Overview

CQ Nexus is a digital casino education and training platform operated by Casino Education Investments LLC on behalf of CEI Limited (collectively, "we," "us," or "CQ Nexus"). We are committed to protecting the privacy and security of your personal information.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, who we share it with, how long we retain it, and what rights you have regarding your data. It applies to all interactions with the CQ Nexus application, the website at play.cqnexus.com, and any related services.

By creating an account or using any CQ Nexus service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, please do not use our services.

This policy covers: play.cqnexus.com, the CQ Nexus iOS and Android apps, the Nexus+ companion platform, and all Creator tools. It does not cover third-party services or platforms linked from our app, which have their own privacy policies.

Section 1 — Who We Are and How to Contact Us

1.1 Data Controller

The data controller responsible for your personal information is:

Legal Entity	CEI Limited (Merchant of Record) / Casino Education Investments LLC (Operations)
Platform	CQ Nexus — play.cqnexus.com
Privacy Contact	[email protected]
General Support	[email protected]

Section 2 — What Personal Data We Collect

We collect personal data in three ways: information you provide directly, information collected automatically when you use our platform, and information received from third parties (such as payment processors). The table below summarizes all categories.

Category	Examples	Why We Collect It	Retention
Account & Identity	Name, email address, username, password (hashed), profile photo	Create and manage your account; authenticate login	Life of account + 2 years post-deletion
Contact Information	Email address, phone number (if provided for 2FA)	Communication, support, security alerts	Life of account + 2 years
Payment & Billing	Last 4 digits of card, billing address, transaction IDs, order history. Full card data processed by Stripe/PayPal — we never store raw card numbers.	Process purchases, subscriptions; issue refunds	7 years (tax and legal compliance)
Gameplay & Session Data	Games played, session duration, betting patterns, strategies used, session outcomes, achievement progress, XP earned	Power progression system; enable session tracking; generate personal analytics	Life of account + 2 years
Subscription & Entitlement	Active tier, purchase date, renewal date, entitlement flags per game	Gate access to purchased content; manage billing cycles	Life of account + 7 years
Creator Profile Data	Creator bio, linked payout account info, published content metadata, community space settings	Enable creator functionality and monetization	Life of creator account + 7 years
Tax & Compliance (Creators)	W-9 or W-8BEN form data, SSN (last 4), EIN, legal name, country of residence	IRS compliance; 1099-K filing for eligible creators; Stripe Connect identity verification	7 years minimum per IRS requirements
Community Contributions	Forum posts, strategy content, comments, direct messages (if applicable)	Enable community features; moderation	Life of account; may be retained in anonymized form after deletion
Device & Technical Data	IP address, device type, OS version, browser, app version, crash reports	Security; fraud prevention; platform optimization	90 days for logs; 2 years for aggregated analytics
Usage & Behavioral Data	Pages visited, features used, click patterns, session frequency, time on platform	Product improvement; conversion optimization; personalization	Aggregated: indefinite. Individual: 2 years
Communications	Support tickets, email correspondence, in-app messages to support team	Resolve issues; improve support quality	3 years from last interaction
reCAPTCHA & Security	Mouse movements, interaction patterns, IP, browser fingerprint elements (processed by Google reCAPTCHA)	Bot prevention; fraud detection during checkout and registration	Per Google's reCAPTCHA data policy

Section 3 — How We Collect Your Data

3.1 Directly From You

You provide data to us when you:

• Register for a CQ Nexus account
• Complete a purchase through our checkout (WooCommerce / Stripe / PayPal)
• Subscribe to a Nexus+ plan
• Apply for Creator status and complete onboarding
• Submit a W-9 or W-8BEN tax form for Creator payouts
• Contact our support team
• Participate in community discussions, post content, or use social features
• Fill out surveys, promotions, or early access sign-up forms

3.2 Automatically

We and our service providers automatically collect data when you use our platform, including:

