Privacy Policy

1. Introduction & Operating Scope

Welcome to Modo Casino, operated by ARB Gaming LLC ("we," "us," or "our"). We are deeply committed to respecting and protecting the personal privacy of every participant who registers an account, accesses our social sweepstakes casino platform via https://playmodocasino.com/, or interacts with our digital sweepstakes promotions, game catalog, customer support channels, or promotional loot mechanics (collectively, the "Services").

This Privacy Policy describes our practices concerning the collection, storage, processing, transfer, and disclosure of personal data gathered from United States visitors and registered users. By accessing or continuing to utilize Modo Casino, you acknowledge that you have read, comprehended, and agreed to the protocols described in this Policy.

2. Personal Information We Collect

We collect personal information necessary to deliver seamless social sweepstakes gameplay, authenticate eligibility under US sweepstakes law, and fulfill real-world prize redemptions. This includes:

• Account Registration Identifiers: First and last legal name, residential address, date of birth, personal email address, and unique password hashes.
• Government Identity & KYC Data: Valid state driver’s license, passport, or state ID copies, biometric facial scans for automated identity matching, and utility bills or bank statements demonstrating residency in eligible US states.
• Financial & Payment Records: Transactional identifiers for optional Gold Coin (GC) package purchases, ACH routing and account numbers for cash redemptions, and digital gift card fulfillment email addresses. Note: Modo Casino never stores full credit card CVV credentials directly on our application servers.
• Player Communications: Chat session transcripts, email support inquiries, responsible gaming self-limitation requests, and feedback submitted via web forms.

3. Automated Information & Cookies

When you browse our progressive web app (PWA) on desktop or mobile devices, our infrastructure automatically records telemetry data via secure cookies, local storage objects, and web beacons. This information encompasses your Internet Protocol (IP) address, geolocation data (to verify jurisdiction eligibility), browser fingerprint, device operating system, hardware specifications, screen resolution, referrers, and game session timelines.

4. How We Utilize Your Data

Modo Casino processes your data under strict lawful bases including performance of promotional sweepstakes obligations, compliance with federal and state regulations, and legitimate operational interests. Specifically, your data enables us to:

• Administer your member wallet, sync Gold Coin (GC) and Sweeps Coin (SC) balances, and execute game spins with certified Random Number Generators (RNG).
• Verify your age (18+) and geographic location to exclude non-eligible jurisdictions (including Washington, Idaho, Nevada, and Michigan).
• Process legal prize redemptions via ACH wire transfers or digital gift cards through partners such as Prizeout.
• Detect and neutralize fraudulent multi-accounting, automated botting, money laundering, and promotional exploitation.
• Enforce voluntary responsible social gaming tools, reality check pop-ups, daily purchase ceilings, and permanent self-exclusions.

5. Data Sharing & Third-Party Disclosure

Modo Casino does not sell, lease, or monetize your personal information to third-party data brokers. We share your information solely with certified service providers under strict non-disclosure obligations:

• Identity Verification Providers: Automated biometric and KYC verification services (such as Sumsub or Veriff).
• Banking & Disbursement Gateways: Accredited US Automated Clearing House (ACH) merchant processors and digital gift card distribution platforms.
• Game Software Providers: Independent gaming studios (Pragmatic Play, Relax Gaming, Booming Games) receiving pseudonymized player session IDs.
• Legal & Regulatory Authorities: Government bodies or law enforcement agencies when mandated by court orders, subpoenas, or statutory sweepstakes compliance.

6. Data Security & Cryptographic Storage

We maintain an enterprise-grade defense-in-depth security posture. All data transmitted between your browser and our infrastructure is protected by 256-bit Secure Sockets Layer (SSL/TLS 1.3) encryption. Sensitive stored data, including verified government IDs, is safeguarded at rest with AES-256 cryptographic standards inside SOC-2 Type II certified cloud environments. Continuous penetration testing and firewall rules ensure robust isolation from unauthorized intrusion.

7. Your United States Privacy Rights (CCPA/CPRA)

Residents of California, Virginia, Colorado, Connecticut, Utah, and other jurisdictions possessing comprehensive consumer privacy legislation hold specific rights regarding their personal data:

• Right to Know & Access: You may request disclosure of the specific categories and pieces of personal data collected about you.
• Right to Rectification: You may request the correction of inaccurate or outdated personal records.
• Right to Deletion: You may request the expungement of your personal data, subject to legal recordkeeping obligations for anti-fraud and tax compliance.
• Right to Non-Discrimination: We will never deny services, alter coin bonus rates, or penalize any player exercising their privacy rights.

To exercise any of these statutory rights, please submit a verified consumer request to our Data Protection Officer at [email protected] with the subject line "Privacy Rights Request."

8. Underage Protection & Minor Policy (18+)

Modo Casino is strictly designed and intended for individuals who are at least eighteen (18) years of age or the legal age of majority in their jurisdiction. We do not knowingly solicit, collect, or store information from individuals under 18. If we discover that a minor has registered an account, that profile and all associated data are purged immediately.

9. Data Retention Schedules

We retain personal information only for as long as your account remains active or as required to fulfill the objectives described in this Policy. Following account closure, certain transactional and verification logs must be maintained for up to seven (7) years to satisfy United States federal anti-money laundering (AML), IRS tax reporting, and sweepstakes audit statutes.

10. Contacting Our Data Privacy Officer

If you have questions, inquiries, or grievances regarding this Privacy Policy or our data management practices, please contact our Data Protection Team at: