PRIVACY POLICY
1.Introduction
Deku Studios LLC ("Deku Studios," "we," "us," or "our") operates the Deku Studios mobile applications, websites (including deku.net), and related services (collectively, the "Platform"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the Platform.
By creating an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is incorporated into and governed by our Terms of Service. Capitalized terms not defined here have the meanings given in the Terms of Service.
If you do not agree with our data practices as described in this Privacy Policy, you should not use the Platform.
2.Information We Collect
2.1Information You Provide Directly
We collect information that you provide when you create an account, participate in contests, make deposits or withdrawals, or contact us:
Account Information. Name, email address, username, display name, and avatar selection. If you sign in through Apple or Google, we receive the information you authorize those providers to share (typically name and email address).
Identity Verification Information. When you complete identity verification (KYC), our third-party verification provider collects a photograph of your government-issued identification document, a selfie photograph, and information extracted from your identification document (including full legal name, date of birth, address, and document number).
Financial Information. When you make deposits or withdrawals, our third-party payment processors collect your payment credentials (credit or debit card number, bank account information, or PayPal account information). Deku Studios does not directly collect, store, or have access to your full card numbers or bank account numbers. We receive and store transaction records including amounts, dates, payment method type, and transaction status.
Tax Information. If your net contest winnings reach or exceed $600 in a calendar year, we collect your Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN) for tax reporting purposes.
Communications. When you contact us for support or other inquiries, we collect the content of your messages, your email address, and any attachments you provide.
2.2Information Collected Automatically
When you use the Platform, we automatically collect certain information about your device and activity:
Device Information. Device model, operating system and version, application version, screen resolution, device language and locale, time zone, and unique device identifiers.
Location Information. With your permission, we collect precise GPS coordinates from your device to verify that you are in an Eligible Jurisdiction before you enter a cash-entry contest. We also collect the state or jurisdiction determined from your GPS coordinates. Location data is collected at the time of each contest entry and is not continuously tracked in the background.
Gameplay Data. For each contest you enter, we collect your submitted words, scores, input timing, game session duration, and contest results. We may also record input replay data (touch positions, swipe paths, and timestamps) for anti-cheat purposes.
Usage Data. Pages and screens viewed, features used, actions taken, time spent on the Platform, and crash or error logs.
Network Information. IP address, VPN or proxy detection signals, and connection type.
2.3Information from Third Parties
We may receive information about you from our third-party service providers:
Authentication Providers. If you sign in with Apple or Google, we receive the profile information you authorize.
Identity Verification Provider. Verification results including approval or rejection status, document authenticity assessment, facial match confidence score, liveness check result, and screening results.
Payment Processors. Transaction status updates, dispute notifications, and fraud risk assessments.
3.How We Use Your Information
We use the information we collect for the following purposes:
Platform Operation. To create and manage your account, process contest entries, calculate scores, distribute prizes, process deposits and withdrawals, and provide customer support.
Legal Compliance. To verify your age, verify your identity, verify your geographic location, comply with anti-money laundering requirements, screen against sanctions lists, comply with tax reporting obligations (IRS Form 1099), and respond to legal process.
Fair Play and Integrity. To detect and prevent cheating, bot usage, multi-accounting, collusion, and other prohibited conduct. To monitor gameplay data for anomalies and conduct human review of flagged sessions.
Safety and Security. To detect and prevent fraud, unauthorized access, and other illegal activity. To protect the security and integrity of the Platform.
Communication. To send you transactional communications (contest results, deposit confirmations, withdrawal status, account alerts), respond to your support inquiries, and send service announcements.
Improvement. To analyze usage patterns, diagnose technical issues, and improve the Platform's features and performance.
Responsible Gaming. To enforce deposit limits, self-exclusion periods, and other responsible gaming controls you have configured.
4.How We Share Your Information
We do not sell your personal information. We share your information only in the following circumstances:
4.1Third-Party Service Providers
We share information with third-party service providers who process data on our behalf to operate the Platform. These providers include services for authentication and session management, payment processing, identity verification and compliance screening, content delivery and security, application hosting, and push notifications. These providers are contractually required to use your information only for the purposes of providing services to us and to maintain appropriate security measures.
4.2Legal Obligations
We may disclose your information when required to do so by law, regulation, legal process, or governmental request. This includes responding to subpoenas, court orders, or other legal process, and cooperating with law enforcement or regulatory authorities.
4.3Tax Reporting
We report contest winnings to the Internal Revenue Service (IRS) as required by law. If your net winnings in a calendar year reach or exceed $600, we will file an IRS Form 1099-MISC that includes your name, address, SSN or ITIN, and the amount of winnings.
4.4Protection of Rights
We may disclose your information when we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraud, or respond to a government request.
4.5Business Transfers
If Deku Studios is involved in a merger, acquisition, bankruptcy, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you of any such change by posting notice on the Platform or by email.
4.6Aggregated and De-identified Data
We may share aggregated or de-identified information that cannot reasonably be used to identify you. For example, we may publish aggregate statistics about contest participation, average scores, or platform usage trends.