• Cookies and similar tracking technologies (see Section 9 — Cookie Policy)
• Server logs recording IP addresses, access times, and pages visited
• In-app analytics events triggered by your actions (game starts, achievement unlocks, feature usage)
• Crash reports and performance data from our app monitoring tools
• Google reCAPTCHA behavior analysis during registration and checkout

3.3 From Third Parties

We receive data from third-party service providers who help us operate the platform:

• Stripe: Payment confirmation, tokenized card references, Connect account status, payout confirmation
• PayPal: Payment confirmation and transaction identifiers
• Google reCAPTCHA: Risk scoring for bot and fraud detection
• Analytics providers: Aggregated and anonymized usage patterns
• App stores (iOS / Google Play): Purchase confirmation and subscription status for in-app purchases processed through those platforms

Section 4 — Legal Basis for Processing Your Data

We process your personal data on the following legal bases. Where multiple bases apply, the primary basis is listed.

Contract	Processing your account information, purchase history, entitlements, subscription status, and gameplay data is necessary to perform our contract with you — to deliver the services you purchased.
Legal Obligation	We retain financial transaction records, tax documents (W-9/W-8), and creator payout records to comply with IRS reporting requirements, anti-money-laundering obligations, and applicable financial regulations.
Legitimate Interest	We collect device data, usage analytics, behavioral patterns, and security data to prevent fraud, improve platform stability, optimize user experience, and protect our platform and users from abuse.
Consent	We use non-essential cookies, marketing analytics, and promotional communications based on your consent. You may withdraw consent at any time. Withdrawal does not affect prior processing.

Section 5 — How We Use Your Personal Data

5.1 To Deliver and Operate the Platform

• Authenticate your login and maintain your session
• Grant access to purchased game licenses and subscription features
• Track your gameplay sessions, achievement progress, XP, and level progression
• Enable Creator functionality including content publishing, community spaces, and payout processing

5.2 To Process Payments and Comply with Financial Obligations

• Process one-time purchases and subscription renewals
• Issue refunds where applicable under our Refund Policy
• Generate and transmit Creator payouts via Stripe Connect
• File required tax reporting documents (1099-K) for eligible Creators
• Maintain a permanent, auditable transaction ledger for fraud prevention and dispute resolution

5.3 To Communicate With You

• Send order confirmations, receipts, and subscription renewal notices
• Deliver support responses to your inquiries
• Send platform announcements, feature updates, and policy change notifications (these are service communications, not marketing, and cannot be opted out of while your account is active)
• Send promotional emails and marketing content — only with your consent, and only to the extent you have not opted out

5.4 To Keep the Platform Safe and Fair

• Detect, prevent, and investigate fraud and unauthorized access
• Enforce velocity limits on purchases to prevent abuse
• Review flagged accounts for chargeback patterns or suspicious activity
• Maintain admin audit logs for all account actions that affect entitlements or account status
• Enforce our Terms of Use and Community Guidelines

5.5 To Improve Our Products

• Analyze aggregated gameplay data to improve game mechanics and progression balance
• Review conversion funnels to improve the free-to-paid upgrade experience
• Identify bugs, crashes, and performance issues through technical monitoring
• Conduct A/B testing on features and UI elements using anonymized usage data

5.6 What We Do NOT Do With Your Data

To be clear about the boundaries of how we use personal information:

• We do not sell your personal data to third parties for their own marketing purposes.
• We do not share your gameplay or session data with casinos, gaming regulators, or law enforcement absent a legal obligation.
• We do not use your data to build advertising profiles for sale to ad networks.
• We do not use your data to make automated decisions that have significant legal or similarly significant effects on you without human review.

Section 6 — Who We Share Your Data With

We do not sell your personal data. We share it only with service providers who help us operate the platform, and only to the extent necessary for those specific purposes. All third-party service providers are contractually bound to protect your data and use it only as directed by us.

