Legal

Privacy Policy

Last updated: June 25, 2026

Privacy Policy Galadriel Labs – New York Online Gaming services

I. GENERAL INFORMATION

When We refer to “Personal Information” in this Policy, We mean information that identifies, relates to, describes or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to a particular individual. Please note, as used in this Policy, “Personal Information” does not include publicly available information from government records or information that has been deidentified or aggregated in a way that it cannot be used to identify a specific individual (“Deidentified Data”).

We commit to maintaining Deidentified Data in its deidentified form and not to attempt to reidentify the Deidentified Data, except and solely for the purpose of determining whether Our deidentification processes satisfy the requirements of applicable laws.

Galadriel Labs primarily collects Personal Information to provide and improve the Services, conduct Our business operations, provide the Services, communicate with You, and enable You to enjoy and easily navigate the Services.

The categories of Personal Information We may collect and use in connection with the Services may fall into one or more of the categories described below. Please note, the types of Personal Information provided as examples for each category are not a representation that We will actually collect that specific type of Personal Information about You.

II. INFORMATION WE MAY COLLECT

A. Personal Information You Provide Directly to Us and While Engaging with the Services.

You must register for an account to access and use certain features of Our gaming application. When You register for an Account, We will collect the Personal Information You provide (including Your name and e-mail address). We may also ask You for additional information, including Your mobile phone number.

When You access, participate in, or otherwise interact with the Services, or otherwise engage with Us in connection with the Services, such as requesting more information about the Services, visiting Our Sites, entering sweepstakes or promotions, or communicating with members of Our team, We may automatically collect information or ask You to provide Us with additional Personal Information. When engaging with You via e-mail or chat, in addition to Your Personal Information, We may also collect any Personal Information You provide in the content of Your interactions with Us.

B. Gaming and Transaction Information.

When You use the Services, We, Our Affiliates, and Our third-party service providers may collect information about how You interact with the Services, including play-money chips balance, experience level, statistics, settings, and all other interactions associated with Your Account. This information is often stored locally on your device or linked to your selected cloud save profile.

C. Tracking Technologies and Device Information.

When You use the Services, We and Our third-party service providers may use cookies, web beacons, clear gifs, tracking pixels, scripts, e-tags, and other technologies (“Tracking Technologies”) to collect and analyze information about You, Your device, and Your activity. Information collected through Tracking Technologies may include: IP address; type of device; browser and operating system; device identifiers, such as MAC address; the name associated with Your device; unique number associated with Your internet connection; internet service provider; (mobile) telephone number; websites visited before or after You visit Our site; and activities within the Services including links clicked, pages or screens viewed, session time, the number of times and date/time a page/screen is clicked or a feature of the Services is used, and the amount of time You spend on a page or using a feature of the Services (“Device Information”).

We may use cookies to store some information on Your personal computer, mobile device or other electronic devices when You access and use the Services. Cookies are small text files that are stored on Your devices or equipment when You visit certain online pages and record Your preferences. Cookies allow Us to remember things about Your visits across the Services. We may also use cookies and third-party cookies to monitor and understand traffic to the Services, improve the Services, and make the Services easier and/or more relevant for Your use.

Our Sites may use Google Analytics (and similar sites or services), a web analytics service provided by Google, Inc. (“Google”), to better assist Us in understanding how the Sites are used. Google Analytics will place cookies on Your computer or device that will generate information that We select about use of the Sites, including a computer’s or device’s IP address. That information will be transmitted to and stored by Google. The information will be used to evaluate Our players’ use of the Sites, compile reports on Sites’ activity for Galadriel Labs's use, and provide other services relating to Site activity and usage.

D. Affiliate Information.

When You register for an Account, We will also verify whether You have a current Galadriel Labs Rewards Account. We may obtain additional information about You from Galadriel Labs and platforms that are owned, operated, managed by or affiliated with Galadriel Labs, from Our other parent and affiliated companies, and from third parties, including Our business partners and other companies and individuals that refer You to the Services.

