Privacy Policy

Last Updated: January 29, 2026
Version: 1.0

Welcome to the Privacy Policy (the "Policy") of Acp Host and its related, affiliated or subsidiary companies (collectively, the "Company," "Sponsor," "we," "our," or "us").

The purpose of this Policy is to inform you how we collect, use, and share your information when you provide such information or use our website, available at https://acphostdev.com/ (the "Site"), as well as other related webpages, mobile applications, products, services or content accessible through the Site (collectively, the "Services").

When we refer to "you" or "your" in this Policy, we mean any individual who interacts with or uses our Services. By using the Services, you represent that you understand and agree to this Policy, and consent to the collection, use, and sharing of information as described herein. If you do not consent to our practices, you can choose not to use the Services.

Privacy Policy Changes. We reserve the right to modify this Policy at any time. All changes are effective immediately upon posting. Material changes will be communicated to you by email. Your continued use of the Services after changes are posted constitutes your acknowledgement of the modified Policy and agreement to abide and be bound by it. The effective date of this Policy is posted at the top of this page. It is important that you periodically check for changes.

1. INFORMATION WE COLLECT

1.1 Information You Voluntarily Provide

• We may collect information about you when you interact with our Services, including information that you voluntarily provide when you:
  • Register and create an account;
  • Add or update your account information;
  • Participate in gameplay or promotions;
  • Make purchases or transactions;
  • Submit a Contact Us inquiry;
  • Undergo identity verification (KYC);
  • Otherwise interact with the Services.

The types of information we may collect include:

• a) Profile Data: email address, password, user settings, and user ID.
• b) Personal Identifiers: first and last name, date of birth, age, gender, and VIP tier.
• c) Contact Information: billing address, residential address, email address, mailing address, and mobile phone number.
• d) Financial Information: credit or debit card information, bank account information, payment details, or other payment information.
• e) Commercial Data: purchase amounts, transaction records, redemption history, and other details of products and services you have acquired from us.
• f) Gameplay Data: gameplay history, player statistics, in-app interactions, and promotional participation records.
• g) Identity Verification (KYC) Data: government-issued identification documents (such as passport, driver's license, or national ID card), selfie photographs, facial recognition data (biometric information), proof of address documents, and payment source verification documents. This information is collected as part of our Know Your Customer (KYC) procedures to verify your identity, age, and eligibility.
• h) Marketing and Communications Information: marketing preferences, consent to receiving marketing from us and third parties, communication preferences, and promotional request history.

1.2 Information We Collect When You Use the Services

As you navigate the Site and/or use the Services, we may collect certain information automatically using various technologies:

• a) Device and Technical Information: internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, time zone setting, language preferences, device type and unique device identifiers, and other technical information from the devices you use to access our Services.
• b) Usage Data: information about how you use our Site and Services, including statistics regarding gameplay activity, page views, clickstream data, session duration, and other interaction data.
• c) Location Information: country, state, or region derived from your IP address, device settings, or geolocation services. This data is used for eligibility verification, legal compliance, regional service availability determination, and geo-fencing to enforce territorial restrictions. We may use third-party geolocation service providers to verify your location.

1.3 Cookies and Tracking Technologies

We and our service providers use cookies, pixels, and other tracking technologies to recognize your browser or device and to capture and remember certain information about your activities on our Services.

• a) Cookies: A cookie is a small text file saved on your web browser when you visit a website. You can view and delete existing cookies through your browser settings. If you do not want to store cookies, you can configure your browser to refuse cookies or alert you when cookies are being sent. However, some parts of the Services may not function properly if you choose not to accept cookies.
• b) Pixel Tags (Clear GIFs): These are tiny graphics with a unique identifier, similar in function to cookies, which allow us to monitor the use of our Services and gauge the effectiveness of our communications and marketing campaigns. You cannot decline pixel tags; however, if you turn off cookies, the pixel tag will simply detect an anonymous visit.
• c) While using the Services, you are not permitted to use VPN or other tools to mask your location.

1.4 Third-Party SDKs and Analytics Services

Our Services integrate third-party software development kits (SDKs) and analytics tools that may collect information from your device. Below is a list of the third-party SDKs currently integrated into our Services:

• a) Google Analytics
  • Provider: Google LLC
  • Data Collected: IP address, device information, usage data (page views, session duration, pages visited, referring/exit pages), browser type, and operating system.
  • Purpose: Website and app analytics, understanding user behavior, and improving our Services.
  • Privacy Policy: https://policies.google.com/privacy
• b) Firebase (Google Firebase)
  • Provider: Google LLC
  • Data Collected: device identifiers, app usage data, crash reports, performance data, push notification tokens, and analytics events.
  • Purpose: App performance monitoring, crash reporting, push notifications, remote configuration, and analytics.
  • Privacy Policy: https://firebase.google.com/support/privacy
• c) AppsFlyer
  • Provider: AppsFlyer Ltd.
  • Data Collected: device identifiers (IDFA/GAID), IP address, install and in-app event data, advertising identifiers, and attribution data.
  • Purpose: Mobile attribution and marketing analytics, measuring advertising campaign effectiveness, and fraud prevention.
  • Privacy Policy: https://www.appsflyer.com/legal/privacy-policy/

These third-party SDKs may collect data independently in accordance with their own privacy policies. We encourage you to review their respective privacy policies for more information about their data practices.

1.5 Information from Third Parties

We may receive information about you from third parties, including identity verification service providers, payment processors, analytics providers, and marketing partners. We may associate this information with other information we have collected about you. The collection, use, and disclosure of information by third parties is governed by their own privacy policies.

