LAST UPDATED 02/22/2017

	Privacy Policy

	Welcome to the SpinToWin Privacy Policy ("Privacy Policy"). LTV Games LLC ("STW") is committed to respecting and protecting your privacy.  The phrase "SpinToWin" refers to the SpinToWin App ("App"), website ( ("Website"), any SpinToWin software application that is installed anywhere on your computer system or mobile device, and a system of portals, online applications, and social media applications employed to enhance your Internet experience. SpinToWin Members and guests shall be referred to in the singular as "User" or "you" and in the plural as "Users".

	This Privacy Policy ("Privacy Policy") sets outs the basis on which any personal data STW collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand STW's views and practices regarding your personal data and how STW will treat it.

	This Privacy Policy applies only to information collected by SpinToWin and does not apply to information collected outside of SpinToWin, including but not limited to companies or websites featured on SpinToWin.


	STW does not require Users to register or submit PII in order to visit the SpinToWin Website, download the SpinToWin application, or playing the App as a guest. STW may collect certain user information from you when you become a registered Member of SpinToWin including but not limited to: your name, email, zip code, cell phone number, age, gender, birthday, Facebook photograph, Facebook profile information, Facebook friends, and contact lists.

	STW may collect and process the following information from Users:

	A.	Personally Identifiable Information ("PII")
	STW may collect and process any information you provide SpinToWin, enter on the SpinToWin Website or provide to STW in any other way through or via SpinToWin that would allow STW to identify you personally or contact you (collectively "Personally Identifiable Information" or "PII").

	Examples of PII that STW may collect from you, includes the following:

	a.	Your name;
	b.	Address;
	c.	phone number(s);
	d.	e-mail address;
	e.	screen name;
	f.	Your social network or third party service user identification number;
	g.	Your mobile device's unique identifier (UDID);
	h.	Transaction identifiers for purchases;
	i.      Your profile picture;
	j.      PII you provide about yourself when you send STW an e-mail.
	k.	Any other relevant information included in your application, social network or other online profile; and

	You can choose not to provide STW with certain PII, but then you may not be able to become a SpinToWin Member, receive sweepstakes entries, or use certain SpinToWin services or products.

	B.	Passive Gathering of Information Electronically

	a.	Cookies and other tracking technologies
	STW may obtain information about your general Internet usage by using cookie files which are small pieces of information that are stored by your browser or on your computer or mobile devices hard drive. These cookies are designed to not contain or collect any PII, but they do contain information which is transferred to your computer or mobile device's hard drive and they do enable STW to provide features such as personalization.

	Web beacons are a type of tracking device and are a transparent image file. Web beacons enable STW to track website usage information, such as the number of times a given web page has been viewed. Web beacons are invisible to you and (unlike cookies) are not placed on your computer.

	Web beacons may be used in association with cookies to understand how visitors interact with the pages and content on the pages of the Website. STW may use web beacons to track usage information and to compile information about how SpinToWin Users use different products and services and when they click through to offers shown on the Website. Web beacons may also be used to track whether you have opened an HTML email. When the email is opened a part of the code that makes up the HTML page calls a web server to load the web beacon which then generates a record showing that the email has been viewed. Web Beacons may also recognize when the email was opened, how many times it was forwarded and which URL's (links within the email) were clicked. For the purposes of this privacy policy "Cookies" shall mean cookies and all other tracking devices including web beacons.

	Most web browsers automatically accept Cookies, but you can usually change your browser to limit or prevent cookies. Cookies in themselves do not identify the individual user, but rather the computer used. Users may have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or to not receive cookies at any time. Different browsers may address Cookies differently. If you set the browser to not accept cookies, it may result in certain personalized services not being provided to users of that computer. Unless you have adjusted your browser settings so that it will refuse cookies, STW's system will issue Cookies as soon as you visit the Website.

	Except for essential cookies, all Cookies will expire after end of session.

	Cookies are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

	b.	Click Stream Data
	SpinToWin may enable STW and third parties working with STW to collect, log, and analyze information about your online activity as part of its functionality. This is known as "Click Stream Data" which includes, but is not limited to, information such as your IP address, operating system and browser type, clicks, URLs of web pages that you have viewed, the date that you viewed the web pages, web beacons, and cookie data. STW and third parties working with STW may use information collected for system administration, to report aggregate information to advertisers and to target promotions and other content to you in an effort to create a personally relevant experience, enhance your experience or research, analyze, or enhance SpinToWin. This is statistical data about STW's Users' browsing actions and patterns and does not identify any individual.

