PRIVACY POLICY FOR LOS TR3S REYES

Last Updated: November 11, 2025

Operated by

Los Tres Reyes LLC

2604 B El Camino Real Suite # 373

Carlsbad, CA 92008

United States

INTRODUCTION

Welcome to Los Tr3s Reyes, operated by Los Tres Reyes LLC (“Company,” “we,” “our,” or “us”).

We value your privacy and are committed to protecting the personal information you share with

us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information

when you use the Los Tr3s Reyes mobile application (“App”).

By accessing or using the App, you acknowledge that you have read, understood, and agree to

the terms of this Privacy Policy. If you do not agree, please discontinue use of the App

immediately.

This Privacy Policy is intended to comply with:

- California Consumer Privacy Act (CCPA/CPRA)

- EU General Data Protection Regulation (GDPR)

- UK GDPR

- COPPA (Children’s Online Privacy Protection Act)

- Applicable U.S. Federal and State laws

- Apple App Store Review Guidelines

- Google Play Data Safety Requirements

This Privacy Policy applies solely to the Los Tr3s Reyes app and not to any other apps or

services provided by Los Tres Reyes LLC.

1. INFORMATION WE COLLECT

We may collect the following categories of information when you use the Los Tr3s Reyes App:

1.1 Personal Identifiers

We may collect personal identifiers such as:

- Email address

- Username

- Phone number

- Password (encrypted and never stored in plain text)

- Profile picture (if uploaded voluntarily)

- Country of origin

- State or province

- City

- Full mailing address

These identifiers are used to create and maintain your account, verify identity when needed,

and support the App’s functionality.

1.2 Sensitive Personal Information (KYC Data)

If identity verification becomes necessary (age verification, fraud prevention, or security), we

may collect:

- Government-issued ID

- Driver’s license

- Passport

- National ID card

- Proof of address

- Selfie verification

- Any official government-issued document provided voluntarily

KYC documents are treated as Highly Sensitive Data, stored securely, and never shared except

as necessary to verify identity or prevent fraud.

1.3 Payment Information (Non-Financial)

Los Tres Reyes LLC does not collect or store full payment card details.

Purchases of Virtual Coins are processed through:

- Authorize.Net / Paysafe

- PayPal

- Google Pay

- Apple Pay

These payment providers may collect:

- Cardholder name

- Billing address

- Last 4 digits of card

- Wallet or device payment data

We receive only:

- Payment confirmation

- Transaction ID

- Email associated with the payment

- User identifier (for fraud prevention and recordkeeping)

Financial data is handled solely by the secure payment provider.

1.4 Device and Usage Information

We may collect:

- Device type

- Operating system version

- App version

- Device settings

- Crash logs

- Error diagnostics

- IP address (if necessary for security)

- General usage behavior

This information helps us maintain stability, improve performance, and fix issues.

1.5 User-Generated Content (UGC)

The App allows certain UGC such as:

- Profile photos

We do not offer chat, messaging, or open content sharing. UGC is optional, and you may

remove it at any time.

1.6 Support Communications

When you contact support, we may collect:

- Email address

- Support messages

- Attachments you choose to send (e.g., screenshots)

- Device and app information relevant to resolving your issue

1.7 In-App Purchase Information

We collect purchase history related to:

- Virtual Coin transactions

- Promotional packages

- Bonus bundles

Important: Virtual Coins may be converted into Chips for gameplay only. Virtual Coins and Chips

have no real-world monetary value, cannot be exchanged for cash, and cannot be withdrawn.

2. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

2.1 To Operate and Maintain the App

Including:

- Account creation and management

- Gameplay functionality

- Virtual Coin and Chip transactions

- Ensuring App stability and compatibility

2.2 To Improve User Experience

We analyze usage data to:

- Enhance features

- Improve performance

- Fix bugs

- Personalize content (where applicable)

2.3 To Process Purchases

We use your information to:

- Facilitate Virtual Coin purchases

- Provide receipts

- Verify completed transactions

- Prevent fraudulent activity

2.4 To Verify Identity (When Necessary)

KYC documents may be used to:

- Confirm age (18+ requirement)

- Prevent fraud or misuse

- Protect account integrity

2.5 For Security and Compliance

We use information to:

- Detect and prevent fraud

- Enforce our Terms of Service

- Investigate security incidents

- Comply with legal obligations

2.6 To Communicate With You

We may send:

- Transaction-related notifications

- Support responses

- Account alerts

- Legal or policy updates

- Optional promotional messages (you may opt out)

3. LEGAL BASES FOR PROCESSING (GDPR)

For users located in the EU, EEA, or UK, our legal bases include:

- Contractual necessity (operating the App)

- Legitimate interest (fraud prevention, analytics, app improvement)

- Consent (profile photos, optional features)

- Legal obligation (age verification, compliance)

4. HOW WE SHARE YOUR INFORMATION

We do not sell or share your personal information for advertising or monetary gain.

We may share limited information only with:

- Payment processors

- Analytics providers

- Service providers assisting in app performance

- Identity verification partners (only when required)

- Legal authorities (only when required by law)

We never share full payment card information.

5. HOW WE RETAIN YOUR INFORMATION

Retention practices follow:

- Business needs

- Legal requirements

- Fraud prevention requirements

KYC documents are stored only as long as necessary, then securely deleted or archived.

6. DISCLOSURE OF YOUR INFORMATION

We do not sell, trade, or rent personal information. We disclose information only when

necessary to operate the App, comply with the law, or protect users.

We may disclose information to:

- Payment processors (Authorize.Net, PayPal, Google Pay, Apple Pay)

- Cloud hosting and data storage providers

- Analytics providers

- Identity verification partners (if needed)

- Customer support tools

- Legal authorities when required

We do NOT ever disclose:

- Full credit card numbers

- Full wallet credentials

- CVV codes

- Bank account details

7. DATA RETENTION

We retain personal information only as long as necessary for legitimate business, legal, and

security purposes.

- Account data: kept as long as your account is active.

- Payment confirmation data: kept only as required for receipts, fraud prevention, and legal

obligations.

- KYC documents: stored securely and deleted once no longer needed.

- Crash logs and analytics: retained only as required for technical improvement and

performance.

- Support communications: retained only as necessary for resolving issues and safeguarding

your account.

8. DATA SECURITY

We implement multiple protections:

Technical safeguards:

- Encryption in transit (HTTPS/TLS)

- Encryption at rest

- Secure cloud infrastructure

- Firewalls and access controls

- Regular system updates

Administrative safeguards:

- Employee confidentiality agreements

- Limited access permissions

- Data protection training

- Vendor risk assessments

Physical safeguards:

- Secure data centers

- Restricted access environments

Payment security:

All sensitive financial data is handled only by secure payment processors compliant with PCI

DSS standards.

KYC security:

KYC documents are stored in encrypted form with extremely restricted access.

9. YOUR PRIVACY RIGHTS

Users worldwide have rights to:

- Access their information

- Correct inaccurate information

- Delete their account

- Withdraw consent

- Restrict certain processing

Additional rights for EU/UK users:

- Data portability

- Right to object

- Right to lodge a complaint

Additional rights for California residents:

- Right to know

- Right to access

- Right to delete

- Right to correct

- Right to limit use of Sensitive Information

- Right to non-discrimination

10. INTERNATIONAL DATA TRANSFERS

Your information may be processed in:

- The United States

- Other countries where service providers operate

We use:

- Standard Contractual Clauses

- UK IDTA

- Adequacy decisions

- Encryption and access controls

All transfers comply with GDPR/UK GDPR and applicable privacy laws.

11. CHILDREN’S PRIVACY

The App is strictly for adults 18+ only.

We do NOT:

- Collect data from children

- Allow minors to create accounts

- Market to minors

We comply with COPPA and international child privacy rules. Any data discovered to belong to a

minor will be deleted immediately.

12. LINKS TO THIRD-PARTY SERVICES

The App may contain links to external services such as:

- PayPal

- Google Pay

- Apple Pay

- Authorize.Net

- Support tools

- Social media

These services have their own privacy policies. We are not responsible for their practices.

Please review their policies before providing personal information.

13. YOUR CHOICES AND OPT-OUT OPTIONS

Users may:

- Update account information (email, phone, username, password, and profile photo).

