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CLUB AXO LLC
Version 4.1 | Effective 1 September 2026 | 21+ | Play Responsibly
This Privacy Policy describes how Club AXO LLC (the “Company”, “we”, “us” or “our”) collects, uses, discloses and protects personal information in connection with the Club AXO platform (the “Platform”). It applies to all users of the Platform and is to be read together with the Terms and Conditions, the Sweepstakes Rules, the Cookie Policy, the Boost Squad Rules and the Responsible Gaming Policy.
The Platform is intended only for individuals who are at least 21 years of age and located in a jurisdiction in which the Company is permitted to operate. By using the Platform you agree to the practices described in this Policy.
Capitalised terms used but not defined in this Policy have the meanings given in clause 1 of the Terms and Conditions.
1.1 Controller. Club AXO LLC is the controller of the personal information described in this Policy.
1.2 Particulars.
Legal name: Club AXO LLC
Assumed or fictitious names: None.
Jurisdiction of formation: State of Wyoming, United States
Registered business address: 1309 Coffeen Avenue, Suite 1200, Sheridan, WY 82801
1.3 Contact. Privacy rights requests and appeals: legal@clubaxo.com. General privacy enquiries: support@clubaxo.com. Marketing preferences and advertising opt-outs: marketing@clubaxo.com. Requests may also be sent by post to the registered business address.
1.4 Misdirected requests. A request sent to any address published by the Company will be honoured. The Company will not reject a privacy request on the ground that it was sent to the wrong address.
2.1 Information you provide. On registration and in the course of using the Platform, the Company collects your full legal name, date of birth, residential address, email address and telephone number. For the purposes of identity verification and the processing of redemptions, the Company collects government-issued identification, a live selfie image, your Social Security Number or Individual Taxpayer Identification Number and, where required, proof of address and source-of-funds documentation. The Company also collects the content of your communications with its support personnel, including chat.
2.2 Biometric information. In the course of identity verification the Company collects biometric information derived from your selfie image and identification document, including facial-geometry data used for liveness detection and to confirm that the live person corresponds to the photograph on the identification document. Clause 5 makes further provision.
2.3 Payment information. Where you purchase Gold Coins, your payment card and transaction details are collected and processed by the Company’s third-party payment processor. Where you receive a redemption, your payout details are processed through MojoWallet. The Company does not store full payment card numbers on its own systems.
2.4 Information collected automatically. The Company automatically collects device and browser information, internet protocol address, device identifiers and fingerprint data, geolocation data, gameplay and transaction activity, authentication logs, and usage information, including through cookies and similar technologies. The Cookie Policy makes further provision.
2.5 Boost Squad information. Where you use Boost Squad, the Company records the connections you form with other participants and determines whether you and your connected participants are online simultaneously in order to calculate the applicable multiplier. Clause 6 governs the information visible to other participants.
3.1 The Company processes personal information for the following purposes:
3.1.1 to create and operate your Account and to provide the Platform;
3.1.2 to verify your identity, age and location;
3.1.3 to process Gold Coin purchases and Sweeps Coin redemptions;
3.1.4 to operate Boost Squad and to calculate any applicable multiplier;
3.1.5 to detect and prevent fraud, money laundering and other misuse;
3.1.6 to establish the facts and to defend the Company’s position where a purchase is disputed;
3.1.7 to enforce eligibility criteria, geographic restrictions and responsible-gaming controls;
3.1.8 to comply with legal, tax and regulatory obligations;
3.1.9 to communicate with you concerning your Account and to provide support;
3.1.10 to improve and secure the Platform; and
3.1.11 where permitted, to send promotional communications, which you may decline at any time by the means described at clause 9.4.
4.1 Categories. The Company processes the following categories of information which are treated as sensitive under one or more State privacy laws:
4.1.1 biometric information, as described at clauses 2.2 and 5;
4.1.2 government-issued identification numbers, including Social Security Number or Individual Taxpayer Identification Number;
4.1.3 precise geolocation data; and
4.1.4 records relating to responsible-gaming controls, being the setting or variation of a deposit, session or spending limit, the commencement or expiry of a cool-off, a self-exclusion and its duration, the identifying information retained in order to enforce a self-exclusion, and records of any responsible-gaming intervention made by the Company under clause 7 of the Responsible Gaming Policy.
4.2 Purposes. The Company processes sensitive information only for the purposes of providing the Platform, verifying identity and age, preventing fraud and money laundering, operating and enforcing responsible-gaming controls, and complying with its legal obligations. The Company does not process sensitive information for advertising, profiling, or the training of any model.
4.3 No sale. The Company does not sell sensitive information and does not disclose it for cross-context behavioural advertising.
4.4 No health determination. The Company does not diagnose any condition, does not provide treatment or medical advice, and does not score, rate or record any conclusion as to the physical or mental health status of any participant. A responsible-gaming intervention under clause 7 of the Responsible Gaming Policy constitutes an offer of tools and support and does not constitute a clinical assessment.
