Scarlet Reels Privacy Policy

1. Who We Are

A.D.T. INTERACTIVE LTD is an Israeli limited company, company number 517321444, with its registered office at 5 Yitzhak Graziani (Ziko) Street, Tel Aviv-Yafo, Israel. For privacy questions or to exercise your rights, contact legal@adult.gg.

2. Scope and Age Restriction

Scarlet Reels is an adults-only social casino game intended solely for people aged 18 or older. It does not offer real-money gambling, cash prizes, or cash-out of virtual coins.

The Service is not directed to children. We do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has used the Service, contact us so that we can investigate and delete the data as appropriate.

3. Personal Data We Collect

Account and authentication data

• Username, internal user ID, and visitor or anonymous identifier.
• A securely hashed representation of your password. We do not store your password in readable form.
• Authentication session identifiers, login and logout times, account-creation date, account status, and tutorial status.

Scarlet Reels does not currently require an email address for ordinary registration. If you contact support, or if we offer an email-based recovery feature, we may collect the email address and related recovery records you provide.

Gameplay and virtual-economy data

• Selected characters, gameplay sessions, spins, virtual wagers, results, reel stops, wins, progression, and feature state.
• Virtual-coin balances, ledger entries, grants, adjustments, purchases, refunds, and chargebacks.
• Game configuration and audit information needed to verify gameplay integrity, including the applicable return-to-player profile and timestamps.

Purchase data

• The virtual-coin package selected, price, currency, transaction status, and timestamps.
• PayPal, Onside, or other payment-provider order and transaction identifiers, plus refund, dispute, chargeback, reconciliation, and fraud-prevention records.

Payment providers process your payment credentials. We do not receive or store your complete card number, bank-account credentials, or PayPal password.

Device, network, usage, and communications data

• IP address, browser or app type, operating system, device type, language, time zone, and approximate location inferred from IP.
• Session and local-storage identifiers, referring URL, campaign parameters, app opens, interactions, gameplay events, and feature usage.
• Server logs, request timestamps, errors, diagnostics, and security events.
• Information in support messages, your contact details, and the records needed to respond.

4. How We Use Personal Data

We use personal data to:

• Create and secure accounts; authenticate users; and provide gameplay, progression, balances, and purchases under our contract with you.
• Process payments, refunds, disputes, and required transaction reporting under our contract and legal obligations.
• Protect the Service, prevent fraud and abuse, enforce our Terms, and maintain auditable game and wallet records based on our legitimate interests and applicable legal obligations.
• Operate, troubleshoot, measure, and improve Scarlet Reels based on our legitimate interests or consent where local law requires it.
• Respond to users and comply with tax, accounting, regulatory, law-enforcement, and legal-claims requirements.

Where we rely on consent, you may withdraw it at any time without affecting processing that occurred before withdrawal. Where we rely on legitimate interests, we consider the impact on your rights and use the data only where those interests are not overridden by your rights.

5. Analytics and Similar Technologies

Scarlet Reels uses local storage and similar technologies to maintain sessions, remember necessary state, support security, and measure use of the Service.

We use PostHog for product analytics. Analytics may include an anonymous or account-linked identifier, device and browser information, app sessions, gameplay interactions, purchases, errors, and campaign or referring information.

Where law requires consent for non-essential analytics, we request it before enabling that analytics and provide a way to withdraw it. We do not sell personal data or use Scarlet Reels data for third-party targeted advertising or tracking across other companies' apps and websites.

6. How We Share Personal Data

We may share personal data with:

• Hosting and infrastructure providers, including Vercel and MongoDB Atlas.
• Analytics providers, including PostHog.
• Media-delivery providers, including Bunny.net and Cloudinary.
• Payment and commerce providers, including PayPal and, where relevant, Onside.
• Onside as the distribution marketplace for distribution, notarization, safety, support, compliance, and marketplace functions.
• Professional advisers, regulators, courts, and law-enforcement agencies where reasonably necessary or legally required.
• Parties to a merger, financing, acquisition, reorganization, insolvency, or sale, subject to appropriate confidentiality protections.

Service providers may process data only for contracted services and subject to applicable data-protection obligations. Some third parties, such as payment providers, may also act as independent controllers under their own privacy policies.

7. International Transfers

We are based in Israel and use providers that may process data in Israel, the European Economic Area, the United States, and other countries. Where required, we use recognized safeguards such as adequacy decisions, the European Commission's Standard Contractual Clauses, and supplementary security measures. Contact us for more information about relevant safeguards.

8. Retention

We retain personal data only as long as reasonably necessary to provide the Service, maintain account and wallet integrity, resolve disputes, prevent fraud, and meet legal duties.

• Authentication session tokens currently expire after 30 days.
• Active gameplay session state generally expires after four hours, although gameplay and ledger records may be retained longer for integrity, fraud prevention, and legal claims.
• Account and progression data are retained while the account is active and thereafter only as needed to complete deletion, protect security, resolve disputes, and satisfy legal duties.
• Purchase and accounting records are retained for periods required by applicable tax, accounting, payment, and legal rules.
• Analytics, diagnostics, and backups are deleted or de-identified under our configured retention and backup lifecycles when no longer needed.

9. Your Choices and Rights

Depending on where you live, you may have rights to access, correct, delete, restrict, object to, or obtain a portable copy of personal data, withdraw consent, and complain to a data-protection authority.

To exercise a right or request account deletion, email legal@adult.gg. We may verify your identity first. A request may be limited where we must retain transaction, fraud-prevention, security, or legal-claims records.

Residents of Israel may also have rights under Israel's Protection of Privacy Law and related regulations. Residents of the European Economic Area or United Kingdom may complain to the authority where they live or work, or where they believe an infringement occurred.

10. Security

We use administrative, technical, and organizational safeguards designed to protect personal data, including access controls, password hashing, session-token protection, transport encryption, database controls, logging, and monitoring. No system is completely secure, and we cannot guarantee absolute security.

11. Automated Decisions

We may use automated rules to detect suspicious transactions, account abuse, or gameplay manipulation. These rules may temporarily block an action for review. We do not use personal data for solely automated decisions producing legal or similarly significant effects unless permitted by law and accompanied by required safeguards.

12. Third-Party Services

The Service may link to or interact with third-party services, including Onside and PayPal. Their processing is governed by their own privacy notices.

13. Changes to This Policy

We may update this Policy to reflect changes to Scarlet Reels, our providers, or legal requirements. We will post the updated Policy with a new effective date and provide additional notice or request consent where required.

14. Contact Us

A.D.T. INTERACTIVE LTD
Company number 517321444
5 Yitzhak Graziani (Ziko) Street
Tel Aviv-Yafo, Israel
legal@adult.gg