PGS Amusements, LLC Privacy Policy
1. Introduction and Scope
This Privacy Policy describes how PGS Amusements, LLC ("PGS," "Company," "we," "us," or "our") is the operator of the Pandora Pay platform and the Sponsor of promotional Sweeps Coin sweepstakes offered through the Services, and, collects, uses, discloses, retains, and protects information when you access or use our website, mobile applications, platform, account and secure vault features, AI-generated digital art services, custom AI art services, promotional Sweeps Coin Games, payments, purchases, redemptions, customer support, and related services (collectively, the "Services").
This Privacy Policy applies to consumers, users, account holders, visitors, participants in promotional features, and, where applicable, business clients, Brands, vendors, authorized representatives, and other individuals whose information is processed through the Services. Additional terms, sweepstakes rules, promotion rules, and contractual terms may also apply to specific features.
By using the Services, you acknowledge the practices described in this Privacy Policy. Where required by law, we will obtain your consent or provide additional choices before collecting or using certain information.
3. Information We Collect
We may collect information directly from you, automatically through your device or browser, from third-party verification tools, from payment and banking partners, from business partners or Brands, from fraud and security vendors, from public or commercially available sources, and from your interactions with the Services. The exact information collected may depend on the features you use, your location, account status, verification requirements, and applicable legal or partner obligations.
3.1 Personal and Account Information
- Full name, username, account credentials, account status, profile information, date of birth, and eligibility status;
- Email address, phone number, mailing address, billing address, and other contact information;
- Preferences, communication settings, support preferences, and account settings.
3.2 Identity Verification, Age, Location, and Eligibility Information
- Government-issued ID information, ID images, verification status, document authenticity results, address verification, and related KYC/identity verification records, where required or supported by vendor workflows;
- Selfie, liveness, facial comparison, or similar verification data processed by identity verification vendors where applicable;
- Age verification, eligibility, location, IP address, device, VPN/proxy/Tor indicators, and other signals used to confirm eligibility or prevent prohibited access.
3.3 Financial, Transactional, Redemption, and Tax Information
- Bank account and routing information, linked debit or credit card details, payment processor tokens, purchase information, payout information, redemption details, and payment method information, where applicable;
- Transaction amounts, dates, times, location or device signals, purchase history, promotional Sweeps Coin activity, gameplay results, prize redemptions, refunds, chargebacks, disputes, and related audit records;
- Tax reporting information where required, including information needed to support reporting, withholding, or recordkeeping obligations.
3.4 Business / Brand Information
- Legal business name, entity type, employer identification number (EIN), tax records, business licenses, business banking details, ownership/control information, authorized representatives, and business KYC documents, where applicable;
- Device, IP address, and activity logs for business users, Brand users, administrators, or representatives.
3.5 Technical, Usage, Cookies, and Device Information
- IP address, geolocation information collected through browser/device signals, device identifiers, browser type, operating system, app version, language settings, session times, clickstream data, pages or screens viewed, and other usage data;
- Cookies, pixels, software development kits (SDKs), analytics tools, security tools, and similar technologies used to operate, secure, improve, measure, or market the Services.
3.6 Communications, Support, and Survey Information
- Support tickets, chat logs, inbound and outbound email communications, text messages, call recordings where applicable and legally permitted, feedback, survey responses, and dispute communications.
3.7 AI Art, User Content, and Custom Prompt Information
- Custom AI art prompts, uploaded reference images or files, generated art, metadata, user-selected package details, user vault records, content moderation records, and communications related to AI-generated digital art services;
- Information needed to deliver, display, store, secure, support, or document ownership/access to digital art purchased or generated through the Services.
3.8 Sensitive Personal Information
Some information we collect may be considered sensitive personal information under applicable law, such as government ID information, financial account information, precise geolocation if collected, identity verification information, selfie/liveness or facial comparison information, account credentials, and certain fraud, sanctions, or security records. We use sensitive information only for permitted purposes, such as providing the Services, verifying identity and eligibility, preventing fraud and abuse, securing accounts, processing payments and redemptions, complying with law, and protecting users and the
platform. We do not knowingly use sensitive KYC/IDV information, financial credentials, or government ID images for marketing or general AI model training.
4. How We Use Information
We may use information for the following purposes:
- Create, maintain, authenticate, secure, and administer accounts and user vaults;
- Provide, personalize, operate, maintain, troubleshoot, and improve the Services, including AI-generated digital art services and custom art functionality;
- Process purchases, payments, transfers, redemptions, payouts, refunds, chargebacks, tax reporting, and related transaction activity;
- Verify identity, age, location, eligibility, payment method, account ownership, and business/Brand information;
- Detect, prevent, investigate, and respond to fraud, abuse, prohibited activity, policy violations, account takeover, chargebacks, identity misuse, sanctions exposure, underage use, prohibited location access, and security incidents;
- Conduct risk-based compliance reviews, transaction monitoring, support quality checks, dispute resolution, and operational reviews appropriate for our size and current business needs;
- Communicate with you about your account, transactions, redemptions, support requests, security alerts, service updates, policy changes, and promotional or marketing messages where permitted;
- Comply with applicable laws, regulations, tax obligations, court orders, subpoenas, legal processes, reporting obligations, partner requirements, and contractual obligations;
- Enforce our Terms & Conditions, Official Sweepstakes Rules, game specific rules where applicable,, contracts, and legal rights;
- Develop aggregate, de-identified, or anonymized information for analytics, reporting, product improvement, security, and business purposes.
5. Cookies, Tracking, Analytics, and Marketing Choices
We and our service providers may use cookies, pixels, SDKs, device identifiers, analytics tools, log files, and similar technologies to operate the Services, remember preferences, authenticate users, maintain security, detect fraud, understand usage, measure performance, improve features, and deliver or measure communications and marketing where permitted.
You may be able to control cookies and tracking through browser settings, device settings, in-app settings, consent tools, unsubscribe links, or other methods we make available. Blocking certain cookies or device permissions may affect the functionality of the Services. Where legally required and technically feasible, we will honor applicable opt-out preference signals, consent choices, or similar mechanisms.
6. How We Share Information
We may disclose information to the following categories of recipients for the purposes described in this Privacy Policy:
| Recipient Category | Examples / Purposes |
|---|---|
| Service Providers and Vendors | Payment processors, banking partners, identity verification providers, cloud hosting providers, customer support tools, analytics providers, security vendors, fraud prevention vendors, sanctions/PEP/adverse media screening vendors, AI technology providers, tax/reporting providers, consultants, legal counsel, and professional service providers. |
| Business Partners / Brands | Brands, sweepstakes operators, co-branded partners, integration partners, or other business partners where your interaction, account relationship, promotion participation, consent, or the Services require sharing. |
| Payment, Banking, and Redemption Partners | Banks, processors, payment networks, payout providers, chargeback/dispute handlers, and other partners needed to process payments, purchases, redemptions, payouts, refunds, and financial compliance obligations. |
| Legal, Regulatory, and Safety Recipients | Regulators, law enforcement, courts, government agencies, payment partners, tax authorities, legal counsel, auditors, or other parties when required or permitted by law, legal process, investigation, audit, compliance, fraud prevention, or safety/security purposes. |
| Corporate Transaction Parties | Parties involved in a merger, acquisition, financing, reorganization, bankruptcy, asset sale, transfer, or similar business transaction, subject to appropriate confidentiality or legal protections. |
| With Your Consent or Direction | Other parties when you request, authorize, direct, or consent to sharing. |
We do not sell or rent your personal information to third parties for their independent marketing use. We also do not knowingly sell personal information or share personal information for cross-context behavioral advertising as those terms are defined by applicable privacy laws, unless we disclose such practices and provide any required opt-out rights. If our practices change, we will update this Privacy Policy and provide choices where required.
7. KYC, Age, Location, Fraud, and Compliance Checks
To protect users, comply with legal and partner requirements, and prevent misuse of the Services, PGS may verify identity, age, location, eligibility, payment method ownership, account activity, and fraud risk. These checks may involve third-party identity verification vendors, payment processors, banking partners, fraud prevention vendors, device intelligence providers, geolocation tools, sanctions/PEP/adverse media screening tools, and similar providers.
Verification vendors may process government ID information, selfie/liveness captures, facial comparison information, device data, IP address, geolocation signals, and verification results. In some cases, these vendors may collect and store certain verification materials directly, and PGS may receive verification status, risk indicators, audit records, or other results needed to operate the Services. We use this information to determine whether an account may be opened, maintained, restricted, suspended, closed, or eligible for purchases, promotional features, redemptions, or payouts. Where legally required, we will obtain consent before processing biometric identifiers or biometric information.
8. AI-Generated Digital Art, Prompts, and User Content
When you request or purchase AI-generated digital art, including custom art, we may process prompts, descriptions, uploaded reference images or files, generated outputs, metadata, package selections, ownership/access records, and support communications. We use this information to provide the requested art, deliver it to your account or vault, support your access, enforce applicable terms, moderate prohibited content, prevent misuse, and resolve disputes.
If third-party AI tools or infrastructure providers are used to generate or support art services, those providers may process prompts, uploaded content, generated art, metadata, or related technical data as service providers or processors. We will not intentionally submit government ID images, bank credentials, sensitive KYC/AML records, or payment account credentials to AI tools for art generation or general AI model training.
Your ownership or license rights in generated art are governed by the applicable Terms & Conditions, purchase terms, or promotion rules. This Privacy Policy addresses privacy and data processing, not intellectual property ownership.
9. Your Privacy Choices and Rights
Depending on where you live and subject to applicable exceptions, you may have the right to:
- Access or obtain a copy of certain personal information we maintain about you;
- Correct inaccurate personal information;
- Request deletion of certain personal information;
- Request data portability where available;
- Opt out of marketing emails or promotional messages;
- Control cookies, tracking technologies, and device permissions where available;
- Withdraw consent where processing is based on consent and withdrawal is legally available;
- Limit or opt out of certain uses of sensitive personal information, targeted advertising, sale, or sharing if applicable under your state privacy law;
- Appeal a privacy rights decision where required by law;
- Use an authorized agent where permitted by law. To submit a privacy request, contact us at privacy@pgsamusements.com or use the privacy or support tools we make available. We may need to verify your identity before fulfilling a request.
