Dynamico Privacy Policy
Version 1-4
Updated May, 2025
This Privacy Policy provides an explanation of why Player information is collected, how it is collected, and how Dynamico keeps it secure. Dynamico is committed to respecting and protecting Player privacy, for the importance of maintaining the trust and confidence of Players. Dynamico is committed to complying with obligations under all applicable global data privacy laws, including the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), and the Virginia Consumer Data Protection Act (“VCDPA”).
This Privacy Policy governs the way Dynamico collects, uses, maintains, and discloses the information collected through https://www.Dynamico.co and any subdomains, subpages, successor sites or any application accessible via our website (the “Dynamico Platform”). This Privacy Policy applies to the Dynamico Platform and all products and services offered through it.
1. The Dynamico Privacy Policy is Subject to Change
(1) This Policy may be updated from time to time as necessary to safeguard Player data collection. When this happens, Players will be notified of any material change affecting them, and when required by law, will need Players’ consent. Notice may be provided to Players by posting such changes on the Platform, or by other means that comply with applicable laws.
(2) Players are encouraged to regularly check this page for any changes or revisions to the Privacy Policy and to stay accurately up to date with how Dynamico helps protect the personal information it collects.
(3) Any changes made to this Privacy Policy will become effective when the updated policy is posted on the Platform.
(4) This Privacy Policy is in effect from the last date at the top of the document. Any updated version will replace and supersede any Privacy Policy that has previously been in effect.
2. Collected Information
(1) The data controller responsible for processing data collected through Players’ use of the Dynamico Platform (including any data Players may provide through the Platform when they purchase a product or service or take part in a promotion or competition) is Dynamico Ltd. (the “Data Controller” or “Dynamico”).
(2) This Privacy Policy is incorporated into and part of the Dynamico Terms and Conditions. The Definitions of those terms set forth in the Terms and Conditions apply equally here and carry the same meaning.
(3) Dynamico collects two general forms of information about its Players: personal information and anonymous information. Personal information consists of any information about the Player, accurate or not, where their identity is discernable, or can reasonably be discerned. Anonymous information does not directly or indirectly identify an individual and cannot be reasonably used to identify an individual. In situations where anonymous information is directly or indirectly associated with personal information, the resulting information is treated as personal information. Dynamico may use personal and anonymous information to create a third type of information known as aggregate information. Aggregate does not include the ability to identify an individual Player from this category.
(4) Dynamico collects:
a. Players’ personal contact details including their first and last name, email, address, residential address and phone numbers;
b. Personal information including Players’ age, gender, image, account login (including username, password and any pictures used with their profile);
c. information sent using email, post or other methods of communication;
d. Any information Dynamico obtain from a third party (such as Meta) about interest in its services;
e. Information such as Players’ postal address, phone number, payment information (banking and financial details, account statements, and credit card details) or any information you provide when making a purchase, requesting a redemption, payment or any use otherwise.
f. Where permitted by law, Dynamico collects Players’ location information provided by a mobile or other device used to access the Platform, or associated with Players’ IP address.
g. Any activity while using the Platform (includes duration of Players’ visit on the Platform, the content viewed, how often Players use the services, Players’ interaction with the Platform, device type, preferences and interaction with the Content on our website, your browser type and IP address).
h. Government issued identifiers such as a driver’s license, social security number, or passport (when Dynamico is required to have this information for tax or other legal reasons).
i. Dynamico may collect Players’ geolocation, financial information, biometric data, and driver’s licenses collected for necessity of legal and regulatory compliance.
(5) Dynamico uses identifiers such as cookies and similar available technology, to help make Players’ experience with the Platform as simple and useful as possible.
(6) In order to enhance Players’ experience on the Platform, Dynamico uses technology such as small files, placed on Player devices when they visit the Platform. This allows Dynamico to record pieces of information when Players visit or interact with the Platform. The information collected may include Player browser type, device type, operating system, geolocation, the time, referring URLs and other information Dynamico deems necessary to collect. The data collected provides information about Player engagement with the page, including the content and how long the Player stayed on that page. This information is usually general and non-identifying; however, Dynamico will treat it as personal Information and associate it with the Player as an identifiable person.
(7) Examples of the types of technology used:
a. Cookies store Player preferences in small text files located in their device’s browsers. Browsers may allow the Player to block or delete cookies, but this may interfere with the Platform’s ability to work correctly.
b. API’s (as defined above) allow different kinds of software programs to communicate with one another. They provide better experiences for both Players and programmers.
c. Mobile device identifiers are used for identifying Player devices for internetbased advertising. The advertising identifier associated with a Player’s device (such as Google Advertising ID and Apple IDFA) may be shared by us to advertisers. For instructions for using the advertising choice mechanisms provided by the most popular mobile operating systems, visit the NAI’s Mobile Choices page here.
d. Pixel tags (also referred to as web beacons) are codes embedded in the Platform that collect information for Dynamico to record information such as whether a Player clicked on a particular advertisement. Dynamico may also use the web beacons in emails to determine whether they have been opened, forwarded, or acted on in any way.
e. Event tagging allows Dynamico to track application installs, purchases, and other events that occur on the Platform. Dynamico uses this data to measure ad performance, build audiences used for ad targeting, and view analytics. (This includes Meta App Events).
