IP BJ HOLDING BV Privacy Policy

Last Revised on 10-01-2025

This Privacy Policy for IP BJ HOLDING BV describes how we collect, use and disclose information about users of the Company’s website www.flipacoin.com, the Company app (“App”), services, tools and features (collectively, the “Services”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services.

Please read this Privacy Policy carefully. By using, accessing, or downloading any of the services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, you may not use, access, or download any of the Services. This Privacy Policy incorporates by reference our Terms of Service, which include an arbitration agreement and class action waiver that govern how disputes between us will be resolved.

1. Updating This Privacy Policy

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on our website and/or the App, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy, please do not access or continue to use the Services.

2. OUR COLLECTION AND USE OF INFORMATION

When you access or use the Services, we may collect certain categories of information about you from a variety of sources.

This Privacy Policy covers our use of any information that can or could be used to identify you (“Personal Data”). It does not cover information which cannot be used to identify you (“Anonymous Data”). We need to collect and use certain Personal Data to provide the Services to you and fulfill the promises we make to you in the Terms of Service.

Some features of the Services may require you to directly enter certain information about yourself. We provide you with choices regarding the collection, use, and sharing of your Personal Data. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services may include:

A. Account and Registration

Users may access our App only if they register an Account with us. The Personal Data we collect as part of the Account creation process includes your first and last name, email, username, password, information to confirm you are old enough to use the Services and use the App, payment information for any in-app purchases or storage of funds in your account (for example, your name and email associated with your payment account). We may also ask you or allow you to submit certain optional information, which may include your updated usernames, preferences, and other profile information.

B. External Account Sign-On

You may be required to have an account with a supported external single sign-on service in order to use some of our Services. Where this is the case, the Personal Data we collect also depends on which external accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access our Services.

Depending on the particular Service you sign up for, we may support other external single sign-on services and collect additional Personal Data from them. Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect this information from them.

C. Location of Your Device

We collect and use your device location information as you use our Services (and, if you elect to turn on background location tracking for participating Services, while you are not directly interacting with these Services), including how you move around and events that occur during in-app activity or gameplay. Our Services may include location-based games whose core feature is to provide an experience tied to your real-world location, so we need to know where you are to operate these apps and games for you and to plan the location of in-game resources. We identify your location using a variety of technologies, including GPS, the WiFi points you are accessing the Service through, and mobile/cell tower triangulation.

We also collect and use your in-game or in-app actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings, and information about third-party applications or software installed on your device), to operate the Services for you and to personalize your gameplay and user experience. We will also generate an internal account ID when you use certain Services to associate you with an account.

We further use the information above in order to provide technical and customer support to you.

D. Personal Data

When you interact with our Services (e.g., making purchases, subscribing, registering for events, entering competitions, or communicating with us), we collect personal data such as your name, address, phone number, country, age, and email. This data is used to fulfill services and provide customer support.

E. Cookies

We also rely on your consent where we use cookies or similar technologies. Please see our Cookie Policy for more information about how we use them. Insofar as cookies collect Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a pseudonym.

F. Do Not Track

While you may disable the usage of cookies through your browser settings, we do not currently respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to the lack of industry standard on how to interpret that signal.

G. Prizes and Payments

We collect information to process prize winnings, administer payments, comply with the law (including requiring W9 tax forms when necessary), and maintain records of prizes, which may include your email, full name, mailing address, Social Security or Taxpayer ID number, and other information necessary to complete a 1099-MISC tax reporting form, and other relevant tax documentation.

H. Feedback

We collect and maintain records of customer service and other communications with users including survey responses, questions or comments sent to us (including the nature of the nature of the request, name and contact information), or other similar activities. This information may be used to enhance the Services or the App and to market to you or others.

I. Custom Content

We may use the information we collect automatically to tailor features and content to you, to market to you, to provide you with offers or promotions, to run analytics and better understand user interaction with the Services.

3. ACCOUNT INFORMATION

If you would like to review or change the information in your account or terminate your account you can log into your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

4. PARTIES WE MAY SHARE YOUR INFORMATION WITH

We will not share any Personal Data that we have collected from or about you except as described below:

Information Shared with Our Service Providers

We engage external Service Providers to work with us to administer and provide the Services. As part of that, they will process your Personal Data on our behalf. These external Service Providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The Service Providers we use help us to:

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) as a Third-Party Service in accordance with their own privacy policy. Such external Third-Party Service does not share your financial information, like credit card number, with us, but it may share limited information with us related to your purchase, like your zip or postal code.

Information Shared with Other Players or Users

When you use the Services, and in particular when you play our App, use social features within the App, or take part in live Contests, we will share certain Personal Data with other players or users. This Personal Data includes your in-game or in-app profile (such as your username, your avatar, your online status, and your team), your in-game or in-app actions and achievements, real-world locations associated with your gameplay, or which gameplay resources you interacted with when playing the game, and your in-game messages and related content you share with other players or users. Additionally, certain games or apps link to third-party sharing features on your device that you can use to disclose Personal Data to others outside the Services; we do not control and are not responsible for the practices of these third-party sharing features.

