Cash Avalanche — Privacy Policy

Last Updated: September 21, 2026

IMPORTANT NOTICE: THIS PRIVACY POLICY ("POLICY") IS TO BE READ TOGETHER WITH THE TERMS OF SERVICE, THE OFFICIAL PROMOTIONAL PLAY RULES, THE RESPONSIBLE GAMING POLICY AND THE GAME STATEMENT (COLLECTIVELY AS THE "INCORPORATED POLICIES"). BY ACCESSING OR USING OUR SERVICES (AS DEFINED HEREIN), YOU AGREE TO BE BOUND BY THIS POLICY AND THE INCORPORATED POLICIES.

Cash Avalanche is operated by Spruce Interactive Inc (“Company,” “we,” “us,” “our”). This Privacy Policy describes how we collect, utilize, disclose, and safeguard your personal information when you access or interact with our platform, services, and associated applications.

Our registered business address is 4017 Rawlins St #102 Cheyenne, WY 82001.

For inquiries or concerns regarding this Privacy Policy, please contact us at [email protected].

By accessing Cash Avalanche, you acknowledge that you have reviewed and understood the practices outlined herein. Should you disagree with any portion of this policy, you must discontinue use of our services immediately.

This Privacy Policy applies to all interactions with the Cash Avalanche platform, encompassing our mobile applications, web-based interfaces, application programming interfaces, customer support channels, and any ancillary services or features we may introduce.

We may periodically revise this Privacy Policy to reflect changes in our practices, technology, legal requirements, or business operations. When revisions are material, we will provide conspicuous notice prior to the changes taking effect.

Section I — Safeguarding Minors: Children’s Privacy Protections

Protecting individuals below the legal age of majority remains a paramount concern. Cash Avalanche maintains rigorous protocols designed to prevent minors from gaining access to our platform and to swiftly remediate any breach of these protections.

(1) Age Verification Standards

Cash Avalanche is intended exclusively for individuals who are twenty-one (21) years of age or older. Our platform is neither designed for, nor directed toward, persons under this threshold. We do not knowingly solicit, gather, or retain data from anyone below the required age.

  • All prospective users must affirm their age during account registration through a mandatory attestation step.
  • We reserve the right to employ third-party age-verification instruments, government-issued identification checks, and electronic database cross-referencing to substantiate claimed ages.
  • Any individual unable to demonstrate compliance with the age requirement will be denied access without exception.

(2) Remedial Measures Upon Discovery of a Minor

In the event that we ascertain or reasonably suspect that an account holder is below the age of twenty-one, the following corrective actions are initiated without delay:

  • The account in question is immediately suspended, and all associated login credentials are deactivated.
  • Every piece of personal data linked to that account is purged from our active systems and backup archives within a commercially reasonable timeframe.
  • Any financial transactions, including deposits, withdrawals, winnings, and bonus accruals, are rendered void and reversed to the greatest extent practicable.
  • The individual is permanently barred from re-registering or creating any subsequent account on our platform.

(3) Parent and Guardian Contact Procedure

Parents and legal guardians who believe their child may have furnished personal information to Cash Avalanche are encouraged to reach out to us promptly.

Notification should be directed to [email protected]. Upon receipt, we will investigate the matter expeditiously, confirm whether minor-associated data exists in our systems, and take all necessary corrective steps, including full data deletion and account closure.

  • Guardians may be asked to provide documentation establishing their legal relationship to the minor before we process the request.
  • We commit to acknowledging guardian inquiries within five (5) business days and completing remediation within fifteen (15) business days thereafter.
  • If a guardian request reveals systemic vulnerabilities in our age-verification procedures, we will conduct a comprehensive review and implement enhanced safeguards.

Cash Avalanche cooperates fully with governmental agencies and law enforcement authorities investigating matters related to child protection and online safety.

Section II — Fortifying Your Information: Data Security Architecture

Spruce Interactive Inc employs a multilayered defense posture to shield your information from unauthorized access, alteration, disclosure, or destruction. Although no system can guarantee impenetrable security, we strive to implement controls that meet or exceed prevailing industry benchmarks.