6.1 Payment Processors

Stripe, Inc. and PayPal Holdings, Inc. process payment card transactions on our behalf. We share your payment details directly with these processors through their secure checkout flows. CQ Nexus does not store raw payment card numbers. Stripe also powers our Creator payout program via Stripe Connect. For creators, Stripe may collect identity and tax information directly as part of their onboarding process.

• Stripe Privacy Policy: stripe.com/privacy
• PayPal Privacy Policy: paypal.com/privacy

6.2 Infrastructure and Hosting

Our platform is hosted on cloud infrastructure. Your data is stored on servers located in the United States. Our hosting providers maintain industry-standard physical and technical security controls and are contractually prohibited from accessing your data for their own purposes.

6.3 Analytics Providers

We use third-party analytics tools to understand platform usage at an aggregate level. Where possible, data shared with analytics providers is anonymized or pseudonymized. We do not share personally identifiable gameplay data with analytics providers without your consent.

6.4 Google reCAPTCHA

We use Google reCAPTCHA Enterprise to protect our registration and checkout flows from automated abuse. reCAPTCHA collects hardware and software information, including device and application data, and sends it to Google for analysis. This use is subject to Google's Privacy Policy and Terms of Service.

• Google Privacy Policy: policies.google.com/privacy

6.5 Tax and Compliance Services

For Creator payouts, we may share tax-related information with third-party compliance services that assist with IRS 1099-K generation and filing. This sharing is required by law and limited to the minimum necessary information.

6.6 Legal and Regulatory Disclosure

We may disclose your personal data if required to do so by applicable law, court order, or government request, or if we believe in good faith that disclosure is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of CQ Nexus or CEI Limited
• Prevent or investigate possible wrongdoing in connection with the platform
• Protect the personal safety of users or the public

6.7 Business Transfers

If CQ Nexus or CEI Limited undergoes a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred as part of that transaction. We will notify you via email and an in-app notice before your data is transferred and becomes subject to a different privacy policy.

6.8 With Your Consent

We may share your data in other ways if you have given us specific consent to do so, for example, if you opt into a casino partnership program or featured player showcase.

Section 7 — Children's Privacy

7.1 Age Requirement

CQ Nexus is intended for users who are 18 years of age or older. Casino education content and community features are not designed for or directed at minors.

Important: We do not knowingly collect personal information from anyone under the age of 18. If you are under 18, do not create an account or use our services.

7.2 If We Discover a Minor Has Registered

If we become aware that we have inadvertently collected personal information from a user under 18, we will:

• Immediately suspend the account pending review
• Delete all personal data associated with the account
• Reverse any purchases made by the account, where technically possible
• Notify the parent or guardian if contact information was provided

To report a suspected underage account, contact [email protected].

7.3 COPPA Notice

CQ Nexus does not operate as a children's service as defined by the Children's Online Privacy Protection Act (COPPA). We do not direct our service toward children, and we do not knowingly collect data from children under 13.

Section 8 — Data Security

8.1 Our Security Measures

We implement a range of technical and organizational measures to protect your personal data:

• Passwords are hashed and salted using industry-standard algorithms — we cannot see or recover your plaintext password
• All data transmission between your device and our servers is encrypted using TLS 1.2 or higher
• Payment card processing is handled entirely by Stripe and PayPal — raw card data never touches our servers
• Admin actions that affect account entitlements are logged with full audit trails
• Velocity limits and fraud detection algorithms monitor purchase patterns in real time
• Google reCAPTCHA protects registration and checkout from automated bot attacks
• Creator payout eligibility requires identity verification through Stripe Connect

8.2 Data Breach Response

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify affected users within 72 hours of becoming aware of the breach (or as soon as reasonably practicable)
• Notify relevant regulatory authorities where required by applicable law
• Provide information about what data was affected, what we are doing to address it, and what steps you can take

8.3 Your Role in Security

While we take security seriously, no digital platform is completely immune to risk. You can help protect your account by:

• Using a strong, unique password for your CQ Nexus account
• Enabling two-factor authentication (when available)
• Not sharing your login credentials with others
• Logging out from shared or public devices
• Reporting any suspicious account activity to [email protected] immediately

Section 9 — Cookie Policy

9.1 What Cookies Are

Cookies are small text files placed on your device by websites and apps you visit. They serve functions ranging from keeping you logged in, to remembering your preferences, to helping us understand how people use our platform.