- Opt out of marketing and promotional emails (transactional emails remain).

- Opt out of analytics where device settings or regional laws allow.

- Opt out of advertising (Android only) using Google device settings.

- Remove UGC (profile photos can be changed or deleted).

- Decline KYC verification, unless required for fraud/security.

- Delete their account by emailing us or using the in-app support system.

14. DATA STORAGE & STORAGE PRACTICES

Your data may be stored in:

- Secure U.S. cloud servers

- Compliant international data centers used by service providers

We use:

- Encryption at rest and in transit

- Redundant backups

- Data minimization

- Segregated storage for sensitive data

Payment record storage is handled by third parties only.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy when:

- Features change

- Laws change

- Security improvements are made

We notify users via:

- In-app messages

- Email (if applicable)

- Policy date updates

Continued use of the App after updates means you accept the changes.

16. CONTACT INFORMATION

If you have questions or wish to exercise your rights, contact us:

Privacy Email:

[email protected]

Support Email:

[email protected]

Mailing Address:

Los Tres Reyes LLC

2604 B El Camino Real Suite # 373

Carlsbad, CA 92008

United States

In-App Support:

For California residents, in-app support may be required for identity verification. We respond

within legally required timeframes (30–45 days depending on jurisdiction).

CALIFORNIA RESIDENT PRIVACY NOTICE

(CCPA/CPRA Compliance — Supplemental Section)

This California Privacy Notice supplements all information contained in this Privacy Policy and

applies solely to residents of the State of California. We provide this notice to comply with the

California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020

(CPRA).

If you reside in California, you are entitled to the following disclosures and rights.

1. No Selling or Sharing of Personal Information

In accordance with California Civil Code sections 1798.140(ad)(2) and 1798.140(ah)(2):

- We do not sell personal information.

- We do not share personal information for cross-context behavioral advertising.

- We do not exchange personal information in return for monetary or any other valuable

consideration.

2. Categories of Personal Information Collected

In accordance with section 1798.130(a)(5):

Your rights under California law are listed in Section 9 of this Privacy Policy.

Categories collected in the last 12 months are detailed in Section 2 of this Privacy Policy,

including:

- Identifiers (email, phone, username)

- Payment confirmation information

- Device data

- Usage data

- KYC documents (if submitted)

- Support communications

- In-app purchase history (Virtual Coins to Chips)

We collect only what is necessary to operate and secure the App.

3. How to Submit CCPA/CPRA Requests

In accordance with sections 1798.130(a)(1)(A) and 1798.130(a)(1)(B):

California residents may contact us via:

- [email protected]

- In-app support system (recommended for verification)

If the App has its own external website, that site may also be used for submitting requests.

You may request:

- Access to your personal information

- Correction of inaccurate data

- Deletion of your information

- Disclosure of categories collected

- Limitation of sensitive personal information

- Confirmation of disclosures to third parties

We will not discriminate against users who exercise their California privacy rights.

4. Verification of Requests

In accordance with section 1798.130(a)(2)(A):

We must verify your identity before responding to any CCPA/CPRA request.

To prevent unauthorized access:

- Requests must be submitted from the same account or associated email. We will not collect

additional unnecessary information.

- If you contact us from a different email, we will require verification through the in-app support

system.

This ensures a reasonably high degree of certainty that the request originates from the rightful

account holder.

5. Authorized Agents

You may designate an authorized agent to make a request on your behalf.

To do so:

- Provide the agent with written, signed permission.

- Verify your identity directly with us.

- Confirm to us that the agent is authorized.

We may deny an agent’s request if:

- They cannot prove legal authorization.

- You do not verify your identity.

- The request appears fraudulent or unlawful.

END OF CALIFORNIA NOTICE

17. CONTACT, INTERPRETATION & GOVERNING LAW

If there is any conflict between translated versions of this Privacy Policy, the English version

shall control.

This Privacy Policy is governed by the laws of the State of California, without regard to

conflict-of-law principles.

For any questions regarding this Policy, please contact:

[email protected]

[email protected]

Los Tres Reyes LLC, 2604 B El Camino Real Suite # 373, Carlsbad, CA 92008, United States

LAST UPDATED:

November 11, 2025