How We Handle Your Data
At CLSMART PRIVATE LIMITED, we built Gold Dragon: Spin & Win with your privacy in mind. This document explains our practices in plain, straightforward language.
Last updated: 2026-04-09. If you have questions about this policy, email carehub@relaxingsailingtrip.com.
Gold Dragon: Spin & Win is a mobile game. By downloading or using it, you agree to the practices described in this policy.
We believe data minimization is good practice. We only collect information that helps us deliver a great experience in Gold Dragon: Spin & Win.
You must be at least 13 years old to use this app.
This policy does not apply to third-party services linked from the app. Always review their privacy policies separately.
Questions or concerns about your privacy? Our team is available at our support team.
Data We Gather
The following describes the categories of personal information that CLSMART PRIVATE LIMITED may collect through Gold Dragon: Spin & Win.
Automatically Collected Data
When you use Gold Dragon: Spin & Win, our servers and integrated SDKs automatically collect:
- Device information (model, OS, screen resolution)
- Pseudonymous device identifiers for analytics
- Gameplay telemetry (events, session timing, feature usage)
- App performance and crash data
- Approximate geographic region derived from IP address
Data You Give Us
If you reach out to our support team, we collect your email address and the content of your messages. We may also collect a username if you create one.
What We Don't Collect:
We do not collect your precise location, contacts, camera images, microphone recordings, financial account information, or health data through Gold Dragon: Spin & Win.
Platform Data: If you connect via Apple Game Center or Google Play Games, we may receive your platform username and game-related data as permitted by those platforms.
Purchase Information: We do not collect or store payment card or financial account details. All transactions are processed by the App Store or Google Play, and we receive only a transaction confirmation.
Data collection questions? Email carehub@relaxingsailingtrip.com — we respond within 30 days.
Why We Use Your Data
Your data is used responsibly by CLSMART PRIVATE LIMITED to power Gold Dragon: Spin & Win and enhance your experience.
Operating the App
Core game functionality requires us to process certain data: delivering game content, saving your progress, processing transactions you initiate, and responding to your support requests.
To Improve the Game
- Analyze gameplay data to understand what players enjoy
- Identify and fix bugs and performance issues
- Test new features before broad release
- Make data-driven design decisions
For Safety and Fairness
- Detect cheating or fraudulent activity
- Protect players from harassment or abuse
- Maintain the integrity of game systems
To Communicate With You
- Respond to your support messages
- Send important service notifications
- Notify you of significant policy updates
Important: CLSMART PRIVATE LIMITED does not sell, rent, or trade your personal information to third parties.
Where required by law (including GDPR), our legal bases for processing include: contract performance, legitimate interests, and legal compliance.
For questions about data use, email our support team — we respond within 30 days.
Third-Party Data Sharing
We share data with trusted third parties only to the extent required to run Gold Dragon: Spin & Win effectively, safely, and legally.
Service Providers
We use third-party vendors to help operate Gold Dragon: Spin & Win, including cloud hosting, analytics, and customer support tools. These vendors may access your data only to perform services for us — they cannot use it for their own purposes.
Legal Obligations
We may disclose your information if required by law, court order, or government regulation, or to protect the rights and safety of CLSMART PRIVATE LIMITED, our players, or others.
Corporate Transactions: In the event of a company merger, acquisition, or restructuring, your information may transfer to a new entity — which will be bound to honor this Privacy Policy.
We do not sell your data. We never sell, rent, or auction personal information to advertisers, data brokers, or any other third party.
We may share aggregated, anonymized statistical data with partners or in public reports. This data cannot identify you individually.
Contact us at our support team with any questions.
Analytics and Tracking
Gold Dragon: Spin & Win integrates analytics tools that use device-level identifiers. Here's a transparent explanation of what we use.
Integrated Analytics: Our analytics providers receive device-level data and gameplay events in pseudonymized form. This helps us understand how players experience Gold Dragon: Spin & Win without identifying individuals.
Advertising ID (IDFA/GAID): We may use your device's resettable advertising identifier for app attribution. This is a device-level ID that does not reveal your identity.
Managing Tracking: You can limit or reset tracking identifiers in your device's privacy settings. On iOS, this requires approving tracking via the system prompt. On Android, visit your Google Account settings.
Crash Reporting: We use crash analytics tools that automatically collect error logs when the app crashes. This data is used solely to identify and fix technical issues.
Contact us at our support team for tracking-related inquiries.
COPPA Compliance
We design Gold Dragon: Spin & Win with child safety in mind. Our data practices comply with COPPA and GDPR-K where applicable.
Children Under 13: We do not intentionally collect personal information from children under 13 (or the applicable age in your country) without parental or guardian consent.
What Parents Can Do:
- Ask us what data we have collected about their child
- Request that we delete it
- Refuse further collection
To make a request, contact our support team with subject line 'Child Privacy Request.'
Child-Safe Design: Gold Dragon: Spin & Win is designed to be age-appropriate. We minimize data collection, avoid behavioral advertising for children, and disable or restrict social sharing features for younger users.
If you believe a child has provided us personal information without appropriate consent, please contact our support team immediately. We will investigate and take corrective action.
We're committed to child safety. Contact our support team with any concerns.
Mixed Audience Notice
We work with advertising partners to show ads in our app. We do not use personal data from users under 13 for targeted or behavioral advertising.
Privacy Rights and Choices
You're in control of your personal data. This section outlines the rights available to you as a user of Gold Dragon: Spin & Win.
