Privacy Policy

1. Data Controller Identity (Social Point S.L.)

This Privacy Policy applies to the social casino platform "Momentum Casino" operated by Social Point S.L. (NIF: B64983059), registered at Calle de Llacuna 166, Planta 10, 08018 Barcelona, Spain. For the purposes of applicable data protection legislation (including the GDPR), Social Point S.L. acts as the Data Controller determining the purposes and means of processing your personal data when you access couldbeyourmoment.com.

2. Types of Personal Data Collected

We process only the minimum data necessary to operate our free-to-play social casino environment. When you register an account, we collect your email address, chosen username, and an encrypted password hash. We do not process real-money payment data, credit card information, or bank details, as our platform is entirely simulated and operates without financial deposits.

3. Gameplay & Interaction Data

As you interact with our mini-games (e.g., Avalanche Reels, Summit Roulette), we record gameplay events to maintain your virtual progress. This includes your current Apex Crystals (APC) balance, your unlock status for specific world locations (such as Base Camp Echo), achievement milestones, and session duration. This data is tied to your account profile to ensure continuity of your simulated casino experience across sessions.

4. Device & Technical Data

To ensure optimal rendering of our visual assets and animations, and to detect fraudulent automated activity (bots), we automatically collect certain technical parameters upon your connection. This encompasses your IP address, browser type and version, viewport dimensions, operating system, and general geographic location (derived at the country/region level) necessary for routing and compliance checks.

5. Purpose of Data Processing

The primary purposes for processing the aforementioned data are: providing access to the free social casino features; maintaining and updating your virtual progression and APC balance; securing the platform against unauthorized access or abuse; analyzing aggregated gameplay trends to improve mechanics and server stability; and serving contextually relevant or targeted advertisements which sustain our free-to-play business model.

6. Legal Basis for Processing

We rely on several legal bases for processing operations: (a) Performance of a Contract, when maintaining your account and gameplay state; (b) Legitimate Interests, for network security, fraud prevention, and general platform optimization; (c) Consent, specifically regarding the deployment of non-essential tracking cookies and the delivery of personalized advertisements through our monetization partners.

7. Monetization & Analytics Tracking

Momentum Casino is funded exclusively through advertising. We utilize third-party analytics and ad-serving networks to display banners, interstitial videos, and optional rewarded ads. With your explicit consent, these partners may collect device identifiers and interaction data to measure campaign effectiveness and tailor ad content to your inferred interests. You may withdraw consent for personalized ads at any time via your account settings or cookie preferences.

8. Data Sharing & Third Parties

Social Point S.L. does not sell your personal data to data brokers. We share data strictly with vetted service providers who act as Data Processors on our behalf. These include cloud hosting infrastructure providers (to store your profile and gameplay state), customer support ticketing systems, and our approved advertising network partners (subject to consent). All processors are bound by strict confidentiality and data processing agreements.

9. International Data Transfers

While our primary servers are located within the European Economic Area (EEA), some of our technical infrastructure or advertising partners may process data outside the EEA. In such instances, we ensure adequate protection mechanisms are in place, relying on Standard Contractual Clauses (SCCs) approved by the European Commission or ensuring the destination country holds an adequacy decision.

10. Data Retention Periods

We retain your account data and gameplay history for as long as your account remains active. If your account is inactive for a continuous period of 24 months, or if you request account deletion, we will permanently anonymize or delete your personal identifying data. Technical logs used for security monitoring are typically purged after 90 days unless required longer for active fraud investigations.

11. User Rights (Access, Deletion, Rectification)

Under the GDPR and equivalent data protection frameworks, you possess the right to: request access to a copy of your personal data; request rectification of inaccurate data; request the erasure of your data (Right to be Forgotten); restrict or object to certain processing activities; and request data portability. To exercise these rights, contact our Data Protection Officer via support@couldbeyourmoment.com.

12. Security Measures

We implement robust technical and organizational measures to protect your data against unauthorized access, alteration, disclosure, or destruction. This includes utilizing TLS/SSL encryption for data in transit, cryptographic hashing for passwords, role-based access controls for our staff, and regular security audits of our server environments.

13. Changes to this Privacy Policy

Social Point S.L. reserves the right to amend this Privacy Policy periodically to reflect changes in our platform mechanics, monetization strategies, or legal obligations. When significant modifications occur, we will notify registered users via an in-game alert or via the email address associated with their account. Continued use of Momentum Casino following such updates constitutes acknowledgment of the revised terms.