2. USE OF YOUR INFORMATION

Our primary purpose for collecting your information is to provide you with the Services you request. We may also use your information for the following purposes:

• Provide, operate, and maintain the Services and our business;
• Create and manage your user account;
• Verify your identity, age, and eligibility through KYC procedures;
• Process transactions, purchases, and redemptions;
• Determine regional availability and enforce territorial restrictions;
• Communicate service-related notices, updates, and promotional messages;
• Provide customer and technical support;
• Customize, measure, and improve our Services and content;
• Deliver relevant advertising and evaluate campaign performance;
• Prevent fraud, abuse, and unauthorized activity;
• Enforce our Terms of Service and the terms of this Policy;
• Comply with legal and regulatory obligations;
• Protect the rights, property, or safety of the Company, users, or others;
• For our own internal business and operational purposes.

Processing is conducted based on consent, contractual necessity, legitimate business interests, or legal requirements, as applicable.

3. YOUR RIGHTS

In accordance with applicable data protection laws, you may have certain rights with respect to your personal data, including but not limited to:

• a) Access: Request confirmation of the types of personal data we have collected about you, the purposes for processing, and obtain a copy of your personal data in a structured, commonly used, machine-readable format.
• b) Correction: Request correction of your personal data where it is inaccurate or incomplete.
• c) Deletion: Request deletion of your account and associated personal data. To submit a deletion request, visit: https://acphostdev.com/deleteaccount.html
  • You will be asked to provide the email address or phone number associated with your account, along with your password for verification. Requests will be reviewed and processed within 7 business days, subject to legal, regulatory, and operational requirements.
• d) Withdrawal of Consent: Withdraw your consent to our collection, use, or processing of your personal data. Please note that withdrawal will only take effect on future processing and will not affect the lawfulness of processing before the withdrawal. If you withdraw consent, you may no longer be able to use all or part of the Services.
• e) Opt-Out of Marketing: Opt out of receiving marketing communications at any time by following the unsubscribe instructions included in the email. This opt-out will not apply to operational or informational emails related to your account.
• f) Lodge a Complaint: Lodge a complaint with us and/or the privacy authorities in your jurisdiction if you believe applicable data protection laws have not been complied with.

For California residents, additional rights may apply under the California Consumer Privacy Act (CCPA), including rights to access, delete, and opt out of certain data practices, subject to statutory exceptions. Requests may be submitted using the contact details below and should include "CALIFORNIA PRIVACY RIGHTS" in the subject line.

4. DATA SECURITY

We have in place physical, electronic, and operational procedures to protect the information that we collect. We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information.

• Payment transactions are handled by third-party payment processors, and we do not store full payment card details on our systems.
• KYC verification documents are stored using encryption and access controls, and are retained only for as long as necessary to fulfill verification and legal compliance purposes.
• Our security measures are reviewed regularly and updated.

Despite these measures, no system can be guaranteed to be completely secure. Transmission of information is undertaken at your own risk.

5. DATA RETENTION

We will retain your information for the period of time necessary to fulfill the purposes described in this Privacy Policy, except where a longer retention period is required or permitted by applicable law. Specific retention guidelines include:

• Account data: Retained for as long as your account is active, plus a reasonable period following account closure.
• KYC verification documents: Retained for the minimum period required by applicable regulations, after which they will be securely deleted.
• Transaction records: We may be required to maintain certain records for a minimum of five (5) years in accordance with anti-money laundering regulations and other legal compliance obligations.
• Analytics data: Retained in aggregated or anonymized form for service improvement purposes.

Upon expiration of the applicable retention period, your data will be securely deleted or anonymized.

6. INFORMATION WE SHARE

We do not sell personal information. We may share information only in the following circumstances:

• a) Service Providers: We may use third-party service providers to perform certain business services and may disclose your information to them as needed. Service providers are contractually required to use information solely for authorized purposes and to maintain confidentiality. Business services include, but are not limited to:
  • Hosting services;
  • Geolocation verification services;
  • Account authentication and identity verification (KYC) services;
  • Payment processing services;
  • Marketing, promotional, and email services;
  • Customer and technical support services;
  • Analytics and performance monitoring services;
  • Fraud prevention services.
• b) Payment Processors: We may share your personal information, such as your email address and payment information, with our third-party payment processors. Once shared, the information will be subject to the privacy policy of the applicable payment processor.
• c) Business Transactions: In connection with corporate transactions, such as mergers, acquisitions, or asset transfers, your information may be transferred to the new owners who may use your information as set out in this Policy.
• d) Legal Process: We may disclose information about you (i) if required by law, regulation, or legal process; (ii) in response to requests by government entities or law enforcement; (iii) when we believe disclosure is necessary to prevent harm, injury, or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.
• e) Protection of Rights: To protect the rights, property, or safety of the Company, our users, or others.

7. INTERNATIONAL DATA TRANSFERS

You acknowledge and agree that all information collected and processed by us may be transferred, processed, and stored outside of your jurisdiction of residence. Such jurisdictions may have data protection laws that are different from where you live. Your information may be accessible to law enforcement and national security authorities of the jurisdiction where we store such information. We endeavor to safeguard your information consistent with the requirements of applicable laws.

8. THIRD-PARTY LINKS

The Services may contain links to external websites or platforms not controlled by us. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies independently before submitting your information.

9. CHILDREN'S PRIVACY

The Services are intended for individuals 18 years of age or older. We do not knowingly collect personal information from individuals under 18. If you are under 18, you are not authorized to provide us with any personally identifying information or access or use our Services. If such information is identified, it will be deleted promptly.

10. NON-CONFIDENTIAL SUBMISSIONS

Any suggestions, feedback, or materials submitted to us outside a confidential relationship may be used by the Company without restriction or compensation, unless otherwise required by law.

11. CONTACT US

If you have any questions about our privacy practices or this Policy, please contact us at:

Email: [email protected]