(1) Technical Safeguards

Our infrastructure incorporates a comprehensive suite of technical defenses, including but not limited to:

  • Transport Layer Security (TLS) and Secure Sockets Layer (SSL) encryption for all data transmitted between your device and our servers.
  • Advanced Encryption Standard with 256-bit keys (AES-256) applied to data at rest across all primary and secondary storage media.
  • Intrusion Detection and Prevention Systems (IDPS) that continuously monitor network traffic for anomalous patterns and known attack signatures.
  • Regular penetration testing conducted by independent third-party security firms, with findings remediated according to severity-based timelines.
  • Segmented network architecture that isolates critical databases, payment processing environments, and application servers from one another.
  • Multi-Factor Authentication (MFA) enforced for all internal administrative access, ensuring that a single compromised credential cannot yield system entry.

(2) Organizational Measures

Beyond technological controls, we maintain robust organizational practices:

  • Role-based access control (RBAC) restricts employee visibility to only the data categories necessary for their job functions.
  • Mandatory security awareness training is administered to every team member upon onboarding and refreshed at least annually.
  • A documented incident response plan governs breach identification, containment, eradication, recovery, and post-incident review.
  • Internal security policies undergo periodic review and revision, no less frequently than once per calendar year, to reflect evolving threats and regulatory guidance.
  • Background checks are performed on all personnel with access to sensitive data, including criminal history screening and reference validation.
  • Physical access to data centers and server rooms is governed by biometric entry controls, visitor logs, and 24/7 surveillance monitoring.

(3) Payment Processing Standards

All payment-related operations adhere to the Payment Card Industry Data Security Standard (PCI-DSS). Spruce Interactive Inc does not store full credit or debit card numbers within its own infrastructure. Instead, sensitive payment credentials are replaced with randomized tokens managed by PCI-DSS compliant payment processors, ensuring that raw card data never persists on our servers.

  • Tokenization renders intercepted payment data useless to unauthorized parties, as tokens cannot be reverse-engineered into original card numbers.
  • Our payment infrastructure undergoes quarterly vulnerability scans and annual compliance assessments by a Qualified Security Assessor (QSA).

(4) User Responsibility

While we invest significantly in protecting your data, certain protective measures depend on your own vigilance:

  • Construct strong, unique passwords comprising a blend of uppercase and lowercase characters, numerals, and special symbols. Avoid reusing passwords across different platforms.
  • Enable Multi-Factor Authentication (MFA) on your Cash Avalanche account wherever this option is presented.
  • Notify us immediately at the first indication of unauthorized account activity, suspicious login attempts, or credential compromise.
  • Refrain from sharing your login credentials, one-time passcodes, or account recovery details with any other individual, regardless of their claimed affiliation.

(5) No Absolute Security Guarantee

Despite our extensive precautions, it is important to acknowledge that no method of electronic transmission or digital storage is entirely invulnerable. We cannot and do not warrant absolute security. In the unlikely event of a data breach, we will notify affected users and relevant authorities in accordance with applicable legal requirements.

You accept that your use of Cash Avalanche, including the transmission of personal information over the internet, carries inherent risks that no technological safeguard can entirely eliminate.

Section III — What We Gather: Information Collection Categories

To deliver, maintain, and enhance the Cash Avalanche experience, we collect several distinct categories of information. The specific data points gathered depend on how you interact with our platform.

(1) Contact Information

We collect fundamental communication details necessary to manage your account and correspond with you:

  • Email address, used for account verification, transactional notifications, and optional promotional correspondence.
  • Telephone number, utilized for two-factor authentication, security alerts, and customer support follow-up.
  • Mailing address, which may be required for identity verification, regulatory compliance, or delivery of physical correspondence.

(2) Account Information

Upon registration, we capture and maintain the following account-level details:

  • Your chosen username and encrypted password.
  • Display preferences, notification settings, and interface customization choices.
  • Account creation date, last login timestamp, and session duration metrics.
  • Account status indicators, including active, suspended, self-excluded, or closed designations.
  • Referral source data, such as the promotional code or affiliate link through which you discovered Cash Avalanche.

