completely deleted from our servers, or retained only in an anonymized form. We strive to ensure that our services protect information from accidental or malicious deletion. Therefore, there may be a delay from when you delete certain information until its copies are deleted from our active systems and backup systems.

4. How We Protect Your Personal Information

We take reasonable and appropriate measures to protect your personal information from unauthorized access and prevent third parties from losing, misusing, or tampering with your personal information.

(a) Data Security Technical Measures

We will adopt industry-standard security protection measures, including establishing reasonable systems and security technologies to prevent your information from being unauthorized accessed, used, and modified to avoid data damage or loss. A variety of encryption technologies are used in our services. For example, in some services, we will use encryption technologies (such as SSL) to protect your information, encrypt it for storage, and isolate it through isolation technologies. In the process of information use (such as information display and information association calculation), we use a variety of data desensitization technologies to enhance the security during information use. We adopt strict data access control and multi-factor authentication technologies to protect information and prevent illegal use of data.

(b) Access Control Measures

We only allow employees and partners who need to know your personal information to access your personal information, and have set strict access control and monitoring mechanisms for this purpose. We also require all personnel who may have access to your information to comply with appropriate confidentiality obligations. If they fail to fulfill these obligations, they may be held legally liable or have their cooperative relationship with our services terminated.

(c) Other Information Protection and Security Measures We Take

We manage and regulate the storage and use of information by establishing a data classification and grading system, data security management specifications, and data security development specifications. We conduct comprehensive security control of data through information access confidentiality agreements, monitoring, and auditing mechanisms. And we are committed to improving security awareness when providing and operating services.

We have an industry-advanced data center data security management system centered on the data life cycle, which improves the security of the entire system from multiple dimensions such as organizational construction, system design, personnel management, and product technology.

(d) Security Tips for You

When you communicate with third parties or purchase services through our services, it is inevitable to disclose your information to the other party or potential other party. Please note that the Internet is not an absolutely safe environment. Due to the limitations of technology and risk prevention, even if we have made every effort to strengthen security measures, we cannot always guarantee 100% security of information. Please understand that the systems and communication networks you use to access our services may have problems due to circumstances beyond our control. Although we sincerely strive to store the collected information in a secure operating environment inaccessible to the public, we cannot guarantee the absolute security of information during transmission or when stored on our systems. In addition, although we strive to ensure the integrity and security of our networks and systems, we cannot guarantee that our security measures will prevent third parties from illegally obtaining this information. We do not guarantee or state that your information will be free from loss, misuse, or tampering by third parties.

(e) Security Incident Handling

In response to potential risks such as personal information leakage, damage, and loss, we have formulated a number of systems that clarify the classification standards of security incidents and vulnerabilities and the corresponding handling processes. We have also established a special security incident emergency response strategy. In accordance with the requirements of the security incident handling specifications, we will activate security plans for different security incidents, conduct loss prevention, analysis, positioning, and formulate remedial measures, and track and combat them in conjunction with relevant departments.

If a security incident that may pose a high risk to your rights and freedoms occurs, we will notify you in a timely manner in accordance with the requirements of applicable laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions we provide for you to prevent and mitigate risks, the remedial measures provided for you, etc. At the same time, we will promptly notify you of the situation related to the incident via email, letter, phone, etc. When it is difficult to notify each information subject individually or it may involve unreasonable efforts, we will issue an announcement in a reasonable and effective manner.

In addition, we will take the initiative to report security incidents in accordance with the requirements of applicable regulatory authorities.

5. When We Will Share Your Personal Information

Unless we obtain your approval or as otherwise described in this Policy, LuckyShort will not share your personal information. We may disclose your personal information in the following circumstances:

(a) Obtaining Your Consent

We may share your personal information with certain third parties after obtaining your approval and consent.

(b) Service Providers

We will engage other companies and individuals to provide services on our behalf for the purposes described in this Policy. Examples of these services include data analysis, IT and related services, payment processing, sending emails, providing customer support, and security fraud detection services. These agents and service providers may have access to your personal information in the process of providing services for LuckyShort and have contractual obligations to maintain the confidentiality and security of your personal information. We also require them to use personal information only on our behalf and for purposes consistent with this Policy.

We entrust the following service providers to collect information:

(i) Google Analytics

Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with and use our services, compile reports on our service activities, and provide other services related to our service activities and usage. The technologies used by Google may collect information such as your IP address, time of access, and whether you are a returning visitor. Our services do not use Google Analytics to collect information that can identify you personally.

The information generated by Google Analytics will be transmitted to and stored by Google and is subject to Google's Privacy Policy. To learn more about Google's partner services and how to opt out of Google's analytics tracking, please click here.