3. How Player Information is Collected
(1) Players agree that any and all contact information provided by them is accurate. Dynamico is able to collect information in many ways as listed below.
(2) Information Players provide directly, whether by visiting the Platform, registering on the Platform, purchasing products on the Platform, responding to any survey or filling out any form, and taking part in any service, activity, or resource Dynamico makes available to Players on the Platform.
(3) Dynamico also collects Players’ information from their phone, video, or through emails, mail, live chat feeds, social media, and text messages. Calls made between Players and any Dynamico representatives may be recorded for quality control and training purposes.
(4) Using a variety of technology, Dynamico collects information about Players’ use of services and products when they visit the Platform or use any third-party sites or platforms (even if Players are not logged in or registered). This includes cookies, pixels, tags, flash cookies, and any API (application programming interfaces). For further information, reference “Personal Data Collected with Technology” below.
(5) Dynamico collects information provided and collected by its trusted third-party services. This may include information used to verify and validate information (postal addresses, documents, or names).
4. How the Collected Information is Used
(1) The information Dynamico collects is used to operate and provide products and services, facilitate financial transactions, and fulfill necessary requirements such as antifraud checks, for preventing money laundering and complying with applicable state and federal regulation and legislation.
(2) Dynamico may collect and use Player information:
a. To process payments. Dynamico collects necessary information provided by Players when placing an order. This may often be needed to comply with anti-money laundering regulations and due diligence requirements to establish the source of funds. This information is not shared with service providers unless necessary for the service.
b. To make the user experience more personal, Dynamico may use aggregated information to understand how players use its services and resources.
c. To provide and manage the services requested by Players, such as processing Player registration, setting up, maintaining and looking after the integrity of Player accounts, including checks made to guard against fraud.
d. To help improve customer service and general services. Any information provided can help Dynamico respond to customer service requests more efficiently. Dynamico may use Player feedback to enhance its product and services.
e. To send Players important notices, such as communications about purchases, issues relating to Player accounts, legal notices regarding changes to the Terms and Conditions, and changes to other policies that may affect Players. Players acknowledge these communications are some they may not opt out from given their level of importance.
f. To contact Players about Dynamico services, including marketing and promotion. Dynamico may contact Players by email, live chat feed, phone call, text, mail, or social media. This is to manage promotions and competitions Players have chosen to enter. Dynamico may also contact Players with offers, surveys, and information about its product and services. To opt out of this please refer to the “Player Privacy Rights” clause.
g. For conducting marketing research and analyses. This information will be collected based on how Players interact with Dynamico services, monitor usage and activity, and for other research purposes.
h. To offer an alternative dispute resolution service. Information Dynamico collects may be provided to its service providers for the purpose of resolving disputes that have not been resolved to the satisfaction of either party through internal processes.
i. To collect information used for taxation purposes, complying with fraud and anti-money laundering laws, responsible social gameplay purposes, and helping to prevent activity that violates any policies or Terms and Conditions, or is otherwise illegal. Dynamico can monitor this through an assessment of Player social gameplay activity.
(3) In abiding by global data protection laws, Dynamico does not use any automated decision making.
(4) Dynamico reserves the right to partner with third-party service providers to manage our advertisement on other websites or to display advertising on the Platform. For any such partnership, Players must acknowledge the third-party service provider may use technology such as cookies to record information about Player activities on the Platform, other websites, and to provide advertising based on activities and interests from the browser.
(5) Players may opt out of this internet-based advertising by Contacting Customer Support.
5. Protecting Player Information
(1) Using reasonable means available, Dynamico will protect personal information from unauthorized access, modification, disclosure, misuse, or loss.
(2) Dynamico protects the information it collects from Players utilizing physical, electronic, and operational measures. Dynamico security procedures include measures for the appropriate collection of data and protection against unauthorized access to where Player data is stored and processed. Using technology tools, Dynamico regularly reviews and updates its security measures.
(3) If there is reason for Dynamico to believe that a data breach has occurred, Players will be notified in accordance with regulatory standards, and Dynamico will keep Players apprised of actions taken to contain and investigate the issue further.
(4) Even with Dynamico’ best efforts, the communication of Player data through the Platform can never be guaranteed to be wholly secured. Players transmit personal information at their own risk, and there is no promise that such information will not be intercepted by third parties. Dynamico will not be liable for any breach of the security of your personal information from the actions of third parties beyond its control. This may include, but not be limited to, Players’ own actions or omissions, defects in third-party data services or products, impersonation of representatives of Dynamico, corruption or intercepted stored data, terrorism, natural occurrences, power failures, hacking, sabotage, and riots. Dynamico will not be responsible for the unauthorized circumvention of any security measures or privacy settings contained within the Platform.