4.5 Right to limit. Where State law confers a right to limit the use and disclosure of sensitive personal information, you may exercise that right in accordance with clause 9.
5.1 Purposes. The Company collects and uses biometric information solely to verify identity, confirm liveness, prevent fraud and duplicate Accounts, and satisfy its legal and compliance obligations.
5.2 Processor. Biometric information is collected and processed on the Company’s behalf by MojoVerify LLC. Consent is obtained during the verification flow, which identifies the Company as the party on whose behalf the information is collected.
5.3 No sale or profit. The Company does not sell, lease, trade or otherwise profit from biometric information, and does not use it for advertising or profiling.
5.4 Retention and destruction schedule. Facial-geometry templates and liveness data used for the match are permanently destroyed on completion of the verification decision. An identity image retained as evidence of that decision is permanently destroyed on the purpose for which it was collected having been satisfied and, in any event, not later than 24 months after your last interaction with the Company. Where the Company determines that continued storage is no longer necessary, the data is destroyed within 45 days of that determination.
5.5 No extension for other purposes. The retention periods at clause 5.4 are not extended for anti-money-laundering purposes. The Company’s anti-money-laundering records retain transaction and decision data and do not retain biometric identifiers, biometric information or identity images. The seven-year period at clause 8 does not apply to biometric information.
5.6 Publication. Clause 5.4 constitutes the Company’s written policy for the retention of, and the guidelines for the permanent destruction of, biometric identifiers and biometric information, and is published here so as to be available to the public.
5.7 Written release. Before collecting biometric information the Company informs you of what is collected, the purpose of collection and the period of retention, and obtains your written release. You may request a copy of that release, and confirmation that a template has been destroyed, at legal@clubaxo.com.
6.1 General position. Personal information held by the Company is not visible to other participants, save as provided in this clause 6.
6.2 Boost Squad. Where you use Boost Squad, a participant to whom you are connected may view: your username; your avatar; whether you are online; whether you have completed identity verification; and the name of the game you are playing. That constitutes the entirety of the information disclosed.
6.3 Information not disclosed. The Company does not disclose to any participant: your balance in either currency; the amount you have won or lost; the amount you have wagered or spent; your legal name; your contact details; your location; your Account history; or the content of your communications with support personnel. No monetary amount is disclosed between participants.
6.4 Duration. Disclosure under clause 6.2 occurs only in respect of a participant with whom you are connected through Boost Squad and only for so long as that connection subsists.
6.5 Withdrawal. You may leave Boost Squad, or remove an individual connection, at any time through your Account settings, whereupon disclosure under clause 6.2 ceases. Withdrawal does not affect Sweeps Coins already credited to you.
6.6 Calculation. The Company uses the fact that you and connected participants are online simultaneously in order to calculate the applicable multiplier. That calculation is performed by the Company and its result is disclosed to you and not to other participants.
6.7 Responsible-gaming controls. While you are subject to a cool-off or a self-exclusion, you are not shown as online to any participant, do not count toward the multiplier of any participant, and will not receive Boost Squad invitations. Clauses 3, 5 and 9 of the Responsible Gaming Policy make further provision.
7.1 Recipients. The Company discloses personal information only as necessary to operate the Platform and to satisfy its obligations, and only to the following categories of recipient:
7.1.1 Service providers, including MojoVerify (identity verification, biometric matching, geolocation, and fraud and sanctions screening), the Company’s third-party payment processor (purchase processing), MojoWallet (redemption payouts), game content providers, and hosting, communications and analytics providers. For the purposes of identity verification, geolocation and fraud prevention, the Company provides MojoVerify with identifying information together with device and network information, including internet protocol address and device fingerprint;
7.1.2 Payment processors, acquiring banks and card networks, where a purchase on your Account is disputed and for the purpose of responding to that dispute, which disclosure may include transaction records, device and browser information, internet protocol address and geolocation data, authentication logs and gameplay history;
7.1.3 Regulators, law-enforcement agencies, tax authorities and other governmental bodies, where required by law or in order to protect the Company’s legal rights;
7.1.4 Sanctions and politically-exposed-person screening services, and fraud-prevention databases;
7.1.5 State self-exclusion registries and cross-platform self-exclusion networks, through the Company’s verification provider, for the purpose of enforcing responsible-gaming exclusions;
7.1.6 Other participants, to the extent and in the circumstances set out at clause 6; and
7.1.7 A successor entity, in connection with a merger, acquisition or sale of assets.
7.2 No sale for monetary consideration. The Company does not sell personal information for monetary consideration. Where a disclosure for the purposes of targeted advertising constitutes a “sale” or “share” under State law, you may opt out in accordance with clause 9.4.