	C.	E-mail Communications
	When you send an e-mail to STW, either through the Contact Us or Member Services areas of the SpinToWin Website or otherwise, STW may retain your e-mail address and the contents of the e-mail you send. When you register with STW and provide your email address, STW may contact you for promotional reasons, to let you know that you won a prize, or for other reasons related to your account with STW.

	D.	Non-Personally Identifiable Information
	STW may also ask you to provide STW with Non-Personally Identifiable Information ("Non-PII") which is data that, when taken alone, does not allow STW to identify you.  Non-PII may include but is not limited to:

	a.	Age or date of birth;
	b.	Gender;
	c.	First name;
	d.     Information about the hardware you may own; and
	e.	Gaming preferences and promotional preferences, and household characteristics like presence of children or income bracket.

	Your non-PII may be aggregated and used for STW's internal purposes or for creating reports for third-party advertisers and partners, or otherwise shared with third parties for any lawful purpose, without your permission. No third party will know who you are as a result of the use of your non-PII. SpinToWin may enable STW and third parties working with STW to collect, log, and analyze information about your online activity as part of its functionality. This is known as "Click Stream Data" which includes, but is not limited to, information such as your IP address, clicks, URLs of web pages that you have viewed, the date that you viewed the web pages, web beacons, and cookie data. STW and third parties working with STW may use information collected through SpinToWin to target promotions and other content to you in an effort to create a personally relevant experience, enhance your experience or research, analyze, or enhance SpinToWin.

	STW may use your PII and Non-PII for a number of purposes, including but not limited to the following:

	A.	As part of Members profile and to manage Member accounts, pop-up application down-load, surveys or promotional activity;

	B.	To facilitate communication between STW and Users including, without limitation, responding to Users questions or comments, sending e-mails, offers, and other promotions, or to contact you for feedback regarding SpinToWin, STW advertisers or business partners;

	C.	To provide a report to STW advertisers or business partners that tells them who responded to a particular offer;

	D.	To research and analyze Users online activity;

	E.	To research, analyze, adjust, improve, and customize SpinToWin to better meet the needs and expectations of Users, advertisers, or business partners; and

	F.	To enforce STW's agreements with you, prevent fraud, and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that STW comply with applicable laws.

	STW may give, share, sell or trade your PII and Non-PII to or with any third parties under the following circumstances:

	A.	Fulfillment of Services
	STW may retain other companies and individuals to perform certain functions on STW's behalf. Examples include companies that help to administer surveys, promotional activities, third party advertisers, or promotional partners who provide a product or service to you, customer support specialists, web hosting and Internet service companies and data analysis firms. Such third parties may be provided with access to PII needed to perform their functions but may not use such information for any other purpose

	B.	Disclosure to Third Party Advertisers and Promotional Partners
	STW may share your PII with third party advertisers or promotional partners.

	C.	STW does disclose Users Non-PII information to its advertisers
	STW may provide its advertisers with aggregate information about Users (for example, STW may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). STW may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women between the ages of 21 of 35 years old). STW may make use of the personal data STW has collected from you to enable us to comply with advertisers' wishes by displaying their advertisement to that target audience.

	D.	Compliance with Law and Fraud Protection
	STW may disclose any information, including PII, that STW deems necessary, in its sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. STW may also exchange information, including, without limitation, PII, with other companies and organizations for credit fraud protection, risk reduction, and related activities or to protect the rights, property, safety of STW, its agents, employees, affiliates or others. STW reserves the right to disclose PII for a User who STW believes is in violation of SpinToWin's Terms of Service, Privacy Policy or End User License Agreement, even without a summons, warrant, court order or other governmental request.

	E.	Sale or Transfer of Information
	In the event that STW sells or buys any business or assets, STW may disclose your PII and Non-PII to the prospective seller or buyer of such business or assets. If SpinToWin or substantially all of its assets are acquired by a third party, PII and Non-PII held about Users will be one of the transferred assets.

	If you want SpinToWin to stop using your PII for its own marketing purposes please send us an email to STW at with the subject line "STW Marketing", or mail your request to LTV Games LLC, 1583 33rd Ave, San Francisco, CA 94122. If you choose to opt-out of further direct marketing from third parties or from STW, STW will keep your e-mail address, phone number, name, and physical address on file for the purpose of honoring your request. In addition, you may unsubscribe from specific marketing emails from either STW or third parties by following the instructions on how to "unsubscribe" in those e-mails. Please keep in mind that any changes that you make to your email preferences may take up to ten (10) business days to process and the sender of the e-mail has the obligation to honor a request to unsubscribe. STW is not responsible for any third parties' failure to honor an opt-out request. Please also note that STW may continue to contact you to provide service to your account as long as you are a SpinToWin Member.

