Privacy Policy

OnPoint Administration LLC (“we,” “us,” or “our”) operates OnPointCasino.com (the “Platform”). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the Platform. By using the Platform, you agree to the practices described in this Policy.

1. Information We Collect

1.1 Information You Provide

• Account registration: full name, email address, date of birth, phone number, residential address
• Identity verification (KYC): government-issued ID document, biometric selfie/facial scan
• Payment information: credit/debit card details (processed and tokenized by our payment processor — we do not store raw card data), bank account information for prize redemptions
• Communications: messages you send to our support team or through the Platform

1.2 Information Collected Automatically

• Device and browser information: IP address, browser type, operating system, device identifiers
• Usage data: pages visited, features used, time spent on the Platform, clickstream data
• Geolocation data: IP-based and browser-based geolocation to verify jurisdictional eligibility
• Cookies and similar technologies: session cookies, persistent cookies, and tracking pixels

1.3 Information from Third Parties

• Identity verification providers (Sumsub): identity verification results, watchlist screening results
• Payment processors: transaction status and fraud signals
• Analytics providers: aggregated usage statistics

2. How We Use Your Information

We use your personal information to:

• Create and manage your account
• Verify your identity and eligibility to use the Platform
• Process Gold Coin purchases and prize redemptions
• Detect and prevent fraud, money laundering, and other prohibited activities
• Comply with legal obligations, including AML/BSA, OFAC, and tax reporting requirements
• Send you transactional communications (account confirmations, redemption notices)
• Send you promotional communications (with your consent, where required)
• Improve the Platform and develop new features
• Respond to customer support inquiries
• Enforce our Terms of Service and other policies

3. Legal Basis for Processing (Where Applicable)

• Contract performance: processing necessary to provide services you have requested
• Legal obligation: processing required by applicable law (AML, tax, sanctions compliance)
• Legitimate interests: fraud prevention, security, Platform improvement
• Consent: marketing communications (you may withdraw consent at any time)

4. How We Share Your Information

We do not sell your personal information. We may share your information with:

• Service providers: payment processors, KYC/identity verification providers (Sumsub), fraud detection services, analytics providers, cloud hosting providers — all bound by contractual data protection obligations
• Law enforcement and regulators: when required by law, court order, or government authority, including FinCEN (SAR filings), OFAC, and tax authorities
• Business transfers: in connection with a merger, acquisition, or sale of assets, subject to confidentiality obligations
• With your consent: for any other purpose with your explicit consent

5. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Platform, remember your preferences, analyze usage, and detect fraud. You can manage cookie preferences through your browser settings; however, disabling certain cookies may affect Platform functionality. We use the following types of cookies:

• Essential cookies: required for Platform operation and security
• Analytics cookies: help us understand how you use the Platform
• Preference cookies: remember your settings and preferences
• Security cookies: support fraud detection and account security

6. Data Retention

We retain your personal information for as long as your account is active and for a period thereafter as required by law. Specifically:

• Account and transaction data: minimum 5 years after account closure (BSA requirement)
• KYC/identity verification records: minimum 5 years
• Marketing preferences and communications: until consent is withdrawn plus 2 years
• Support communications: 3 years

7. Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

• Access: request a copy of the personal information we hold about you
• Correction: request that we correct inaccurate or incomplete information
• Deletion: request deletion of your personal information (subject to legal retention obligations)
• Opt-out of marketing: unsubscribe from promotional communications at any time via the unsubscribe link in emails or by contacting us
• Portability: request your data in a portable, machine-readable format (where applicable)
• Restriction: request that we restrict processing of your data in certain circumstances

To exercise any of these rights, contact us at support@onpointcasino.com. We will respond within 30 days. Note that some requests may be limited by applicable legal obligations (e.g., we are required to retain certain records under the BSA regardless of deletion requests).

8. California Privacy Rights (CCPA/CPRA)

California residents have the following additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to know what personal information is collected, used, and disclosed
• Right to delete personal information (subject to exceptions)
• Right to correct inaccurate personal information
• Right to opt out of the sale or sharing of personal information (we do not sell personal information)
• Right to limit use of sensitive personal information
• Right to non-discrimination for exercising privacy rights

To submit a CCPA/CPRA request, contact us at support@onpointcasino.com with “California Privacy Request” in the subject line.

9. Data Security

We implement industry-standard security measures to protect your personal information, including TLS encryption for data in transit, encryption of sensitive data at rest, access controls and authentication requirements, and regular security assessments. However, no system is completely secure, and we cannot guarantee the absolute security of your information.

10. Children's Privacy

The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 18, we will promptly delete it. If you believe we have inadvertently collected such information, contact us at support@onpointcasino.com.

11. Third-Party Links

The Platform may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by email or prominent notice on the Platform. The “Last Updated” date at the top of this Policy reflects the most recent revision.

13. Contact Us

For privacy-related questions, requests, or concerns, contact our Privacy Team at: support@onpointcasino.com

OnPoint Administration LLC
OnPointCasino.com
Nashville, Tennessee