(c) Third-Party Plugins

Cooperate with third-party applications and platforms (such as Facebook Connect), which allow you to choose to post information about your activities on our website to your personal homepage to share with others in your network. This Policy does not apply to your use of any such third-party applications and services, and we are not responsible for how these third parties collect, use, and disclose your information. We encourage you to review the privacy policies of these third parties to learn more about their information and privacy practices before connecting to or using their applications or services.

(d) Disclosure to Protect Us or Others

We may disclose your information in accordance with the requirements of applicable laws and regulations, such as complying with subpoenas, or when we believe it is appropriate to comply with applicable laws and regulations; investigating fraud, responding to government requests, enforcing or exercising our rights; or protecting the rights, property, and safety of us, our users, or others. This includes exchanging information with other companies and organizations to prevent fraud.

(e) Disclosure in the Event of Merger, Sale, or Asset Transfer

In the event of any merger, sale of our assets, or financing or acquisition of all or part of our business by another company, we may share your information. If there is any change in the ownership or use of your personal information, we will notify you via email and/or a notice on our services.

(f) Advertising Partners

Through our services, we may allow third-party advertising partners to set up technologies and other tracking tools to collect information about your use of our services and your device.

Such information includes GAID (Google Advertising ID on Android devices) or IDFA (Advertising Identifier on iOS devices), region (i.e., location using a specific language), geolocation information (with your consent), and IP address. This Policy does not bind our third-party advertising partners, as they have their own privacy policies. We have no access to or control over such third parties. In addition to identifiers, these third parties may also collect information related to the following:

• Advertisements served and their positions;
• Visible duration of advertisements;
• Domain type, IP address, advertisement size;
• Click-through rate (i.e., whether the advertisement was clicked) and advertisement response.

They use this information (alone or in combination with information about you they collect when you use third-party websites or services) to: (i) implement technologies to deliver advertisements to your device and verify click-through rates and/or installations; (ii) provide you with advertisements more relevant to our services (for example, providing you with relevant offers on our website); (iii) enable offer walls that allow you to choose from a variety of rewarded advertisements or market research offers; (iv) track results and measure advertising effectiveness; (v) improve the accuracy of their targeting and measurement systems. We recommend that you review the privacy policies of these advertising partners for more information.

You can learn how to opt out of mobile app tracking by certain ad networks through your device settings and resetting the advertising ID on your Apple or Android device. For more information on how to change these settings, please visit:

• Apple: http://support.apple.com/kb/HT4228
• Android: https://support.google.com/ads/answer/2662922
• Windows: http://choice.microsoft.com/en-US/opt-out

Please note: Adjusting your preferences as described in this section does not mean that you will no longer receive advertisements. It only means that the advertisements you see may be less relevant to your interests. Our advertising partners will still use your device's advertising ID to deliver less relevant advertisements to you; for example, we may use it for frequency control (in other words, controlling the maximum number of times you see the same advertisement from us). You can also reset the advertising ID associated with your device in accordance with the instructions provided by your device manufacturer or operating system developer.

(g) When You Disclose Your Personal Information Publicly

6. How We Protect Children's Personal Information

We will not intentionally collect or solicit personal information from children under the age of 14 (or the age of majority in your jurisdiction), nor will we intentionally allow children to use our services. If you are a child under the age of 14 (or the age of majority in your jurisdiction), please do not send us any information about yourself, including your name, address, phone number, email address, or other personal information. No one under the age of 14 may provide any personal information. If you believe we have collected personal information from a child, please contact us using the contact information listed below. If we learn that we have collected personal information from a child, we will delete that information as soon as commercially feasible.

7. International Transfers

We may transfer the information we collect about you cross-border to other third parties, from the country or jurisdiction where you are located to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as the jurisdiction where you are located, and we will take measures to ensure that there are sufficient safeguards to realize the transmission of information and the use and disclosure of information about you (including personal information) as described in this Policy.

8. How to Manage Your Personal Information

(a) Your Choices Regarding the Information You Provide

If you do not want to provide personal information to LuckyShort, you can choose not to provide it. If you choose not to provide us with personal information, we may not always be able to provide you with the services you want. For example, without providing an email address, you will not be able to create an account to pay for our services.

(b) Your Choices Regarding Information Provided by Third Parties

You can control how third parties collect and share your information by changing your preferences or choosing not to accept collection directly from third parties. Before disclosing information to third parties, we recommend that you review their respective privacy policies for more details.

(c) Your Choices Regarding Marketing and Advertising

You can choose how we use your personal information and update your preferences at any time:

• To opt out of individual contests or promotions, or choose to no longer receive our marketing communications, simply contact us using the details listed in "How to Contact Us". If you choose to no longer receive our email marketing communications, please note that we may still occasionally contact you regarding the status of your account, such as notifying you that your account may be about to expire, or other service-related information.
• To disable the collection of information related to advertising campaign effectiveness or analytics data by selected tracking technologies and stop receiving personalized advertisements on our services, please refer to the guidelines provided by your device manufacturer, operating system developer, or personal web browser for help in managing preferences for tracking technologies used on our services.

(d) Accessing and Deleting Your Information

You can cancel your LuckyShort account or delete the email associated with your account by contacting us using the details listed in "How to Contact Us".

If you want to access or view the personal information we hold about you, or if you have any doubts about the way we use your personal information for any reason, or want to correct or request us to delete such personal information, you can also contact us using the details listed in "How to Contact Us".

If you are a resident of California or a user in the European Economic Area (EEA), the United Kingdom, or Switzerland, to learn more about your rights regarding personal information, please refer to the relevant Appendix sections below.

9. Notifications and Revisions

We may update this Policy from time to time to reflect changes in our information practices. If we make any material changes, we will notify you via email (sent to the email address specified in your account) or via a notice on our services before the changes take effect. If applicable data protection laws and regulations require us to provide you with more detailed notice or seek your consent for any such changes, we will do so. You can check the "Last Updated" date displayed at the top of this Policy to learn the latest update time of this Policy. We encourage you to review this page regularly for the latest information on our privacy practices.

10. How to Contact Us

We will protect your personal information in accordance with this Policy. If you have complaints and reports about cybersecurity, or any questions, comments, or suggestions about this Policy and your information, as well as questions about the privacy practices of our services, please contact us in the following ways:

• (a) Send an email to service.luckyshort@outlook.com;

In general, we will process your questions, comments, or suggestions in a timely manner after receiving and verifying your user identity. If you are not satisfied with our processing process, you can complain or report to the government department responsible for personal information protection. You can learn more about your rights by contacting your local data protection authority.

Appendix 1: Supplementary Information for Residents of California

If you are a resident of California, the following information also applies to you and supplements the information in this Policy regarding your use of our services.

Information We Collect and Sources of Information

Our Policy has described the information we collect and the sources of information - see Section "2 How We Collect and Use Your Personal Information" above. This section organizes this information around the categories of personal information specified in the California Consumer Privacy Act (CCPA).

In the past 12 months, we have collected the following information for the following purposes:

• Identifiers: Including, for example, your account name, email address, Internet Protocol address, unique personal identifier, User ID, third-party account name, and other online identifiers. We obtain this information automatically when you provide it to us or when you interact with our services.
• Internet or other electronic network activity information: Including, for example, browser type and language, device and hardware information, usage data, and other information about your interaction with our services. We obtain this information automatically when you interact with our services.
• Commercial information: Including consumption history or tendencies. This allows us to provide technical functions, develop new services, and analyze your usage. We obtain this information directly from you or automatically when you interact with our services.
• Geolocation data: Including, for example, your region and general geolocation information (based on your IP address). We obtain this information automatically when you provide it to us or when you interact with our services.
• Audio, video, and other electronic data: Including audio, electronic, visual, or similar information, such as any interactions you have with us (e.g., for customer service purposes) or with other users (e.g., chats), such as photos, videos, audio, any information you submit on forums, chats, or message boards, and feedback or recommendations you provide about our services. We obtain this information automatically when you provide it to us or when you interact with our services.
• Profiles and inferences: Including inferences drawn from any of the above-identified information to create profiles reflecting preferences, characteristics, tendencies, behaviors, attitudes, intelligence, abilities, and aptitudes. We obtain this information automatically when you interact with our services.

We collect personal information directly from you, automatically from your use of our services, from non-affiliated parties (for example, when you connect with us using a third-party login function), and obtain additional personal data about you by using or combining personal data, as described in Section "2 How We Collect and Use Your Personal Information" above.

How We Use and Share Information

We collect and use personal information for the commercial and business purposes described in Section "2 How We Collect and Use Your Personal Information".

Unless we obtain your approval or as otherwise described in this Policy, LuckyShort will not share your personal information. You can find more information in Section "5 When We Will Share Your Personal Information" above. In the past 12 months, we have disclosed the following categories of personal information for commercial purposes:

The above identifiers; Internet or other electronic network activity information; demographic information/protected classification characteristics; commercial information; geolocation data; audio, video, and other electronic data; and profiles and inferences.

We do not sell users' personal information. However, we allow certain third-party advertising and analytics partners to collect information from consumers through our services for the purpose of delivering more relevant advertisements, conducting advertising campaign measurement and analysis, and advertising fraud detection and reporting. The information collected by our partners includes GAID (Google Advertising ID on Android devices) or IDFA (Advertising Identifier on iOS devices), region (i.e., location using a specific language), geolocation information (with your consent), and IP address.

Your Privacy Rights

Under the CCPA, residents of California have the following rights:

• Right to Know: You have the right to request that we disclose the personal information we have collected, used, and disclosed in the past 12 months, as well as information about our data practices;
• Right to Delete: You have the right to request that we delete the personal information we have collected from you;
• Right to Non-Discrimination: We will not discriminate against you for exercising these rights.
• Right to Opt-Out of Sale: We do not sell personal information, so you do not need to opt out.
• Right to Notice of Financial Incentives: You have the right to know about any financial incentive offers and their material terms, the right to opt out of such incentives at any time, and you cannot be included in such incentives without your prior informed consent. Currently, we do not offer any such incentives.

California law also allows you to request that we and our affiliates disclose certain information about your personal information to third parties for the third parties' own direct marketing purposes. We will not disclose your personal information to third parties for their own direct marketing purposes.

Since there is currently no general consensus on how to interpret "Do Not Track" signals, we do not currently respond to "Do Not Track" signals. However, as described above, we provide you with the ability to opt out of receiving interest-based advertisements delivered using tracking technologies.

To exercise any of the above rights, or if you are an agent authorized to exercise rights under the CCPA, you can contact us using the details listed in "How to Contact Us".

Please note that to protect your information, we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as a government-issued ID.

Under the CCPA, you can exercise these rights yourself or designate an authorized agent to make these requests on your behalf. We may require your authorized agent to have your written permission to make requests on your behalf and may need to verify the identity of your authorized agent.

For more information about our privacy practices, you can contact us using the details listed in "How to Contact Us".

Appendix 2: Supplementary Information for Users in the European Economic Area (EEA), the United Kingdom, and Switzerland

If you are a resident of the European Economic Area (EEA), the United Kingdom, or Switzerland, the following information applies to the personal data collected through your use of our services.

Data Controller

LuckyShort is the data controller of your personal data.

Legal Basis for Processing Your Personal Data

We collect, use, and share your personal data based on the following bases:

• Performance of a Contract: We need to process your personal data to perform the contract between us for the provision of services, including: managing your account with us; providing contests or promotions you participate in; supporting purchases you make; providing service functions; or providing customer support.
• Consent: We process your personal data based on your consent. This includes, for example, providing: newsletters, direct emails, and surveys about our services; targeted advertising on the website; and certain other marketing functions.
• Legitimate Interests: We process your personal data where we have a legitimate interest in doing so and those interests do not override your fundamental rights and freedoms related to data privacy. This includes, for example, processing: to provide you with the required customer service or technical support; to debug and improve our current and future services; to provide you with exclusive content, personalize your experience of using our services, and contact you in accordance with applicable marketing preferences; and to establish, exercise, or defend legal claims, or whenever a court acts in a judicial capacity.
• Legal Obligations: We also process your personal data to comply with the legal obligations we are subject to.

International Data Transfers

The personal data we collect may be transferred to, stored in, and processed in the United States or any other country where we or our affiliates, partners, or service providers have facilities or conduct business. We will ensure that the transfer of personal data to third countries or international organizations is subject to appropriate safeguards.

Your Privacy Rights

You have the following rights regarding your personal data:

• Right to Access, Rectification, and Deletion: You have the right to view, correct, update, or request the deletion of your personal data, as detailed in the "Accessing and Deleting Your Information" section above.
• Right to Object: In cases where we process your personal data based on legitimate interests, you may object to the processing of your personal data on grounds related to your particular situation. For example, you can control the extent to which we market to you, and you have the right to ask us to stop sending you marketing information at any time. You can use the methods described in the "Your Choices" section above.
• Right to Withdraw Consent: In cases where we process your personal data based on your consent, you have the right to withdraw your consent to our further use of your personal data at any time. You can update your marketing preferences using the methods described in the "Your Choices" section above.
• Right to Data Portability: In certain circumstances, you may request that we transmit or transfer the personal data you have provided to us.

For each of the above rights, you can contact us using the details listed in "How to Contact Us".

We hope to be able to resolve any questions you may have about the way we process your personal data. However, if you have an unresolved issue, you also have the right to lodge a complaint with the relevant data protection authority. You can lodge a complaint in the Member State where you reside, work, or where the data protection law is alleged to have been violated. For more information, please contact your local data protection authority.