(3) Personal Identification Details

Regulatory obligations necessitate the collection of certain identifying information:

  • Full legal name as it appears on government-issued documentation.
  • Date of birth to verify legal age eligibility.
  • Nationality and country of residence for jurisdictional compliance.
  • Government-issued identification number (e.g., passport, driver’s license) for identity authentication.
  • Social Security Number (SSN) or Taxpayer Identification Number (TIN), collected solely where mandated by tax reporting regulations.

(4) Transaction and Usage Data

Interactions with our financial and gaming systems generate detailed activity records:

  • Deposit amounts, methods, timestamps, and originating financial instruments.
  • Withdrawal requests, processing statuses, and destination accounts.
  • Complete wagering history, including game type, stake amount, outcome, and session duration.
  • Bonus participation records, encompassing promotional offers accepted, wagering requirements, and fulfillment status.
  • Customer support interaction logs, including chat transcripts, email threads, and resolution outcomes.

(5) Preference Data

We record and honor your expressed preferences regarding platform engagement:

  • Marketing communication opt-in or opt-out selections for email, push notification, and SMS channels.
  • Language and locale preferences governing interface display.
  • Responsible gaming configurations, such as deposit ceilings, loss boundaries, session time restrictions, and voluntary self-exclusion elections.

(6) Location and Device Information

Verifying geographic eligibility and optimizing the user experience requires collection of the following:

  • Internet Protocol (IP) address, from which approximate geographic location may be inferred.
  • Global Positioning System (GPS) coordinates, when you have granted location access permissions.
  • Device model, manufacturer, operating system type and version.
  • Browser type, version, and installed plugin inventory.
  • Unique device identifiers, including Identifier for Advertisers (IDFA) and Google Advertising ID (GAID).
  • Mobile carrier identity and network connection type (Wi-Fi, cellular, VPN).

(7) SDK Auto-Collection

Software development kits embedded within our applications may autonomously capture operational telemetry:

  • Application install and initial launch events, along with associated timestamps.
  • In-app navigation paths, screen view sequences, and feature interaction patterns.
  • Crash reports, error stack traces, and performance degradation indicators.
  • Advertising identifiers leveraged for campaign attribution and audience measurement.

(8) Sensitive Information

Certain verification workflows require the temporary processing of sensitive data categories:

  • Photographs and video recordings captured during identity document verification and facial liveness detection.
  • Audio recordings used in voice-based verification procedures where applicable.

This sensitive information receives heightened security treatment, including restricted access, enhanced encryption, and minimized retention periods commensurate with the verification objective.

We do not utilize sensitive data for marketing, profiling, or any purpose beyond the specific verification task for which it was originally collected. Once the verification objective has been satisfied, sensitive media files are either securely deleted or retained only as long as regulatory requirements dictate.

Section IV — Sensitive Data and Biometric Commitments

Certain regulatory and fraud-prevention imperatives compel us to process data of a particularly sensitive nature. This section articulates the specific types collected, the rationale behind their processing, and the ironclad commitments governing their treatment.

(1) KYC Documentation Requirements

As part of our Know Your Customer (KYC) obligations, we may request and process the following:

  • Full legal name, date of birth, and nationality as declared during registration.
  • A legible copy of a government-issued identification document (passport, national identity card, or driver’s license).
  • A clear selfie photograph for facial comparison against the submitted identification document.
  • Proof of residential address issued within the preceding ninety (90) days (utility bill, bank statement, or official government correspondence).
  • Device identifiers associated with the account to correlate verification sessions with known hardware.

(2) Video and Audio Verification

Where standard document review proves insufficient or where elevated risk indicators exist, supplementary verification may be invoked:

  • Liveness detection procedures requiring the user to perform specified facial movements or gestures before the device camera.
  • Side-by-side capture of the identification document and the user’s face to confirm physical possession.
  • Voice verification sessions in which the user repeats designated phrases for voiceprint comparison, where supported by applicable law.

