Privacy Policy / Your California Privacy Rights

BY VISITING THIS WEBSITE AND REQUESTING INFORMATION, PRODUCTS OR SERVICES THERON, YOU
AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY. IF YOU DO NOT
AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT PROVIDE ANY INFORMATION OR
USE ANY OF THE SERVICES OR PRODUCTS OFFERED OR PROVIDED ON ANY OF THE WEBSITES
REFERRED TO IN THIS PRIVACY POLICY.

luckyspinwin.com (“Company,” “we” or “us”) reserves the right to revise this Privacy Policy at any time simply by
posting such revision, so we encourage you to review it periodically. In order to track any changes to this
Privacy Policy, we will include a historical reference at the top of this document.

ACKNOWLEDGEMENT/YOUR AGREEMENT

Company websites are not intended for use by individuals under the age of 18 or those who are not legal
residents of the United States. By using our website or submitting information to us, you consent to the
Company’s use and sharing of the information collected or submitted as described in this Privacy Policy. If you
are not 18 years of age or older and a valid resident of the United States or you do not agree with the terms of
this Privacy Policy, do not provide us with any information or use any of the products or services offered or
provided on Company websites or through Company technology.

YOUR CALIFORNIA PRIVACY RIGHTS

Beginning January 1, 2005 under California’s “Shine the Light” law, California residents who provide personal
information in obtaining products or services for personal, family or household use are entitled to either: (1) a
list detailing the categories of information shared and the entities to which such information was provided; or (2)
to be notified of a mechanism by which a consumer may opt-out of having their information shared with third
parties. We have elected the second option. If you wish to opt out of having your information shared with third
parties, please send an email to info@giveaway-zone.com.

HOW DO WE COLLECT INFORMATION AND WHAT INFORMATION DO WE COLLECT?

We collect and combine personally identifiable information (“PII”) and non-personally identifiable information
(“Non-PII”) through various sources, including those discussed below. For your reference, PII is data collected
with an intention to specifically identify, contact or locate a person, including but not limited to name, address,
telephone number, or e-mail address. Conversely, Non-PII is data that is not used to specifically identify,
contact or locate an individual, including but not limited to zip code, gender, age, or IP address.

Website Registration Forms

We collect information about you when you register on one of our websites. This registration information may
include, but is not limited to your:
* full name
* mailing address
* telephone number
* date of birth
* gender
* e-mail address

Offer Forms

We also collect information about you when you complete a survey or offer form on one of our websites or web
pages. This information may include, but is not limited to: your e-mail address, name, mailing address, tele-
phone number, date of birth, gender, and payment information; information about your background, interests,
health, education, career goals, and shopping preferences; and any other personal information or unique
preference information you provide to us or our advertisers.

Distribution Partners

Website operators that license our ad serving technology pass information to us so that we may serve adver-
tisements to you. The information passed may include, but is not limited to, your IP address, e-mail address,
name, mailing address, telephone number, date of birth, and gender.

Publisher Partners

When you complete a registration or offer form that is hosted by one of our website publisher partners on our
behalf, the website publisher partner may submit all or a portion of the information that you submitted on the
form to the Company. This information may include, but is not limited to your IP address, e-mail address,
name, mailing address, telephone number, date of birth, gender, and payment information; information about
your background, interests, health, education, career goals, and shopping preferences; and any other infor-
mation you provide to our website publisher partners.

Marketing Partners

We may receive information about you, including but not limited to your IP address, e-mail address, first name,
last name, mailing address, and telephone number, from third party marketing partners that provide us with
consumer data to manage on their behalf.

Automatic Information/Digital Identifiers

We may automatically receive and store certain types of information about you through the data sources listed
above.
You may be family with the term “cookies,” which are unique alphanumeric identifiers that store information on
your computer. A cookie is placed on your computer when your web browser accesses our website. We use
cookies for tracking transactions and the user characteristics explained in detail throughout this Privacy Policy.
If you choose, there are utilities available for purchase from independent software providers to install on your
computer as well as tools/preferences you can choose through most web browsers to make website visits
anonymous. Of course, cookies let you have a more satisfying website experience, so we recommend that you
leave then turned on.
We also collection information through our web server applications. This information includes your Internet
Protocol or “IP” address, date/time stamp, browser type, and referring URL.
Additionally, we may use pixel tracking technology to track the completion of transactions with us or our adver-
tisers, the source information for those transactions, and your IP address, date/time stamp, browser type, and
referring URL.

Government Forms

The Company may be required to create, collect, maintain, and submit certain information required by the
government, such as IRS Forms W-9 and 1099. This information, which may include your taxpayer identifica-
tion number, will not be used, shared, transferred, or sold for marketing purposes.

HOW DO WE USE THIS INFORMATION?

We may use the collected PII and Non-PII for any legally permissible purpose in our sole discretion, including
but not limited to those explained below.

Pre-select/Pre-fill Offers

Our website technology may pre-select certain offers for you to view based on the demographic and geo-
graphic information you submitted to the Company during the website registration process. Additionally, this
technology may pre-fill some or all of the offers’ data fields with the information you submitted during the
website registration process in order to prevent you from having to re-enter this information. We may not show
all of the pre-filled data fields to you.

Customer Service and Fulfillment

We may use your information to operate the website promotion, service your account and to fulfill rewards
earned through Company websites. We may also use your information to verify your identity or claimed
account status and, where we consider appropriate, investigate your compliance with the terms and conditions
of the website promotion or any advertiser offer. We do retain customer service correspondence.