III. HOW WE USE THE INFORMATION WE COLLECT AND OPT-OUT OPTIONS

Marketing Purposes. We may use the information We collect for Our own marketing purposes, including notifying You of special promotions, offers, and events via push notifications, e-mail, and other means. We may use Your Personal Information to create and update consumer profiles, determine eligibility for offers and predict preferences, interests and future gaming activities. We may also link Personal Information with non-Personal Information and use such information for Our own marketing purposes.

Non-Marketing Purposes. We may use the information We collect for non-marketing purposes (collectively “Non-Marketing Purposes”) including:

IV. HOW WE DISCLOSE THE INFORMATION WE COLLECT

We may disclose Personal Information about You to Galadriel Labs for marketing purposes and for Non-Marketing Purposes.

We may disclose the information We collect to Our business partners for marketing and Non-Marketing Purposes. We may engage service providers to provide certain services to Us or to perform certain services on Our behalf including analytics, marketing, fulfillment, and to meet Our other business needs. In some cases, service providers may collect or be provided with access to Your information to perform such services.

We may disclose all information We collect to any successor to all or part of Our business in connection with a transaction involving a sale, purchase, reorganization, merger, or transfer of any Our assets or the assets of Affiliates. We may disclose Personal Information to any third party to whom You consent or instruct Us to provide Your Personal Information.

V. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

The length of time We retain Personal Information depends on the reason the Personal Information was originally collected, how We use the Personal Information in connection with Our operations, and requirements applicable to the Personal Information. This may include, without limitation, retaining Personal Information to continue Our ongoing business relationship with You, ensure the security and integrity of the Services, and satisfy applicable legal or reporting requirements.

VI. YOUR RIGHTS AND CHOICES

To opt out of receiving marketing communications from Galadriel Labs, visit the ‘Account Settings’ --> ‘Communication Preferences’ tab of Your Account Details, e-mail Us or click the “unsubscribe” link provided in any e-mail You receive from Us.

Requests to close or delete an account may be made by logging into Your account and selecting Service Closure or by contacting Our Customer Care team. We will delete Your account information once We no longer need to retain it for the purpose(s) for which it was retained.

VII. SECURITY

We have measures in place designed to prevent the unauthorized or unnecessary disclosure of the Personal Information We collect and designed to ensure that Personal Information about player accounts is kept confidential and processed pursuant to this Policy or as required by applicable law. Our servers are protected by firewalls and other industry standard security measures. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach. We cannot enforce or control the security of the computer equipment, electronic devices, or electronic communication methods that You may use to send e-mails and submit information to Us over the Internet.

VIII. OTHER WEBSITES

Our Sites may contain links to other websites. The fact that We link to a website is not an endorsement, authorization or representation of Our affiliation with that third party. We do not exercise control over third-party websites. Third parties may place their own cookies or other files on Your computer or mobile device and collect or solicit Personal Information subject to their own privacy policies.

IX. INTERNATIONAL TRANSFERS

Information collected on the Services may be stored and processed in any country in which We or Our Affiliates, suppliers, third-party electronic payment processors and/or financial institutions or agents maintain facilities. By using the Services, You expressly consent to any transfer of information outside of Your country (including to third countries that may not have been assessed as having adequate privacy laws).

X. PERSONS UNDER 21

The Services are for use by persons 21 or older. If You are under 21, You may not access, attempt to access, or use the Services. We do not knowingly collect, allow the collection of, sell or share Personal Information of persons under 21. If You know someone under the age of 21 who is registered with Us, please contact Us immediately.

XI. CHANGES TO THIS POLICY

We may revise this Policy from time to time in Our sole discretion and any changes will be effective upon the date of the revised Policy. You are solely responsible for reviewing the Policy for any changes.

XII. CONTACT US

If You have any general questions or issues regarding the Galadriel Labs Platform or Your Account, please contact Our Customer Care team by e-mail.