1.  Introduction 

Sweeps-casino.com (“Website”) is an affiliate marketing website that features social casino platforms operating under a sweepstakes promotional model (“Brands”), operated by Marqui Element Interactive SRL (“the Company,” “we,” “us,” or “our”). All Brands currently featured on the Website are brands with which the Company has a commercial affiliate arrangement.  

This Privacy Policy describes how the Company collects, uses, discloses, retains, and protects your personal information when you visit or interact with the Website or subscribe to our newsletter. Please read it carefully before using the Website.  

Any term used but not defined in this Privacy Policy shall have the same meaning as ascribed to it in the T&C published on the Website, as amended from time to time. 

By accessing or using the Website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please discontinue use of the Website immediately. 

No Legal Advice. Nothing in this Privacy Policy or on the Website constitutes legal advice. All content is provided for informational purposes only. You should consult a qualified professional if you have specific questions about your privacy rights or obligations. 

Legal Bases for Processing. The Company processes your personal information on the following bases: (a) your freely given and informed consent where required; (b) the Company’s legitimate interests in operating and improving the Website; and (c) compliance with applicable legal and regulatory obligations. 

2.  Geographic Restrictions 

The Website is intended solely for users who have reached the age of majority in their jurisdiction and are located in jurisdictions where access to social casino and sweepstakes content is lawful. As of the Last Updated date, the Company does not knowingly accept newsletter sign-ups, promotional submissions, or affiliate-link traffic from residents of the Restricted States. We exclude these states from our advertising audience targeting. If you reside in one of these jurisdictions, please discontinue use of the Website immediately. 

3.  Information We Collect 

3.1  Information You Provide Directly 

The Company collects personal information that you voluntarily provide, including your name and email address, when you subscribe to our newsletter. The Company collects only the minimum information necessary for these purposes and does not collect payment information, government identifiers, or other sensitive categories of personal data directly from you. 

3.2  Your Representations 

By providing your personal information to the Company, you represent that the information is true, accurate, current, and belongs to you. You acknowledge that providing false or third-party information may result in the removal of your details from our systems. 

3.3  Information Collected Automatically 

When you visit the Website, certain information is collected automatically through cookies, pixels, tags, and similar technologies, including: 

• IP address and approximate geographic location (country and state level); 

• Browser type, version, and operating system; 

• Pages visited, time spent on each page, and navigation paths; 

• Referring URL and search terms used to find the Website; 

• Device type and screen resolution; and 

• Interaction data such as clicks, scroll depth, and form completions. 

This information is collected only after you have provided consent via our cookie consent banner, which appears on your first visit to the Website. You may withdraw or update your consent at any time via the “Cookie Settings” link in the Website footer. 

3.4  Information from Third-Party Sources 

The Company may receive aggregated, non-personally identifiable performance data from Brands, such as total referrals, conversion rates, and revenue metrics. This data does not identify you individually and is used solely for campaign performance analysis. 

The Company may from time to time acquire personal information, including names and email addresses, from third-party data providers under data acquisition agreements. The Company only acquires data from providers who represent and warrant that the data was collected lawfully and that the individuals concerned have consented to receive marketing communications from third parties such as the Company. Data acquired from third-party providers is used solely to send you promotional emails relating to social casino and sweepstakes content available on the Website. If you receive an email from the Company and did not directly subscribe through the Website, your details were acquired through this process. You may unsubscribe at any time by clicking the unsubscribe link in any email or by contacting [email protected]. The Company will promptly action all unsubscribe requests. 

3.5  Sensitive Personal Information 

The Company does not knowingly collect sensitive categories of personal information, including precise geolocation data, racial or ethnic origin, religious or philosophical beliefs, mental or physical health information, sexual orientation or gender identity, biometric data, genetic data, financial account details, or government identification numbers. If you believe you have inadvertently provided such information, please contact [email protected] immediately. 

4.  How We Use Your Information 

The Company uses the information it collects for the following purposes: 

• To send marketing communications, promotional offers, and newsletters where you have provided consent; 

• To operate, maintain, and improve the Website, including content personalisation and performance optimisation; 

• To track affiliate referrals and measure campaign performance using aggregated, non-personal metrics; 

• To verify approximate user location and enforce geographic restrictions; 

• To detect, prevent, and address fraud, abuse, and security incidents; 

• To respond to customer service inquiries and use feedback to improve the Company’s services; 

• To contact you about promotions and offers you have elected to receive; and 

• To comply with applicable legal and regulatory obligations. 

The Company will not use your personal information for any purpose that is incompatible with the purposes described above without first obtaining your consent or as otherwise permitted by applicable law. 