Credit Card Preauthorization

By submitting your credit card information to us or to one of our advertisers, you are authorizing the Company
or its agents to periodically verify that your credit card account is valid and has credit available by charging, and
thereafter crediting, a small sum to the card.

Marketing

We may use your information in our online (e.g., e-mail marketing) and offline (e.g., telemarketing, cell phone
text messaging, skip tracing, and direct mail) marketing programs. If you would like to be removed from these
programs, follow the opt-out instructions.

HOW DO WE SHARE INFORMATION?

We may share the collected PII and Non-PII for any legally permissible purpose in our sole discretion, including
but not limited to those explained below.

Within the Company

We may share information we collect with affiliated companies, including our parent company and other subsid-
iaries of our parent company, for use in their ad serving and marketing programs. This Privacy Policy does not
apply to affiliated companies and their collection, use and sharing of information.

Vendors

We may share our information with various third party vendors that are not part of the Company, including but
not limited to vendors that provide us with technology to deploy commercial e-mail, vendors that sell the
products or services for which you have qualified through one of our websites, and shipping companies that
we utilize to ship products to you.

Advertisers

When you participate in an offer by completing a form, we will transfer the information you submitted on the
form to the applicable advertiser.
When you answer “yes” or “no” to a survey question some or all of the information that you submitted during
the website registration process will be transferred to advertisers that we believe may be of interest to you
without providing you with another opportunity to review the information.
When you select “yes” next to an offer, we will transfer some or all of the information that you submitted during
the website registration process to the applicable advertiser without providing you with another opportunity to
review the information.

Marketing Partners

We may share, license or sell your information to third parties for various marketing purposes, including their
online (e.g., e-mail marketing) and offline (e.g., telemarketing, cell phone text messaging, skip tracing, and
direct mail) marketing programs.

Data Enhancement/Appending/Validation

We may use third party service providers to enhance our database with additional elements, including but not
limited to age ranges present in your household, whether you own or rent a home, the length of time you have
lived at your residence, whether you are a mail order buyer or responder, household income, and gender.
Further, we may use third party service provider to append telephone numbers to other data points we have
in our database. We also may use third party service providers to validate the data we have in our database.
Additionally, we may share, license or sell your information to third parties for use in their data validation,
enhancement, information verification services, and, to the extent permitted by law, individual reference or
look-up services.

SMS, Wireless and Other Mobile Offerings

Some of the services that we provide will result in sending an SMS, wireless or other mobile offering to your cell
phone. These should be obvious in the context of the offering at the time you sign up. By signing up, you are
agreeing to receive these mobile offerings. You understand that your wireless carrier’s standard rates apply to
these messages. To unsubscribe or discontinue SMS messages, send “STOP”, “END”, “QUIT” to the SMS text
message you have received. This process impacts only the future delivery of the particular SMS message
offering, so you must send that message for each offering. This will not affect offerings sent on behalf of third
parties.

Governmental Agencies or Other Companies

We may share your information with law enforcement officials or governmental agencies: (1) in response to
their request; (2) when permitted or required by law; or (3) to establish our compliance with applicable laws,
rules, regulations, or guidelines.
We may store and share your information with third parties for suppression or opt-out purposes.
We also may share your information with third parties when: (1) trying to protect against or prevent actual or
potential fraud or unauthorized transactions; (2) investigating fraud that has already taken place; (3) enforcing
or applying existing terms and conditions and/or other agreements; (4) protecting the rights, property or safety
of our websites, our users or others; or (5) responding to subpoenas, court orders or legal process, or to
establish or exercise our legal rights or defend against legal claims.
In all cases, this information is not provided to these entities or persons for marketing purposes.

Right to Transfer

Should the Company choose to sell or transfer business assets, it is possible that the information we possess
may be transferred as part of that transaction. The Company may decide to retain a copy of the information
post sale or transfer.

COMPANY CUSTOMER CHOICES

Marketing Communications

By completing and submitting a Company registration form, you are consenting to receive marketing communi-
cations from the Company and its third party marketing partners. If, after you have shared your information with
the Company, you decide that you do not want to receive marketing communications from the Company and
its third party marketing partners, you can discontinue the communications by following the opt-out instruc-
tions. If you have registered or submitted information under more than one e-mail account, you must submit
separate unsubscribe requests for each account.

Request for More Information

If you have questions about this policy, please contact us at info "at" luckyspinwin.com. or write to us at
Prozone Marketing LLC 297 Kingsbury Grade, Suite D, P.O. Box 4470 Lake Tahoe, NV 89449


LIMITATION OF LIABILITY

YOU UNDERSTAND AND AGREE THAT ANY DISPUTE OVER PRIVACY IS SUBJECT TO THE TERMS AND
CONDITIONS OF THIS PRIVACY POLICY, AS WELL AS THE TERMS AND CONDITIONS OF THIS WEBSITE
(INCLUDING LIMITATIONS ON DAMAGES). YOU AGREE THAT THE COMPANY’S LIABILITY FOR ANY
BREACH OR THIS PRVACY POLICY SHALL BE LIMITED TO THE VALUE OF THE TRANSACTIONS OR
SERVICES PROVIDED TO YOU BY THE COMPANY TO THE EXTENT SUCH CLAIM IS NOT OTHERWISE
BARRED BY OUR TERMS AND CONDITIONS.