9.2 Types of Cookies We Use

Strictly Necessary Cookies

These cookies are essential for the platform to function. They cannot be disabled. They include:

• Session authentication cookies that keep you logged in
• Security tokens that protect against cross-site request forgery (CSRF)
• Checkout session cookies that maintain your cart during purchase

Functional Cookies

These cookies remember your preferences and settings to improve your experience:

• Language and display preferences
• Your chosen game settings and layout preferences
• Whether you have dismissed certain notifications or tutorials

Analytics Cookies

These cookies help us understand how users navigate and use the platform. The data collected is aggregated and does not directly identify you. You may opt out of analytics cookies in your account settings or through our cookie consent tool.

Third-Party Cookies (reCAPTCHA)

Google reCAPTCHA sets cookies as part of its bot detection functionality. These are processed in accordance with Google's Privacy Policy. By using our checkout and registration flows, you consent to Google's reCAPTCHA data processing.

9.3 Managing Cookies

You can control and delete cookies through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in or completing purchases. For instructions on managing cookies in your browser, visit your browser's help documentation.

Section 10 — Data Retention

We retain your data for as long as necessary to fulfill the purposes described in this policy, and no longer than required by applicable law or our legitimate business needs. The following principles guide our retention:

• Active accounts: All account data is retained while your account is active and for 2 years following account deletion, to allow for account recovery requests and dispute resolution.
• Financial and transaction records: Retained for 7 years from the date of each transaction to meet IRS, anti-money-laundering, and payment processor requirements.
• Creator tax documentation: Retained for a minimum of 7 years from the date of filing, per IRS requirements.
• Support communications: Retained for 3 years from the date of last interaction.
• Security and fraud logs: Retained for 90 days (detailed logs) and up to 2 years (aggregated risk signals).
• Analytics data: Aggregated and anonymized analytics retained indefinitely; individual behavioral data anonymized after 2 years.
• Community content (posts, strategy contributions): Retained for the life of the account; may be retained in anonymized form after deletion if the content has been engaged with by other users.

When your account is deleted, we anonymize your personal identifiers (name, email, IP) and retain the anonymized data for the periods above. We do not retain identifiable personal data beyond these windows except where required by law.

Section 11 — Your Privacy Rights

Depending on where you live, you may have specific rights regarding your personal data. We honor these rights for all users regardless of location, to the extent technically and legally feasible.

Right	Who It Applies To	How to Exercise It
Right to Access	All users	Request a copy of all personal data we hold about you. Email [email protected] with subject line 'Data Access Request.' We respond within 30 days.
Right to Correction	All users	Request correction of inaccurate or incomplete data. Update most information directly in your Account Settings, or contact us for records you cannot edit.
Right to Deletion	All users (subject to legal retention requirements)	Request deletion of your account and associated data. We will delete or anonymize your data within 30 days, except where retention is required by law (see Section 10).
Right to Data Portability	All users	Request a machine-readable export of your gameplay data, session history, and achievement records. Email [email protected].
Right to Restrict Processing	All users	Request that we limit how we use your data while a dispute or correction request is pending. Contact [email protected].
Right to Object	All users	Object to processing based on legitimate interest, particularly for direct marketing. You may opt out of marketing emails at any time via the unsubscribe link in any email.
Right to Withdraw Consent	All users (where consent is the basis)	Withdraw consent for non-essential cookies, analytics, and marketing communications at any time via Account Settings or by contacting us. Withdrawal does not affect prior lawful processing.
CCPA: Right to Know	California residents	Request disclosure of personal data categories collected, sources, purposes, and third parties with whom data is shared. Contact [email protected].
CCPA: Right to Non-Discrimination	California residents	You will not receive different service or pricing for exercising your privacy rights.
GDPR: Right to Lodge a Complaint	EU/EEA residents	You have the right to lodge a complaint with your local data protection authority if you believe we have not handled your data appropriately.