6. Information Sharing
(1) In no circumstance does Dynamico rent, sell, or trade Players’ personal information to third parties for marketing, promotion, financial or other purposes. Nevertheless, under specific circumstances Dynamico may share Player’s personal data with a third party as necessary for the operation of its services and products, including affiliates, and service providers (other companies that provides services to players on their behalf).
(2) Dynamico requires any third party that it shares Player information with to uphold the same data protection methods that Dynamico does. Such third parties are prohibited from using Player personal information for any purpose other than those requested by Dynamico or by law.
(3) Dynamico will only share your information with third parties as necessary to perform the function of its product and services for these reasons:
a. When providing Players with products and services and notifying them about developments related to them.
b. When Players allow us to do so.
c. When requested by law by public authorities for security or law enforcement purposes, or when ordered to do so by a regulatory body, court of law, legislature, or statute requiring us to comply.
d. When performing due diligence on a Player such as ID verification.
e. When necessary to do so with Dynamico service providers enabling it to provide its services to Players, including but not limited to, technology services, storing and combining data, and processing payments and redemptions. Such service providers will act as the Data Controller when using Player personal information for their own purposes, as permitted by law.
f. When requested by a regulator, Dynamico may authorize the financial institution identified in a Player’s Customer Account to disclose personal information relating to that Customer Account.
g. When necessary to detect fraud or other illegal and/or prohibited activity on the Platform, protecting Dynamico’ rights and property and those of its customers, and enforcing its Terms and Conditions.
h. In the event of a business transition, such as a merger, acquisition, joint venture, assignment, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of a portion or all assets, including bankruptcy, liquidation, or similar proceeding, Players’ information may be disclosed in connection with the negotiation of such transaction and/or sold or transferred as part of such a transaction as permitted by law and/or contract.
(4) Dynamico may share generically collected demographic information that is not linked to any personal information regarding Players and visitors to the Platform with trusted affiliates, advertisers, and business partners.
(5) Dynamico may ask that Players provide their image to help Dynamico verify Player identity. Dynamico utilizes a third-party service provider with facial recognition software to verify that the photo provided matches a qualified identification document with the Player’s photo on it. This facial recognition technology collects information from the Player’s captured image, including biometric data. This data is stored by the third-party service provider until the purpose for collecting it has been satisfied, or, within three calendar years of your last interaction with Dynamico (provided there is no legal obligation for Dynamico to retain this information for a longer time period).
(6) Dynamico operates within numerous jurisdictions within the United States. At times, the personal information Dynamico collects may be stored, processed, maintained and transferred to its affiliates or third parties located within the country. Dynamico will use appropriate safeguards to protect Player privacy and the integrity of this information when doing so.
(7) In the event that a Player wins a Prize, Dynamico reserves the right to use that Player’s first name and the first initial of his or her last name for publicity purposes on its Platform, social media, marketing communications or otherwise (by way of example, but not limited to: “Jane A. won SC 25,000 playing on Dynamico”).
7. Player Privacy Rights
(1) Players may adjust their preferences for cookies and other trackers.
(2) Players have the right to object at any time to Dynamico processing their personal information to use in direct advertising by contacting Customer Support.
(3) Players may opt out of receiving commercial messages: simply follow the instructions provided within the message received, modify their marketing preferences within their Player Profile, or by contacting Customer Support for further instructions. Upon such request, Dynamico will not continue processing Player personal information for the purpose of direct advertising.
8. Privacy Rights in Action
(1) We understand and respect that Players have a number of rights relating to their personal information which Dynamico may hold. These rights include: objecting to the processing of Player data, the right to access the personal information held about Players, updating and correcting the information held about Players when necessary, and being able to withdraw and revoke any consent provided. In specific circumstances, Players may ask Dynamico to delete the personal information held.
(2) In order to exercise any of the rights described above, please contact Customer Support.
(3) In no circumstance will Players experience any discrimination from Dynamico (such as denying services or products or receiving a different level of quality of the goods and services provided) for choosing to exercise any of the rights mentioned above.
(4) Dynamico reserves the right to request evidence of power of attorney should a Player elect to use an authorized agent to exercise their rights as described above.
(5) Nothing within this Privacy Policy shall serve to restrict Players’ right to lodge a complaint to a supervisory authority relating to the way Dynamico processes personal information.
9. Duration of Information Retention
(1) Player information collected will be retained for the reasonable time necessary to fulfill the purposes set out in this Privacy Policy, or as further required by law.
(2) When Dynamico either no longer needs the personal information for why it was first collected or any related purpose, or it is not required by law to retain the personal information, Dynamico will take all reasonable steps to permanently de-identify or delete it.
10. Information Relating to Minors
(1) Dynamico never knowingly collects information from minors (individuals under the age of 18) in order to protect their privacy. No part of the Platform has been designed or is intended to attract individuals under the age of 18. Dynamico does not offer any service or products to minors. For any specific questions regarding personal information and how Dynamico uses it, please contact Customer Support.