(3) Third-Party Verification Providers

Cash Avalanche engages specialized third-party providers to execute certain verification workflows. Our primary verification partner is Sumsub, which processes identity documents, biometric captures, and liveness assessments on our behalf.

We strongly encourage all users to review Sumsub’s own privacy policy to gain a comprehensive understanding of how their data is handled within Sumsub’s infrastructure.

Cash Avalanche performs due diligence on all third-party verification providers before engagement, evaluating their data protection standards, certifications, breach history, and contractual commitments to privacy.

(4) KYC Retention Period

KYC-related data is retained for the entire duration of your active account relationship and for the additional period mandated by applicable regulatory requirements following account closure. Once both the account lifecycle and the regulatory retention window have elapsed, KYC data is securely expunged from all active and archival storage systems using industry-recognized data destruction methods.

(5) Biometric Data Commitment

Spruce Interactive Inc makes the following unequivocal pledges regarding any biometric data it processes:

  • We will NEVER sell, lease, or trade biometric information to any third party for any purpose whatsoever.
  • Biometric data is processed solely for the purposes of identity verification, fraud prevention, and regulatory compliance.
  • All biometric records benefit from enhanced encryption standards that exceed those applied to general personal data.
  • Access to biometric data is confined to the narrowest possible set of authorized personnel and automated systems essential to the verification workflow.
  • Biometric templates are stored separately from other personal identifiers to prevent linkage in the event of a partial data compromise.

These commitments represent binding obligations that survive any corporate restructuring, change of ownership, or platform migration undertaken by Spruce Interactive Inc.

Section V — Confirming Your Location: Geolocation and Territorial Restrictions

Cash Avalanche operates exclusively within jurisdictions where online gaming is sanctioned by applicable law. Accurate geographic positioning is indispensable for compliance with these territorial constraints.

(1) Location Verification Consent

By utilizing Cash Avalanche, you expressly consent to the collection and processing of your geographic position data. This consent is integral to our ability to verify that you are physically situated in an authorized jurisdiction each time you access the platform. Withdrawing location consent will render you unable to use core platform features.

(2) Device-Based Verification Methods

We employ multiple complementary techniques to ascertain your physical location:

  • GPS coordinates obtained directly from your device’s satellite positioning hardware.
  • Wi-Fi triangulation using the signal strengths of nearby wireless access points.
  • IP-based geolocation that maps your internet address to an approximate geographic region.
  • Cell tower proximity analysis for mobile devices connected to cellular networks.
  • Native device APIs that aggregate multiple positioning signals for improved accuracy.

(3) VPN and Proxy Detection and Prohibition

The use of virtual private networks (VPNs), proxy servers, anonymizing relays, or any other mechanism intended to mask or falsify your true geographic location is strictly prohibited. Our detection infrastructure continuously evaluates connection attributes for signatures indicative of location obfuscation.

  • Upon detection, the active session is terminated immediately.
  • The associated account may be suspended pending further investigation.
  • Account balances, pending withdrawals, and accrued bonuses may be forfeited in their entirety.

(4) Restricted Territories

Cash Avalanche services are unavailable to individuals located within the following territories:

  • California
  • Connecticut
  • Idaho
  • Louisiana
  • Michigan
  • Montana
  • Nevada
  • New Jersey
  • The state of New York

Attempting to access our platform from any of these jurisdictions constitutes a violation of our Terms of Service and may result in immediate account termination and forfeiture of funds.

This roster of restricted territories may be revised as legislative landscapes evolve. Users bear the responsibility of confirming that their jurisdiction permits participation before creating an account or placing any wagers.

Travel into a restricted territory while maintaining an active account does not exempt you from territorial prohibitions. Platform access must cease immediately upon entering a restricted jurisdiction.

Section VI — Why We Process: Purposes and Legal Foundations

Every instance of personal data processing at Cash Avalanche is anchored to a defined purpose and a recognized legal basis. This section enumerates the principal objectives driving our data practices.

(1) Service Delivery and Operation

We process your data to provision, maintain, and enhance the core functionalities of the Cash Avalanche platform. This encompasses hosting infrastructure management, software updates, feature rollouts, system monitoring, and performance optimization efforts.

