Privacy Policy

VB America, Inc. ("VB America"), operates the website https://vegasbonanza.com/ (the "Website"), and all subdomains, subpages and successor sites features, social media pages, mobile apps, tools and services relating thereto (collectively, the "Services"). This Privacy Policy details how VB America manages, collects and uses the information obtained through your use of our Services. All information you provide through your use of the Services shall be subject to the terms set forth in this Privacy Policy.

WHAT TYPE OF INFORMATION WE COLLECT

Non-Personal Information

We collect unidentifiable information that may be made available or gathered via your use of the Services ("Non-personal Information").

Personal Information

We may also collect personally identifiable information in order to enable your use of the Services, including, but not limited to:

• (i) name
• (ii) address
• (iii) phone number
• (iv) email address
• (v) age
• (vi) transaction information you provide when you make a purchase and/or request a redemption, including banking, financial, and/or other payment method details, and bank account statements
• (vii) location information, including, without limitation, location information provided by a mobile or other device interacting with the Website, or associated with your IP address

("Personal Information")

We may also request other forms of Personal Information in order to ensure your compliance with our Terms and Conditions and/or verify your eligibility to participate in the Services. All Personal Information provided shall be accurate, complete, and up-to-date. It shall be your sole responsibility to update any and all Personal Information provided for use of the Website. If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

Device Information

In order to enhance the functionality of our Services and provide you with a better user experience, we may also collect technical information transmitted by your device used to access the Services, including certain software and hardware and/or other device information, information about your web browser, and/or your IP address and device settings.

Usage Information

We may also collect information about your use of the Website, such as user activity (e.g. pages viewed, the amount of time spent on particular pages, clicks, actions, etc.). This information is collected for research and analytics purposes regarding your use of the Services.

Social Media Information

If you choose to connect to our Website through your social media account, we may also collect Personal Information from your social media profile to be used in accordance with this policy.

Aggregated/De-Identifying Information

We may also aggregate, anonymize or de-identify the information collected by the Services or via other means so that the information cannot, on its own, personally identify you. We may share this aggregated and/or de-identified data with our affiliates, agents and business partners. We may also disclose aggregated and/or de-identified user statistics and other metrics related to our Website in order to describe our products or services to current and prospective business partners and to other third parties for other lawful purposes.

COOKIES

We use cookies and other technologies to gather, store, and track certain information related to your use of the Services. A cookie is a piece of data stored on your device containing information about your access to the Website. Cookies may be sent by us or our third-party vendors. Each user can set its browser to notify the user before a cookie is received, giving an opportunity to decide whether to accept the cookie. Each user may also set its browser to turn off cookies; however, some features of the Website may not work properly in such instance.

By using our Services and/or otherwise accessing the Website, you agree to the use and storage of cookies on your device used to access the Website. If you do not wish for cookies to be stored on your device, you can deactivate the relevant option in the system settings of your browser. You can also delete stored cookies in the system settings of your browser at any time.

HOW WE USE THE INFORMATION WE COLLECT

We will only collect information that is relevant for the purposes of providing the Services, including, without limitation, to:

• (i) improve the Website and/or its features
• (ii) gather usage statistics for the Website
• (iii) provide customized user experiences
• (iv) provide access to third party content or services and/or providers
• (v) fight spam, fraud, and other abuses of the Website

Our use of your Personal and/or Non-Personal Information shall include the following purposes:

• To identify you as a user
• To process transactions (i.e. purchases and redemptions on the Website)
• To collect your location information for the purpose of verifying whether you are eligible to access the Website and/or otherwise utilize the Services
• To prevent illegal and/or unauthorized activity
• To meet legal and regulatory requirements
• To enforce our Terms and Conditions and/or other policies
• To contact users
• To provide information regarding your account
• To conduct market research
• Where you have given us your specific consent for processing your information

The type of information collected and the purposes listed above are necessary for our legitimate business interests including, without limitation, to develop our products and services, grow our business, study how visitors use our Services and inform our marketing strategy.

SHARING OF PERSONAL INFORMATION

In addition to the different uses listed above, we may share your Personal Information with third parties for any of the following reasons:

Service Provision

For the purpose of processing payments and/or other transactions, conducting testing, geo-locating users, personalizing and improving your use and experience of the Website, sending email and push notifications, providing customer support and technical maintenance, and preventing harmful and/or unlawful uses of the Services.

Analytics and Performance

For analytics purposes and Website performance.

Marketing Communications

For marketing communications and/or to our advertisers and advertising networks, excluding mobile phone numbers and SMS/messaging information. We will not share, sell, rent, or trade your mobile phone number or SMS/messaging information with third parties for their promotional or marketing purposes.

Legal Compliance

To:

• (i) comply with any applicable law, regulation, legal process or governmental request
• (ii) investigate, detect, prevent, or take appropriate action regarding illegal activities or other wrongdoing, suspected fraud or security issues
• (iii) establish or exercise our rights to defend against legal claims
• (iv) prevent harm to the rights, property or safety of us, our users, yourself or any third party
• (v) for the purpose of collaborating with law enforcement agencies

SMS/TEXT MESSAGING

Phone Number Collection and Use

We collect your phone number for account verification, security purposes, and to communicate with you about the Services. When you provide your phone number during account registration, we will send you a one-time verification code via SMS to confirm ownership of the phone number.

