Privacy Policy

Last Updated: May 22, 2025

Version: 10.0

### 1. INTRODUCTION

NexusX Game Studios ("we," "us," or "our") operates SpinRiches (https://nexusxgame.com/) and related services (collectively, "Services"). This Privacy Policy explains how we collect, use, and protect your information.

By using our Services, you consent to these practices. If you disagree, please refrain from using our Services.

Policy Updates: We may modify this policy at any time. Continued use after changes constitutes acceptance.

### 2. INFORMATION WE COLLECT

#### A. Data You Provide

We collect when you:

- Register an account

- Complete KYC verification (including biometrics like face scans/government IDs)

- Make purchases or contact support

- Participate in chats/recorded interactions

Categories include:

✅ Profile Data

✅ Personal Identifiers

✅ Financial Information

✅ Commercial Activity

✅ Marketing Preferences

#### B. Automated Collection

Via cookies and tracking technologies:

- Device Data: IP address, browser type, OS

- Usage Analytics: Play statistics, clickstream data

- Cookies/Pixels: For functionality and ads (manage via browser settings)

#### C. Third-Party Sources

Data from partners/payment processors, governed by their policies.

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### 3. HOW WE USE YOUR DATA

| Purpose | Examples |

|------------------------------|----------------------------------------------|

| Service Delivery | Account management, prize redemptions |

| Legal Compliance | KYC verification, fraud prevention |

| Marketing* | Personalized offers (opt-out available) |

| Business Operations | Analytics, system improvements |

*Requires consent where applicable

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### 4. DATA SHARING & DISCLOSURES

We may share with:

🔹 Service Providers (payment processors, cloud hosts)

🔹 Legal Authorities (subpoenas, fraud investigations)

🔹 Business Transferees (mergers/acquisitions)

International Transfers: Data may be processed globally, including jurisdictions with differing privacy laws.

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### 5. YOUR RIGHTS

Depending on location, you may:

- Access/correct your data

- Withdraw consent*

- Request deletion**

- Lodge complaints with regulators

*May limit service functionality

**Subject to legal retention requirements (e.g., 5+ years for AML)

How to Exercise: Contact support@nexusxgame.com

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### 6. SECURITY & RETENTION

- Protections: Encryption, access controls, audits

- Retention: Kept only as long as necessary for legal/business needs

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### 7. SPECIAL PROVISIONS

#### Children

🚫 Services are **18+ only**. We do not knowingly collect data from minors.

#### Regional Notices

- California Residents: - CCPA requests: Email "CALIFORNIA PRIVACY RIGHTS" to support@nexusxgame.com - We honor opt-outs but do not respond to DNT signals

- Canada/Other Jurisdictions: Additional rights may apply per local law.

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### 8. CONTACT US

For questions or requests:

📧 Email: support@nexusxgame.com

🏢 Registered Office:

2, G/F., Belvedere Square, Belvedere Garden Phase III

Tsuen Wan, N.T., Hong Kong

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Key Improvements:

1. Structured Layout – Easy-to-navigate sections with tables for complex information.

2. Clearer Language – Simplified legal jargon without losing precision.

3. Compliance Highlights – Explicit callouts for GDPR/CCPA rights and children's data.

4. Actionable Details – Specific instructions for exercising rights.

This version balances legal rigor with user accessibility while maintaining full compliance with global standards. Let me know if you'd like any further refinements!