	A.	Updated Versions of SpinToWin
	SpinToWin will periodically contact servers at STW to download and automatically install the latest version of SpinToWin on your computer or mobile device or prompt you to accept the latest version of SpinToWin on your computer or mobile device.

	B.	Your Account Information
	When you register to become a SpinToWin Member, the information you provide SpinToWin will be stored in a profile on your "My Account" page. The profile, or a portion thereof, may be viewed by STW and anyone else to whom you provide the e-mail and password associated with your account or anyone who has access to your computer when you are logged on to the SpinToWin Website. You are responsible for maintaining the confidentiality of your e-mail and password. You are entirely responsible for any and all activities which occur under your account whether or not authorized by you. You agree to immediately notify SpinToWin of any unauthorized use of your account.

	C.	Third Party Links and Third Party Advertisements
	The SpinToWin Website and App may contain links to third-party websites and apps. Please be aware that STW cannot control and are not responsible for the information collection practices of such websites or apps, which may differ from those of SpinToWin. STW encourages you to review and understand the privacy policies of these websites or apps before providing any information to them. STW may include banner, icon, or text advertisements for third parties (or for websites or apps operated by third parties) that are not sponsors of and are not affiliated with STW. Should you click on any such advertisement, you may leave the SpinToWin Website or App and be taken to the advertiser's website or app. STW is not responsible for the content, practices, or information practices (including but not limited to information practices relative to the gathering and use of PII) of the websites or apps operated by these third parties. In addition, these advertisements do not constitute sponsorship, endorsement, or approval by STW of the content, policies, practices, or products of these websites or apps. All Users should check the relevant website's privacy policy and Terms of Use in order to understand their policies and practices regarding the collection and use of your information, including PII.

	D.	Data Security
	SpinToWin has no control over the security of other websites or apps on the Internet that you might visit even when a link may appear to those websites or apps from SpinToWin. If you share your computer or use a computer that is accessed by the general public, remember to sign off and close your browser window when you have finished your session. This will help to ensure that others cannot access your PII.

	STW wants you to feel confident using SpinToWin. However, no system can be completely secure. Therefore, although STW takes commercially reasonable steps to secure your information, STW does not promise, and you should not expect, that your PII, searches, or other communications will always remain secure. In the event of a breach of the confidentiality or security of your PII, STW will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. STW may notify you under such circumstances using the e-mail address(es) STW has on record for you. Users should also take care with how they handle and disclose their PII.

	E.	Children
	SpinToWin is restricted to Users and not intended for persons under the age of 13. SpinToWin does not knowingly market to, or solicit or collect information from any person under the age of 13. If STW becomes aware that any person submitting a registration or information to SpinToWin is under the age of 13, STW will attempt to delete the account and any related information as soon as possible. STW require that only persons 13 years of age or older use SpinToWin. By using STW, you hereby represent that you are at least 13 years old.

	F.	Changes to this Privacy Policy
	STW may occasionally update this Privacy Policy to reflect changes in STW's practices. When STW post changes to this Privacy Policy, STW will revise the updated date at the top of this Privacy Policy. If STW makes any material changes to its Privacy Policy, STW only will notify Members by sending an e-mail to the e-mail address(s) provided to STW in the Member's account, profile, or registration, and by prominently posting notice of the changes on the SpinToWin Website. STW will give you an opportunity to opt-out of any materially changed Privacy Policy or alternatively, cancel your SpinToWin Membership. STW recommends that you check the SpinToWin Website or the information section of the SpinToWin App from time to time to inform yourself of any changes in this Privacy Policy or any of STW's other policies.

	G.	Access to Information
	STW respects the privacy of your PII. If you are a Member and would like to review, update or delete your profile, please log in to your account and select "My Account" where you can review, modify or delete your membership. If you are not a Member but have provided PII to us and wish to delete such information, you may reach us via the Contact Us page on the SpinToWin Website or in the information section of the SpinToWin App.

	H.	Contacting Us
	If you have any questions about, STW, SpinToWin, this Privacy Policy or the SpinToWin Website, please feel free to contact STW either by sending an email to or by regular mail by sending a letter to STW at LTV Games LLC, 1583 33rd Ave, San Francisco, CA 94122