5.Data Retention
We retain your personal information for as long as your account is active and for the periods described below after account closure or data collection:
| Data Type | Retention Period | Rationale |
|---|---|---|
| Account information (name, email) | Duration of account + 7 years | Tax and regulatory compliance |
| Transaction records | 7 years from transaction date | IRS financial record requirements |
| Geofence verification records | 7 years | Regulatory audit evidence for state compliance |
| Age verification records | 7 years | Proof of age gate enforcement |
| KYC documents and verification results | 7 years after account closure | AML/KYC regulatory retention |
| Gameplay data and contest results | 7 years | Dispute resolution, anti-cheat review, regulatory compliance |
| Device information | Duration of account + 7 years | Anti-cheat context, fraud investigation |
| Tax records (SSN, 1099 filings) | 7 years from applicable tax year | IRS requirements |
| Support communications | 3 years from resolution | Customer service quality |
After the applicable retention period, data is deleted in accordance with our data lifecycle procedures.
6.Data Security
We implement technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction:
Encryption. All data is encrypted in transit using TLS (Transport Layer Security). Data at rest is encrypted using industry-standard encryption at the database and infrastructure level.
Access Controls. Access to personal information is restricted to authorized personnel on a need-to-know basis. Administrative access is role-based with all actions logged in an audit trail.
Payment Security. We are PCI-compliant through our payment processor integrations. Card data is tokenized before it reaches our servers. Full card numbers never touch Deku Studios systems.
Authentication Security. Player authentication supports Apple Sign-In, Google Sign-In, and email-based authentication. Multi-factor authentication is enforced for administrative access.
Monitoring. We employ automated fraud detection, transaction monitoring, and security alerting.
While we take commercially reasonable steps to protect your information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security.
7.Your Rights and Choices
7.1Account Information
You may update your account information (display name, email address, avatar) at any time through the Platform's settings.
7.2Location Permissions
You may revoke location permissions through your device settings at any time. If you revoke location permissions, you will be unable to enter cash-entry contests but may continue to use free-play features.
7.3Push Notifications
You may opt out of push notifications through your device settings or within the Platform's notification preferences.
7.4Account Deletion
You may request deletion of your account by contacting support@deku.net. Upon receiving a verified account deletion request, we will close your account and prevent further access, return any remaining cash balance to you (subject to identity verification and applicable withdrawal processing times), forfeit any remaining Acorns balance, and delete or de-identify your personal information except for data we are required to retain for legal, regulatory, tax, or compliance purposes (as described in Section 5).
Account deletion requests are processed within thirty (30) days.
7.5Data Access and Portability
You may request a copy of the personal information we hold about you by contacting privacy@deku.net. We will provide your data in a commonly used, machine-readable format within forty-five (45) days.
8.California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have the following additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"):
Right to Know. You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which we collected it, the business or commercial purposes for collecting it, and the categories of third parties with whom we shared it.
Right to Delete. You have the right to request that we delete personal information we have collected from you, subject to certain exceptions (including data retained for legal compliance, as described in Section 5).
Right to Correct. You have the right to request that we correct inaccurate personal information we maintain about you.
Right to Opt Out of Sale or Sharing. We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising purposes.
Right to Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights.
Categories of Personal Information Collected. Under CCPA categories, we collect: identifiers (name, email, SSN), personal information under Cal. Civ. Code 1798.80 (name, address, financial information), protected classification characteristics (age, date of birth), commercial information (transaction records, contest history), internet or electronic network activity (usage data, device information), geolocation data (GPS coordinates), sensory data (selfie and ID photographs for KYC), and inferences drawn from the above.
How to Exercise Your Rights. To exercise any of these rights, contact us at privacy@deku.net or submit a request through the Platform's settings. We will verify your identity before processing your request. You may designate an authorized agent to submit a request on your behalf with written authorization.
Financial Incentive Notice. We do not offer financial incentives or price differences in exchange for the retention or sale of personal information.
9.Children's Privacy
The Platform is not intended for children under the age of eighteen (18). We do not knowingly collect personal information from children under thirteen (13). If we become aware that we have collected personal information from a child under thirteen (13), we will promptly delete that information.
If you are a parent or guardian and believe your child under 13 has provided us with personal information, please contact us at privacy@deku.net. We take compliance with the Children's Online Privacy Protection Act (COPPA) seriously and will investigate and act on all such reports.
10.International Users
The Platform is currently available only in the United States. If you access the Platform from outside the United States, you understand and consent to the transfer, processing, and storage of your information in the United States, where data protection laws may differ from those of your country.
11.Third-Party Links and Services
The Platform may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access.
12.Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the Platform and, where practicable, by sending notice to the email address associated with your account. The "Last Updated" date at the top of this policy indicates when it was most recently revised. Your continued use of the Platform after the effective date of any changes constitutes acceptance of the updated Privacy Policy.
13.Contact Us
If you have questions about this Privacy Policy or our data practices, please contact us:
Privacy Inquiries: privacy@deku.net
General Support: support@deku.net
Mail: Deku Studios LLC, 418 Broadway #11209, Albany, NY 12207
Website: https://deku.net