Marketing Communications

We may use your phone number to send you marketing communications about our Services, including promotions, offers, bonuses, and other opportunities that may be of interest to you, where permitted by applicable law. You may ask us to stop sending you marketing messages at any time by following the opt-out instructions contained in the applicable marketing communication or by contacting us at [email protected]. If you opt out of receiving marketing messages, this will not apply to service, transactional, verification, or account administration messages directly related to your use of the Services.

No Third-Party Sharing

We do not share, sell, rent, or trade your mobile phone number or SMS/messaging information with third parties or affiliates for their marketing or promotional purposes. We may share your mobile phone number or SMS/messaging information with service providers that assist us in delivering communications on our behalf, but only for the purpose of providing those services to us.

Message Frequency and Charges

The frequency of SMS messages may vary depending on your account activity and marketing communication preferences. Message and data rates may apply depending on your mobile carrier plan.

Business Transfers

In the event that ownership of all or a part of VB America or its business were to change via merger, acquisition, divestiture, dissolution, or sale of all or substantially all of VB America's assets.

We do not trade, sell, or otherwise share your Personal Information with third-parties except as set out in this Privacy Policy. We use best commercial efforts to ensure that third parties with whom your Personal Information is shared do not use your Personal Information for any purpose other than those specified by us or otherwise required by law.

THIRD PARTY WEBSITES

If you decide to use, click on, access, or provide any information to a third party website that may be linked to the Services, you acknowledge that you are doing so at your own risk. Please be aware that we do not operate, control, or endorse third party websites that may be linked on the Website or the Services, nor are we responsible for the content or privacy practices of third party websites.

We disclaim any responsibility for the use of your information on or by any third party websites, and we do not make any warranties or representations that any third party website will function without error or interruption, that defects will be corrected, or that any third party websites or their servers are free of viruses or other problems that may harm your computer.

We do not control third party tracking technologies or how third parties use them. Your use of applications or services provided by a third party are governed by the terms and privacy policy of the third party that provided such application or service. This Privacy Policy does not apply to any third party's websites, services or applications, even if they are accessible, downloadable, or otherwise distributed through the Website and/or other Services.

PROTECTING YOUR INFORMATION

We exercise all reasonable efforts to safeguard the confidentiality of information provided via use of the Website; however, you acknowledge that the protection of your information is not 100% guaranteed and all disclosure of your Personal Information is done so at your own risk.

RETAINING YOUR INFORMATION

We will retain your Personal Information for as long as you are an active user of the Website, and thereafter so long as needed for purposes that are not prohibited by applicable law. When Personal Information is no longer required, we will utilize procedures to de-identify, delete, or convert it to an anonymous form.

OPT-OUT

You have the right to opt out of disclosing Personal Information to third parties for the purpose of allowing such third parties to directly market their products and services. If you wish to opt out, you may do so by contacting us at [email protected]. As a result of your ability to opt out, we are not required to maintain or disclose a list of third parties that receive your Personal Information for marketing purposes.

YOUR PRIVACY RIGHTS

The following rights may be exercised directly by you or, in certain cases, through an authorized agent:

Right to Access Personal Information

You have the right to request information about the categories and sources of Personal Information we collect, our purposes for collecting such information, and how it is used. Details about our data collection, use and third-party disclosures can be found in this Privacy Policy. In addition, you have the right to request a copy of your Personal Information.

Right to Correct/Delete Personal Information

You have the right to request that we (i) correct, and/or (ii) delete some or all of the Personal Information that we have about you, subject to certain exceptions (i.e. information used to provide features on the Website, complete transactions, honor opt-outs, prevent fraud, spam, and other abuse, comply with our legal obligations, cooperate with law enforcement, or to exercise and defend our rights).

Right to Opt-Out of Sale of Personal Information

The right to opt out of the sale of your Personal Information, and to request information about whether we have sold your Personal Information in the past twelve (12) months. We do not sell Personal Information to third parties. Should such change, we will notify users and provide an ability to opt out as required.

Right to Object to Processing of Personal Information

The right to cease permitting Personal Information to be collected, used, or disclosed by us and/or by any third parties with whom we have shared Personal Information.

Right to Opt-Out or Withdraw Consent

You have the right to opt-out or withdraw any consent(s) previously provided to VB America. Please note that even if you opt out from receiving communications, we may still contact you with important information related to your use of the Website.

To exercise your rights, we must be able to verify your identity as the owner of the account and/or Personal Information you are inquiring about. An authorized agent submitting a request on your behalf must also have access to the email address associated with your account, along with sufficient evidence (as determined in VB America's discretion) that you have authorized that person to submit the request on your behalf. We won't discriminate against anyone because they exercise any rights herein. If you wish to exercise any of the rights set out above, please contact us at [email protected].

MINORS

The Website is not provided to users under the age of 21. If you are under 21, you should not use the Website nor provide any Personal Information to us. We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at [email protected].

UPDATES

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our Website. Your continued use of the Website after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy. The provisions contained in this Privacy Policy shall survive any termination of your account and/or use of the Website.

GOVERNING LAW

This Privacy Policy shall be construed and enforced in accordance with the laws of the State of Delaware, without regard to any conflict of law provisions. Notwithstanding the foregoing, this Privacy Policy, and the collection of information hereunder, shall comply with all relevant data protection provisions, including, without limitation, the Data Protection Act, General Data Protection Regulation, the California Consumer Privacy Act ("CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), and/or any other applicable act or regulation governing our collection of your Personal Information.

Any dispute over privacy is subject to the provisions of this notice and to our Terms and Conditions.

HOW TO CONTACT US

If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us at [email protected].