11.1 How to Submit a Privacy Rights Request

To exercise any of the rights above, please contact us at [email protected] with:

• Your full name and account email address
• The specific right you are exercising
• Any relevant details to help us locate your data (such as a date range for a data access request)

We will respond within 30 days. For complex requests, we may extend this period by an additional 30 days and will notify you. We may request verification of your identity before processing certain requests.

Section 12 — California Privacy Notice (CCPA)

This section provides additional disclosures required by the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) for California residents.

12.1 Categories of Personal Information Collected

In the preceding 12 months, CQ Nexus has collected the following categories of personal information as defined by the CCPA:

• Identifiers (name, email, IP address, device identifiers)
• Personal information categories listed in the California Customer Records Act (payment information, partial financial account data)
• Internet or other electronic network activity (usage data, gameplay patterns)
• Inferences drawn from personal information (skill level, progression stage, product preferences)
• Professional or employment-related information (for Creators: business type, content category)

12.2 Sale or Sharing of Personal Information

CQ Nexus does not sell personal information as defined by the CCPA. We do not share personal information with third parties for cross-context behavioral advertising.

12.3 Sensitive Personal Information

We collect Social Security Numbers (last 4 digits) and full SSN/EIN via tax forms for Creator payout compliance only. We do not use sensitive personal information for any purpose other than what is required by law or necessary to fulfill our payout obligations.

12.4 Exercising CCPA Rights

California residents may submit requests to know, delete, or correct their personal information by contacting [email protected]. We will not discriminate against you for exercising these rights.

Section 13 — International Data Transfers

CQ Nexus is operated from the United States. If you access our platform from outside the United States, your personal data will be transferred to and processed in the United States, where data protection laws may differ from those in your country.

For users in the European Union or European Economic Area, we ensure that transfers of personal data outside the EEA are subject to appropriate safeguards, including Standard Contractual Clauses approved by the European Commission or other transfer mechanisms recognized under applicable law.

By using CQ Nexus, you consent to this transfer and processing of your data in the United States.

Section 14 — Third-Party Links and Integrations

Our platform may contain links to third-party websites, casino partner pages, or external resources. We are not responsible for the privacy practices of those third parties. This Privacy Policy applies only to CQ Nexus and its services.

When you click a link to an external website or use a third-party feature integrated into CQ Nexus (such as a casino partner's booking portal), you leave the CQ Nexus environment and that site's own privacy policy applies. We encourage you to review the privacy policy of any third-party site you visit.

Section 15 — Responsible Use and Platform Limitations

CQ Nexus is a casino education and simulation platform. We do not facilitate real-money wagering, and our games do not involve real stakes.

However, we recognize that some users may have concerns about compulsive behaviors related to platform engagement or spending. If you wish to limit your account activity, restrict purchases, or close your account, contact [email protected]. We will work with you to implement appropriate account-level controls.

Section 16 — Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or platform features. When we make material changes, we will:

• Post the updated policy at play.cqnexus.com/privacy
• Update the effective date at the top of this document
• Send an email notification to your registered address at least 14 days before the change takes effect
• Display an in-app notification requiring acknowledgment for significant changes

Your continued use of the platform after the effective date of the updated policy constitutes acceptance of the new terms. If you do not agree with the updated policy, you may close your account before the effective date.

Section 17 — Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us:

Privacy Requests	[email protected]
General Support	[email protected]
Website	play.cqnexus.com/privacy
Response Time	Within 30 days for all privacy rights requests