We may deny or limit requests where permitted by law, including when retention is needed for KYC/AML, sanctions, fraud prevention, age/location compliance, account security, tax reporting, dispute resolution, legal claims, audit, regulatory obligations, or contractual requirements. We will not discriminate against you for exercising privacy rights, although some requests may affect your ability to use certain Services.
10. Data Security
We use reasonable administrative, technical, and physical safeguards designed to protect information against unauthorized access, loss, misuse, disclosure, alteration, or destruction.
No method of transmission or storage is completely secure. We cannot guarantee absolute security, but we work to maintain reasonable safeguards appropriate to the nature of the information, the Services, and our current operations. If we determine that a security incident requires notification, we will notify affected users, regulators, or other parties in accordance with applicable law and contractual obligations.
11. Data Retention
We retain information for as long as reasonably necessary to provide the Services, maintain accounts and user vaults, process transactions and redemptions, comply with legal, tax, AML/KYC, sanctions, payment partner, and contractual obligations, resolve disputes, prevent fraud and abuse, maintain security, enforce our terms, and support audits and investigations.
| Data Category | General Retention Approach |
|---|---|
| Account and profile records | Retained while your account is active and for a reasonable period after closure, subject to legal, security, fraud-prevention, dispute, and business needs. |
| KYC / identity verification records | Generally retained for at least 5 years after account closure or the last transaction/redemption, or longer if required by law, partner requirement, investigation, or risk need. In some cases, vendors may retain verification records under their own contractual and legal obligations. |
| Payment, transaction, purchase, redemption, payout, refund, chargeback, and tax records | Retained as required for financial, accounting, tax, payment partner, contractual, audit, fraud-prevention, dispute, and legal purposes. |
| Fraud, sanctions, compliance, dispute, and investigation records | Retained as needed to prevent fraud and abuse, comply with law, evidence decisions, protect the platform, resolve disputes, and defend legal claims. |
| Support and communication records | Retained for support, quality assurance, dispute resolution, legal defense, compliance, and operational needs. |
| Technical, device, geolocation, cookie, security, and application logs | Retained based on security, fraud-prevention, analytics, troubleshooting, operational, legal, and audit needs. |
| AI art prompts, uploaded content, generated art, metadata, and vault records | Retained as needed to provide the Services, support account/vault access, document purchases or ownership/access, moderate content, resolve disputes, and enforce terms. |
When information is no longer needed, we may delete, de-identify, anonymize, aggregate, or securely dispose of it. Certain information may remain in backups until overwritten through normal backup cycles, unless legally required to be retained longer.
12. Children's Privacy and Age Restrictions
The Services and promotional features are not intended for individuals who do not meet the applicable minimum-age requirements set forth in the Terms and Conditions and Official Sweepstakes Rules. Participation in Sweeps Coin Games requires users to be at least 18 years old, or the age of majority in the user's jurisdiction if higher, as applicable. We do not knowingly collect or process personal information from minors under 18. If we learn that a minor has created an account or used the Services without authorization, we may suspend or close the account, delete information where appropriate, and retain limited records where necessary to prevent misuse, comply with law, or document the decision.
13. International Users
PGS is headquartered in the United States. If you access the Services from outside the United States, your information may be transferred to, stored in, accessed from, or processed in the United States or other jurisdictions where we or our service providers operate. Data protection laws in those jurisdictions may differ from the laws where you reside. By using the Services, you acknowledge this transfer and processing, subject to applicable law.
14. State-Specific Privacy Notice
Residents of certain U.S. states may have additional privacy rights and disclosures under applicable state privacy laws. The categories of information we may collect, the sources of information, the purposes of use, and the categories of recipients are described in Sections 3 through 6 of this Privacy Policy. We may update this section or provide additional state-specific notices as our legal obligations, user base, or data practices change.
We do not knowingly sell personal information or share personal information for cross-context behavioral advertising unless disclosed and supported by legally required choices. If you believe a specific state privacy law applies to your request, please contact us at privacy@pgsamusements.com and include the state where you reside.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time, including as PGS grows, adds features, changes vendors, expands jurisdictions, or updates its legal, compliance, payment, security, or operational practices. If we make material changes, we will notify you through the Services, by email, or by other legally required methods. The "Last Updated" date reflects the latest revision. Your continued use of the Services after an update means you acknowledge the updated Privacy Policy, subject to applicable law.
16. Contact Us
If you have questions, complaints, privacy requests, or concerns about this Privacy Policy or our data practices, please contact:
- PGS Amusements, LLC / Pandora Pay Privacy Contact
- Email: privacy@pgsamusements.com
- Account deletion/support requests: support@pgsamusements.com Hours: Monday-Friday, 9:00 AM to 5:00 PM EST