5.  Cookies and Tracking Technologies 

The Company uses cookies, pixels, tags, and application programming interfaces (APIs) to enhance your experience on the Website, analyse site traffic, and deliver relevant advertising. A cookie is a small text file stored on your device when you visit the Website, which may contain a unique identifier to distinguish your device from others. 

The Company uses these technologies to: operate and improve the Website; personalise content and remember your preferences; measure and optimise advertising campaigns; track affiliate referrals; and enforce geographic restrictions. 

The Website integrates tracking and advertising technologies from third-party platforms, including but not limited to Google Ads, Microsoft Advertising, Yahoo Advertising, Meta Ads (Facebook and Instagram), TikTok Ads, LinkedIn Ads, X (formerly Twitter) Ads, Pinterest Ads, Snapchat Ads, Apple Search Ads, Unity Ads, IronSource, AppLovin, and Amazon Ads. These third-party platforms may independently collect information about your online activity across multiple websites over time through cookies, pixels, and similar technologies. Their data collection practices are governed by their own privacy policies, which the Company encourages you to review. 

The Company uses a third-party email delivery provider to send and track newsletter and promotional emails, including open and click tracking. This provider processes your email address solely to deliver emails on the Company’s behalf and is not permitted to use your data for any other purpose. 

Your Choices. You may manage your cookie preferences at any time through our cookie consent banner. You may opt out of interest-based advertising from participating third-party platforms through industry opt-out tools such as the Digital Advertising Alliance (DAA) at optout.aboutads.info or the Network Advertising Initiative (NAI) at optout.networkadvertising.org. You may also manage cookies directly through your browser settings. Please note that disabling certain cookies or opting out of interest-based advertising may affect your experience on the Website. 

6.  How We Share Your Information 

The Company does not sell your personal information for monetary consideration. 

The Company may share or disclose your personal information in the following circumstances: 

• Third-party service providers: The Company may engage third-party companies and individuals to perform services on its behalf, including email delivery, web hosting, data analytics, advertising platform management, and technical infrastructure support. These service providers are authorised to access and use your personal information only to the extent necessary to provide those specific services on the Company’s behalf. They may not sell your personal information, use it for their own marketing or commercial purposes, or disclose it to further third parties without the Company’s express authorisation. The Company requires all such third parties to maintain appropriate contractual and technical safeguards to protect your personal information. 

• Brands: Where a Brand shares your contact details with the Company based on consent you previously provided on that Brand’s platform, the Company uses that data only to send you promotional emails relating to social casino and sweepstakes content. You may unsubscribe from such communications at any time. 

• Legal compliance: The Company may disclose your personal information where required by applicable law, regulation, legal process, or enforceable governmental or regulatory request. 

• Business transfers: In the event of a merger, acquisition, reorganisation, or sale of all or substantially all of the Company’s assets, your personal information may be transferred to the successor entity. The Company will provide reasonable notice before your information becomes subject to a materially different privacy policy. 

• Protection of rights: The Company may disclose your personal information where necessary to enforce its Terms and Conditions, protect the safety or security of users or the public, prevent fraud or illegal activity, or defend the Company’s legal rights and interests. 

The Company requires all third parties with whom it shares personal information to respect the security of that information and to treat it in accordance with applicable law. The Company does not permit third-party service providers to use your personal information for their own purposes. 

7.  Marketing Communications 

The Company sends commercial electronic messages only where you have provided consent as required by applicable regulatory requirements. 

Express Consent. The Company obtains your express consent when you subscribe to the newsletter by entering your name and email address and affirmatively checking an opt-in box (which is unchecked by default). At the point of subscription, the Company clearly discloses: the purpose of the communications (marketing, promotions, and newsletters relating to social casino and sweepstakes platforms); the identity of the sender (Marqui Element Interactive SRL, which operates the Website); and how to withdraw consent at any time. 

Implied Consent. In limited circumstances, and where permitted by applicable regulatory requirements, the Company may rely on implied consent to send commercial electronic messages where you have had a prior business relationship with the Company or with a third-party data provider from whom the Company has acquired your contact details, within the time period permitted by applicable regulatory requirements. The Company will only rely on implied consent where it has a reasonable basis to believe that such consent exists and covers the type of communications being sent. You may withdraw implied consent at any time by unsubscribing. 

Every commercial electronic message the Company sends will include: clear identification of the Company and the Website as the sender; a label identifying the communication as promotional or advertising in nature; a clear and functioning unsubscribe mechanism; and accurate subject lines that are not deceptive or misleading. 

You may opt out of receiving marketing communications at any time by clicking the unsubscribe link in any email or by emailing [email protected] with the subject line “Unsubscribe.” The Company will process your request promptly as required by applicable regulatory requirements. 

Record Keeping. The Company maintains records of how and when consent was obtained for each subscriber, including the date, time, method of consent, and the version of the consent language presented, as required by applicable regulatory requirements. 

8.  Data Retention 

The Company retains your personal information for as long as is necessary to fulfil the purposes described in this Privacy Policy, to satisfy its legitimate commercial needs, or as permitted or required by applicable law and regulatory requirements. 

The Company will retain your name and email address for as long as you remain subscribed to our newsletter. Upon unsubscribing, the Company will suppress your details from future marketing sends and will retain a record of your unsubscribe request for compliance purposes. 

If you request permanent deletion of your personal information, the Company will require written authorisation from you and will complete the deletion within a reasonable period, except where retention is required for legal, audit, or compliance purposes or where the Company has a legitimate interest in retaining the information. 

9.  Your Privacy Rights 

Depending on your jurisdiction and applicable law, you may have some or all of the following rights with respect to your personal information held by the Company: 

• Access: The right to request a copy of the personal information the Company holds about you. 

• Rectification: The right to request correction of inaccurate or incomplete personal information. 

• Erasure: The right to request deletion of your personal information, subject to any legal retention obligations. 

• Restriction of processing: The right to request that the Company restricts its processing of your personal information in certain circumstances. 

• Data portability: The right to receive your personal information in a structured, commonly used, and machine-readable format. 

• Objection: The right to object to the Company’s processing of your personal information where processing is based on the Company’s legitimate interests. 

• Withdrawal of consent: The right to withdraw any consent you have previously given at any time, without affecting the lawfulness of processing carried out prior to withdrawal. 

To exercise any of these rights, please contact the Company at [email protected] with the subject line “Privacy Rights Request.” The Company will respond within the period required by applicable law. The Company reserves the right to verify your identity before processing any privacy rights request. 

10.  Children’s Privacy 

The Website is intended solely for individuals who have attained the age of majority in their jurisdiction. The Company does not knowingly collect, use, or maintain personal information from any person under the age of 18. No part of the Website is structured to attract or directed at minors. 

If you are a parent or guardian and believe that a minor has provided personal information to the Company without your consent, please contact us immediately at [email protected]. The Company will take prompt steps to verify the report and, if confirmed, delete the relevant information from its systems. 

11.  Security 

The Company takes reasonable, industry-standard steps to protect your personal information against unauthorized access, use, modification, disclosure, or destruction. These measures are reviewed and updated periodically. 

While the Company takes reasonable, industry-standard steps to protect your personal information, no method of data transmission over the internet or electronic storage system is completely secure, and the Company cannot guarantee absolute security. The Company is not responsible for any unauthorized access, disclosure, or loss of personal information that occurs despite these measures, where such incident is outside the Company’s reasonable control. 

If you have reason to believe that your personal information has been compromised while in the Company’s care, please notify the Company immediately at [email protected]. 

In the event of a data security incident affecting your personal information, the Company will take appropriate steps as required by applicable law, which may include notifying affected individuals where required. 

12.  Third-Party Websites 

The Website contains links to third-party websites, including Brand platforms and other websites. The Company is not responsible for the privacy practices, content, security, or data handling of any third-party website. The inclusion of a link on the Website does not constitute an endorsement of that website’s privacy practices. 

Before providing your personal information to any third-party website, including any Brand’s platform, the Company strongly encourages you to review that website’s privacy policy, terms and conditions, and sweepstakes rules. The Company has no control over, and accepts no responsibility for, the privacy practices of any Brand or other third party. 

13.  International Data Transfers 

The Company is incorporated and based in Costa Rica. The Website is hosted by a third-party hosting provider, and your personal information may be stored and processed in the country or countries where that provider’s facilities are located. Your personal information may also be transferred to and processed in other countries, including the United States (for advertising platforms, analytics services, and related third-party providers) and other jurisdictions where the Company’s third-party service providers operate. The Company takes reasonable steps to ensure that any international transfers of personal information are conducted in accordance with applicable data protection and regulatory requirements and that appropriate safeguards are in place to protect your information. 

14.  Contact Us 

If you have questions, concerns, or requests regarding this Privacy Policy or the Company’s data practices, or if you wish to exercise your privacy rights, please contact the Company at: [email protected] 

15.  Changes to This Privacy Policy 

The Company may update this Privacy Policy from time to time to reflect changes in its data practices, the technologies it uses, applicable regulatory requirements, or for other legitimate operational reasons. When the Company makes material changes to this Privacy Policy, it will update the “Last Updated” date at the top of this page. 

For material changes, the Company will provide additional notice where required by applicable law, such as by posting a prominent notice on the Website or by sending an email notification to subscribers. Your continued use of the Website after the effective date of any changes to this Privacy Policy constitutes your acceptance of the updated policy. 

The Company encourages you to review this Privacy Policy periodically to stay informed about how it collects, uses, and protects your personal information.