8.1 General. The Company retains personal information for so long as is necessary to provide the Platform and to satisfy its legal obligations. The periods below apply unless a longer period is required by law or by a pending investigation, dispute or legal claim.
| Category | Retention period |
|---|---|
| Account and profile data | Duration of the Account, then 7 years |
| Transaction, purchase and redemption records | 7 years from the transaction or closure of the Account, whichever is later |
| Anti-money-laundering records and decisions | Not less than 7 years |
| Identity images and biometric information | As provided at clause 5.4; in any event not later than 24 months after the last interaction |
| Geolocation and device records | 24 months |
| Chargeback and dispute evidence | 7 years, or until final resolution of the dispute and any related claim, whichever is later |
| Responsible-gaming records | Not less than 7 years |
| Self-exclusion identifiers | For so long as is necessary to enforce the exclusion |
| Support communications, including chat | 3 years |
| Marketing preferences | Until withdrawn, then 2 years as a record of withdrawal |
8.2 Deletion. Where information is no longer required, the Company deletes or anonymises it.
9.1 Rights. Subject to your State of residence, you may have the right under applicable State privacy law, including the laws of California, Colorado, Connecticut, Virginia, Texas, Oregon, Montana and other States, to: access the personal information held about you; correct inaccurate information; request deletion; obtain a portable copy; limit the use and disclosure of sensitive personal information; and opt out of targeted advertising, of the sale or sharing of your information, and of certain profiling.
9.2 Exercise of rights. Rights may be exercised by email to legal@clubaxo.com, by contacting support@clubaxo.com, or by post to the registered business address.
9.3 Response period. The Company will respond within 45 days, which period may be extended once by a further 45 days where a request is complex, in which case the Company will notify you of the extension and its reasons within the initial 45-day period. No charge is made.
9.4 Opt-out. You may opt out of the sale or sharing of your personal information and of targeted advertising by the “Do Not Sell or Share My Personal Information” link in the Platform footer, through the cookie preferences tool, by transmitting a Global Privacy Control signal, or by email to marketing@clubaxo.com.
9.5 Appeals. Where the Company declines a request, it will notify you of the reasons and of the means of appeal. An appeal may be made to legal@clubaxo.com and will be determined within 45 days. Where an appeal is denied, the Company will provide a written explanation and a means of contacting the Attorney General of your State.
9.6 No discrimination. The Company will not discriminate against you for exercising any right under this clause 9.
9.7 Exemptions from deletion. Certain information is exempt from deletion because the Company is required by law to retain it, in particular anti-money-laundering records, transaction records and self-exclusion identifiers. Where a deletion request is made, the Company will effect a partial deletion and will notify you of the records retained and the basis of retention. An Account subject to an active self-exclusion may not be deleted for the duration of that exclusion.
10.1 The Company uses cookies and similar technologies to maintain your session, remember your preferences, secure the Platform and analyse its use. The Cookie Policy describes those technologies, the categories of cookie set, and the means of controlling them.
10.2 The Company honours the Global Privacy Control signal as a request to opt out of the sale or sharing of personal information and of targeted advertising, in every State in which that signal is required to be honoured.
10.3 The Company does not respond to Do Not Track signals, no common industry standard existing in respect of them.
10.4 Certain features of the Platform may not function correctly where cookies are disabled.
11.1 The Company protects personal information by appropriate technical and organisational safeguards, including encryption of data at rest (AES-256) and in transit (TLS 1.3), tokenisation of payment data consistent with PCI DSS, multi-factor authentication for sensitive functions, access controls and logging, and contractual and due-diligence safeguards in respect of its vendors.
11.2 In the event of a data breach affecting your information, the Company will notify you and the relevant authorities as required by applicable law.
12.1 The Platform is restricted to adults aged 21 or over.
12.2 The Company does not knowingly collect personal information from any person under 21.
12.3 Where the Company becomes aware that it has collected information from a person under 21, it will close the Account, void the related activity, and delete the information save where retention is required by law.
13.1 The Platform may link to or integrate third-party websites and services which the Company does not control, including the websites of Venue Hosts.
13.2 The handling of information by such third parties is governed by their own privacy policies.
13.3 Clause 24 of the Terms and Conditions describes the relationship between the Company and a Venue Host.
14.1 The Company may amend this Policy from time to time to reflect changes in its practices or in applicable law.
14.2 An amended version takes effect on publication on the Platform unless otherwise stated.
14.3 Where an amendment materially affects your rights, the Company will give notice before it takes effect.
Club AXO LLC 1309 Coffeen Avenue, Suite 1200, Sheridan, WY 82801
| Purpose | Address |
|---|---|
| Privacy rights requests, appeals, legal notices | legal@clubaxo.com |
| General privacy and account enquiries | support@clubaxo.com |
| Marketing preferences and advertising opt-outs | marketing@clubaxo.com |