EXWORKS SERVICES LTD OOD ("we," "us," or "our"), located at Atanas Dukov str., Lozenets Distr., Fl. 6, Sofia - 1407, Bulgaria1, is committed to protecting your privacy.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application (the "App"). This policy is drafted to comply with theGeneral Data Protection Regulation (GDPR), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), and Quebec’s Law 25.
The App is a "Social Casino" intended for entertainment purposes only.
No Real Money: The virtual currency ("Coins”) used in this App has no real-world monetary value. It cannot be exchanged, redeemed, or cashed out for real money, goods, or services.
No Winnings: You cannot win real money or real-world prizes.
Age Restriction: You must be 18 years of age or older (or the age of majority in your province of residence) to access this App. If you are under 18, you are strictly prohibited from using the App.
We collect data to provide the game service, process virtual transactions, and improve your experience.
Account Data: If you choose to link a social media account (e.g. Apple ID, Google Sign-In), we may collect your name, email address, and profile picture URL.
Customer Support: Data you provide when contacting us for help (e.g., screenshots of game errors, email correspondence).
Device Data: Device model, operating system (iOS/Android), unique device identifiers (IDFA/GAID - subject to your consent), and IP address.
Gameplay Data: Your win/loss history, spin patterns, game levels achieved, and virtual currency balances.
Location Data: General location data (derived from IP address) to ensure you are not accessing the App from a restricted jurisdiction. We do not collect precise GPS coordinates.
We do not collect credit card numbers or any other financial data. There are no options to purchase anything from the app.
We use your data for the following "Legal Bases" under GDPR and "Identified Purposes" under PIPEDA:
Purpose ⇒ Legal Basis / Identified Purpose
To Provide the Service ⇒ Maintaining your account, syncing progress, and managing virtual currency balances.
Customer Support ⇒ Responding to your emails to contact@exwo.com.
Game Economy & Integrity ⇒ Analyzing gameplay to prevent fraud, "bot" usage, or cheating (Legitimate Interest).
Legal Compliance ⇒ Verifying age and location to comply with gambling regulations.
Data Controller: EXWORKS SERVICES LTD OOD (Bulgaria).
Location of Processing: Your personal data is processed in Bulgaria (European Union)and on servers hosted by our third-party providers (e.g., AWS) which may be located in the EU or North America.
Transfer Safeguards: Because we are a Bulgarian company, your data is protected by the GDPR (one of the strictest privacy laws in the world). When we transfer data from Canada to Bulgaria, we rely on the European Commission's "Adequacy Decisions" and standard contractual clauses to ensure your data remains protected.
Tracking: These partners may use cookies or mobile identifiers (IDFA/GAID) to show you ads based on your interests.
Your Choice (Canada & Global): You can opt-out of targeted advertising in your device settings:
Quebec Residents: In compliance with Law 25, we engage "Privacy by Default." We will explicitly ask for your consent (via a pop-up) before activating tracking technologies that profile you.
We retain your personal data only as long as your account is active or as necessary for legal/tax obligations.
Deletion Request: You may request the deletion of your account and all associated data at any time.
Email Request: Email us at contact@exwo.com with the subject line "Data Deletion Request."
Depending on your location, you have the following rights:
Right to Access: Request a copy of the data we hold about you.
Right to Correction: Fix inaccurate personal data.
Right to Erasure: Ask us to delete your data ("Right to be Forgotten").
Right to Withdraw Consent: Revoke permission for data processing (e.g., marketing emails) at any time.
To exercise these rights, contact our Privacy Officer at: contact@exwo.com
In compliance with the Act respecting the protection of personal information in the private sector (Quebec):
Privacy Officer: The person accountable for the protection of personal information at EXWORKS SERVICES LTD OOD is the Privacy Officer, reachable at contact@exwo.com.
Location of Data: Your personal information may be communicated outside of Quebec (to Bulgaria/EU). We have conducted a Privacy Impact Assessment (PIA) to ensure your data receives protection equivalent to that in Quebec.
Profiling: If we use your data to render a decision based exclusively on automated processing (e.g., fraud detection), you have the right to be informed and to submit observations.
This App is strictly for users aged 18+. We do not knowingly collect information from children. If we discover we have collected data from a child under 18, we will delete it immediately.
If you have questions about this Privacy Policy, please contact us:
EXWORKS SERVICES LTD OOD
Attn: Privacy Officer
1 Atanas Dukov str., Lozenets Distr., Fl. 6, Sofia - 1407, Bulgaria
Email: contact@exwo.com