Information Shared Publicly

When you use the Services, and in particular when you play our App, use competitive features, or participate in any forum we may establish, the following information about you may be shared on web pages accessible to the public and therefore become publicly available: your username, in-game or in-app profile, achievements, and public messages.

Information Shared with Third Parties

We share Anonymous Data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with any other third parties for their direct marketing purposes.

Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate:

Information Disclosed in Connection with Business Transactions

Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third-party acquirer in connection with the transaction.

Other Legitimate Sharing Circumstances

In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies Policy

Effective Date: January 1, 2025

Our Services use cookies, which are small text files that are placed on your computer or device by a web server when you access our Services. We may place and access cookies and similar technologies on your computer or device, which are known as “first party cookies.” Cookies may also be placed and accessed by third parties, which are known as “third party cookies” and are described below.

We use cookies and local storage to monitor aggregate usage and web traffic of our Services, customize and improve our Services, help you navigate our Services, deliver content specific to your interests, and deliver advertisements to you.

We also use “web beacons” (also known as web bugs, pixel tags, or clear GIFS) which are small graphics with a unique identifier that may be included on our Services, for example, to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on a user’s hard drive or device, web beacons are typically embedded invisibly on web pages (or in an email).

Types of Cookies

We use the following types of cookies:

The types of cookies described above may be “session cookies” or “persistent cookies.” Session cookies are only stored on your device while you are using the Services and are deleted when you log off from the Services or close your browser. Persistent cookies remain on your device for a period of time after you log off from the Services or close your browser.

Third Party Cookies

Some cookies may be placed by third parties when you use the Services as some third-party service providers that we engage (including third-party advertisers) may place their own cookies on your hard drive or device. These cookies may provide information to those third parties about your browsing habits or may be used for security. Some also help to serve you with advertisements that are more relevant to you.

Google

Our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses non-operational cookies, which are text files placed on your computer or device to help the website or app analyze how visitors use the website or app. The information generated by the cookie about your use of the website or app (including your IP address) will be transmitted to and stored by Google on servers in the United States. At our request, Google will use this information for the purpose of evaluating how the website or app is used, compiling reports on website/app activity for operators, and providing other services relating to website/app activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.

Facebook

Similarly, we use the Facebook pixel service. The Facebook pixel is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions you take on other websites or apps. We use it to make sure our advertising on Facebook is shown to the right people and is effective. When you visit our website or app and take an action, this triggers the pixel, which reports this action to Facebook.

By using our Services, you consent to the processing of data about you by Google and Facebook in the manner and for the purposes set out above.

Cookies Settings

You may decline cookies that are not Strictly Necessary by clicking “Decline” in the cookie banner at the bottom of your screen. Additionally, although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. However, if you don’t accept cookies, you may not be able to access all portions or features of the Services. If you continue to use the Services, you consent to our use of cookies as described in this Cookies Policy.

Do Not Track Signals

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our Website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Cookies and Other Tracking Technologies

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services to work incorrectly or not function at all.

6. THIRD PARTY WEBSITES AND LINKS

We may provide links to third-party websites or other online platforms operated by third parties. If you follow these links to sites or interact with features (e.g., applications offered by third parties or social media widgets) not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy, security, accuracy, completeness, or reliability of information found on these third-party sites.

Information you provide on public or semi-public venues, including third-party social networking platforms like Facebook or X (formerly Twitter), may be viewable by other users without limitation on its use by us or third parties. Our inclusion of such links does not imply endorsement of the content, owners, or operators, except as disclosed.

In using our Services, you may access Third-Party Services owned/operated by others. Any information provided to a Third-Party Service is subject to their privacy policy, not ours. We're not responsible for the content, privacy, or security practices of any Third-Party Service. To protect your information, we recommend reviewing their policies.

7. CHILDREN’S PRIVACY

Children are not allowed to use the Services. We do not seek or knowingly collect any Personal Data from children. If we become aware that we have unknowingly collected information about a child, we will make commercially reasonable efforts to delete such information from our database.

We define children as follows:

If you are the parent or guardian of a child under 13 years of age who has provided us with their Personal Data, you may contact us using the below information to request that it be deleted.

8. DATA SECURITY

Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit.

We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.

9. SPECIFIC DISCLOSURES FOR CALIFORNIA RESIDENTS

California law requires that we make certain disclosures about your data. The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”).

Collection and Use of Personal Data

In the preceding 12 months, we have collected the following categories of Personal Data: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information. To learn more about the specific information we collect, the sources and purposes of such collection, please see Section 2 (“Our Collection and Use of Information”).

Sale or Sharing of Personal Data

We do not sell or share your Personal Data as those terms are defined under the CCPA. We have no actual knowledge of selling or sharing the Personal Data of minors under 16 years of age.

Disclosure of Personal Data for a Business Purpose

In the preceding 12 months, we have disclosed for a business purpose the following categories of Personal Data: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information. To learn more about the disclosure of your Personal Data, please see Section 3 (“Parties We May Share Your Information With”).