Right to Know: You can ask us what personal information we have collected about you.
Right to Correct: You can ask us to fix any inaccuracies.
Right to Delete: You can ask us to delete your personal information.
Right to Object: You can object to certain types of processing.
Regional Rights: California residents have rights under CCPA. EU and UK residents have rights under GDPR. We honor all applicable rights regardless of your location.
Submitting a Request: Send a rights request to our support team. We may ask for identity verification and will respond within 30 calendar days.
Withdraw Consent: Where our processing is based on your consent, you may withdraw it at any time. This doesn't affect the lawfulness of processing before your withdrawal.
Privacy matters. Contact our support team to exercise any right described here.
Our Data Retention Policy
Data minimization includes keeping data only for appropriate periods. Here's how long CLSMART PRIVATE LIMITED holds different categories of your information.
Account data: Retained while active, deleted within 30 days of your request. Analytics: 90-day rolling window. Support logs: 12 months. Purchase records: Per legal requirements (up to 7 years).
Account Dormancy: Accounts inactive for more than 2 years may be subject to data minimization. We'll notify you before taking any action on a dormant account.
Requesting Deletion
You can request deletion of your data at any time by contacting our support team. We process deletion requests within 30 days.
Legal Holds: We may defer deletion where data is subject to an active legal obligation, regulatory requirement, or dispute resolution process.
To request deletion or ask about retention, email our support team.
Data Security
Protecting your personal information is a core responsibility at CLSMART PRIVATE LIMITED. Here's how we secure data in Gold Dragon: Spin & Win.
We protect your data with TLS encryption in transit and encryption at rest. Our cloud infrastructure uses role-based access controls so only authorized staff can access your information.
Operational Security: We limit data access to staff who need it for their role, conduct background checks for relevant positions, and maintain data processing agreements with all third-party vendors.
An Honest Note
No system is perfectly secure. While we maintain strong protections, we cannot guarantee absolute security of data transmitted over the internet. We encourage you to protect your account credentials and keep your device software updated.
Breach Notification: If a data breach occurs that is likely to harm your rights, we will notify you without undue delay and, where legally required, notify the relevant supervisory authority within 72 hours.
For data security inquiries, write to our support team.
Third-Party Tools and Services
Gold Dragon: Spin & Win integrates the following third-party tools to support app functionality, performance measurement, and ad delivery infrastructure. These tools operate under their own privacy policies.
- Firebase Analytics — Gameplay analytics and user behavior tracking: Privacy Policy
- Firebase Crashlytics — Crash reporting and app stability monitoring: Privacy Policy
- Google Play Services — Android platform services — leaderboards and achievements: Privacy Policy
- Adjust — Mobile attribution and ad revenue tracking: Privacy Policy
- AppLovin MAX SDK — Ad mediation layer — loads and displays ads from all integrated ad networks: Privacy Policy
- Android: Settings → Google → Ads → Opt out of Ads Personalization
Advertising Partners
Gold Dragon: Spin & Win is free to play and supported by in-app advertising. The following ad networks deliver advertisements within the app. Each network may collect device identifiers and interaction data to serve and measure ads.
- Google AdMob: Privacy Policy
- AppLovin / MAX: Privacy Policy
We work with advertising partners to show ads in our app. We do not use personal data from users under 13 for targeted or behavioral advertising.
To opt out of interest-based advertising, visit Your Ad Choices or adjust your device's advertising settings.
Transferring Data Internationally
CLSMART PRIVATE LIMITED operates globally. Your data may be processed in countries outside where you live, including the United States or other regions.
Our servers and third-party service providers are located in various countries, including the United States and the EU. Your data may be processed in any of these locations.
Legal Safeguards for EU/UK Transfers: For transfers of personal data from the EEA or UK to third countries, CLSMART PRIVATE LIMITED relies on Standard Contractual Clauses (EU Commission Decision 2021/914) and, where applicable, UK IDTAs.
No matter where we process your data, we apply the same protections described in this Privacy Policy. Location doesn't change our commitment to your privacy.
Adequacy Decisions: Some countries we transfer data to have been recognized by the European Commission as providing adequate protection (e.g., UK, Canada for commercial organizations, Japan).
Reach us at our support team for more on global data practices.
Privacy Policy Amendments
When we make changes to this Privacy Policy, we want you to know about them. Here's our update and notification process.
We distinguish between material and minor changes. Material changes (new data practices, new data types, new third-party sharing) get prominent in-app notices. Minor corrections don't require separate notification.
Version Tracking: The effective date at the top of this page shows exactly when the policy was last updated. Previous versions are archived and available on request.
Disagreement with Changes: You're always free to stop using Gold Dragon: Spin & Win if you don't agree with updates. Contact our support team to request account deletion.
To request a copy of a previous version of this Privacy Policy, email our support team.
Policy update questions: our support team.
Our Privacy Team
Your privacy matters to us. Don't hesitate to reach out with any questions, requests, or concerns.
CLSMART PRIVATE LIMITED
Privacy Email: our support team
Support Email: our support team
When to Expect a Reply: Acknowledgment within 5 business days, full response within 30 days. We always keep you informed of progress.
When submitting a rights request, please include: the specific right you're asserting, your account identifier if available, and your jurisdiction. This helps us respond faster.
Supervisory Authority: EU/UK residents have the right to lodge a complaint with their local data protection authority. EU authorities: edpb.europa.eu. UK: ico.org.uk.
We're committed to protecting your privacy. Contact our support team with any concerns.