Your CCPA Rights

10. YOUR CHOICES

We may send periodic informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.

11. YOUR RIGHTS UNDER THE GDPR

In addition to the other disclosures in this Policy, we make the following express disclosures in accordance with the GDPR and hereby notify you of your rights:

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

12. TRANSFERRING YOUR PERSONAL DATA

We operate our Services throughout the world. Your Personal Data will likely be transferred and stored in a country outside of your home country, including in the USA, for the purposes outlined in this Privacy Policy to the extent permitted by applicable laws. The data protection laws in these countries may not be the same as in your home country.

If we transfer your Personal Data from the UK or the EEA to other countries, including the USA, we ensure that a similar degree of protection is provided to your Personal Data as within the UK or the EEA, as applicable, by ensuring that at least one of the following safeguards is implemented:

13. CALIFORNIA PRIVACY RIGHTS ADDENDUM

A. California Privacy Notice

This CALIFORNIA PRIVACY NOTICE (“Notice”) supplements our Privacy Policy. We have adopted this Notice to comply with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”).

B. Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Data”). The table below indicates whether we have collected certain types of Personal Data in the preceding 12 months:

Category Examples Collected?
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. YES
Personal Data categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Including but not limited to name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. YES
Protected classification characteristics under California or federal law. Age (40 years or older), national origin, citizenship, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information. NO
Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
Biometric Data An individual’s physiological, biological or behavioral characteristics that can be used singly or in combination with each other or with other identifying data, to establish individual identity. Facial recognition technology collects information from your image capture, including biometric data, and shares this information with us, which assists us to verify your ID. YES
Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. YES
Geolocation Data Physical location/movements YES
Audio/visual data Audio, electronic, visual, thermal, olfactory, or similar information YES
Professional or employment related information. Current or past job history or performance evaluations. NO
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
Inferences drawn from other Personal Data. Profile reflecting a person's preferences, characteristics, predispositions, behavior, etc. YES

C. Personal Data Sources

We obtain the categories of Personal Data listed above from the following categories of sources:

  1. Directly from our Users. For example, from when Users register for our services.
  2. Directly and indirectly from activity on our websites and applications. This includes:
    • Usage and log information. For example, service-related, diagnostic and performance information. This includes information about your activity on our websites and applications, log files, and reports.
    • Device and connection information. We collect device-specific information such as hardware model, operating system information, browser information, IP address, etc.
  3. From third parties that interact with us in connection with the services we perform. We may work with third parties, for example, in order to understand, customize, support and market the services we provide and/or to comply with laws.

D. Use of Personal Data

We may use or disclose the Personal Data we collect for one or more of the following business purposes as disclosed in our Privacy Policy:

  1. To provide and manage the services you request;
  2. To improve customer service and our services;
  3. To process payments;
  4. To personalize user experience;
  5. To contact you about our services;
  6. To send important notices to you;
  7. To comply with our legal and regulatory obligations;
  8. To offer alternative dispute resolution services.

E. Other Personal Data

We will not collect additional categories of Personal Data or use the Personal Data we collect for materially different, unrelated, or incompatible purposes without providing you notice.

F. Sharing Personal Data

We may disclose your Personal Data to a third party for business purposes. When we disclose Personal Data for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Data confidential and not use it for any purpose except for performing the contract. We disclose your Personal Data for a business purpose to the following categories of third parties:

We do not sell your Personal Data.

G. Your Rights and Choices

The CCPA provides players Users who are California residents with specific rights regarding their Personal Data. You have the right to access the Personal Data we’ve collected about you during the past 12 months and information about our data collection practices. You also have the right to request that we delete the Personal Data we have collected from you.

H. Exercising Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us as set forth below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Data. If you decide to use an authorized agent, please also include written permission that you have designated that agent to make this request, or proof of the agent’s power of attorney. We may follow up with you to verify your identity before processing your authorized agent’s request. You may also make a verifiable consumer request on behalf of your minor child.

I. Verifiable Consumer Request

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

J. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

K. No Discrimination Policy

We will not discriminate against you for exercising any of your CCPA rights.

L. Updates to Notice

This Notice may be updated from time to time to reflect changes in the Services or how the Services are regulated. We will notify you of changes by posting changes here, or by other appropriate means. Any Personal Data we collect is covered by the Privacy Policy in effect at the time the data is collected. You will be given reasonable notice of any material change.

14. YOUR RIGHTS, CHOICES, AND HOW TO CONTACT US

You may exercise your rights under this Privacy Policy by reviewing the list of options below. Should you have any questions about our privacy practices or this Privacy Policy, please email us at support@flipacoin.com.

To exercise your rights regarding your Personal Data, you can:

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

After you contact us, you may receive an email in order to verify your request. We aim to provide the information or complete the outcome you request within 30 days, or such shorter time period as provided by laws of your jurisdiction.

Data Protection Officer Contact Information: ______________________________________