  • Personalizing your gaming experience based on stated preferences, historical activity, and device characteristics.
  • Diagnosing and resolving technical malfunctions, service interruptions, and performance bottlenecks.

(2) Account Administration

Personal information is essential for creating, authenticating, and managing your user account. This includes registration processing, credential management, preference storage, session governance, and account lifecycle events such as reactivation or closure.

(3) Transaction Processing

Facilitating deposits, withdrawals, wager settlements, and bonus disbursements requires the processing of financial and transactional data. We maintain detailed records of every monetary exchange to ensure accuracy, enable dispute resolution, and satisfy audit obligations.

  • Currency conversion calculations and associated exchange rates applied at the time of each transaction.
  • Withholding tax computations and reporting submissions required by applicable tax authorities.

(4) Communications

We use your contact information to deliver service-critical notifications, such as transaction confirmations, security alerts, and account status updates. Where you have provided consent, we may also transmit promotional materials, newsletters, and personalized offers.

(5) Fraud Detection and Prevention

Protecting our community from fraudulent schemes, collusion, money laundering, and other illicit activities demands continuous analysis of behavioral patterns, transaction anomalies, and device fingerprints. Automated risk-scoring models and manual review processes operate in tandem to identify and neutralize threats.

  • Multi-account detection algorithms that identify coordinated abuse across seemingly unrelated accounts.
  • Velocity checks on deposits, withdrawals, and wagering patterns that fall outside normal behavioral baselines.
  • Cross-referencing device fingerprints and IP addresses against known fraud databases maintained by industry consortia.

(6) Legal and Regulatory Compliance

We are obligated to process certain data to satisfy the requirements of gaming commissions, financial regulators, tax authorities, and law enforcement agencies. This includes anti-money laundering (AML) checks, responsible gaming monitoring, and mandatory reporting obligations.

  • Filing Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) as required by the Bank Secrecy Act and FinCEN regulations.
  • Responding to regulatory examinations, license renewal inquiries, and compliance audits from state gaming commissions.

(7) Legal Bases for Processing

Depending on the specific processing activity and applicable jurisdiction, we rely upon one or more of the following legal grounds:

  • Contractual necessity: processing required to fulfill the terms of our agreement with you.
  • Legal obligation: processing mandated by statute, regulation, or binding judicial order.
  • Legitimate interests: processing that advances our reasonable business interests without overriding your fundamental rights, such as fraud prevention and infrastructure security.
  • Consent: processing that occurs only after you have provided affirmative, informed agreement, which you may withdraw at any time.
  • Vital interests: processing necessary to protect an interest essential to your life or physical safety, or that of another natural person.
  • Public interest: processing carried out in furtherance of a task performed in the public interest or in the exercise of official authority, where applicable.

Section VII — Removing and Retaining Your Data

We recognize your prerogative to request the removal of your personal data. This section explains how to initiate such a request, the verification process involved, and the categories of data that may be retained notwithstanding a deletion request.

(1) How to Request Deletion

To initiate a data deletion request, please submit a written communication to [email protected]. Your request should include your registered username, the email address on file, and a clear statement expressing your desire for data removal.

(2) Verification of Deletion Requests

For the protection of all users, we must verify the identity of any individual submitting a deletion request before processing it. Verification may involve confirming account credentials, matching personally identifiable information previously provided, or requesting supplementary documentation. We will not honor deletion requests that cannot be satisfactorily attributed to the account holder.

(3) Retained Data Categories

Certain categories of information may be retained even after a valid deletion request has been fulfilled, where retention is necessary for:

  • Anti-money laundering (AML), tax reporting, and financial regulatory compliance mandated by applicable law.
  • Transaction histories required for audit trail integrity and financial reconciliation.
  • Fraud detection databases designed to prevent recidivism by previously identified bad actors.
  • Pending or anticipated legal obligations, including litigation holds, regulatory investigations, and dispute proceedings.
  • Anonymized or aggregated datasets from which individual identities cannot be reconstituted, as these fall outside the scope of personal data.

Where partial deletion is performed, we will inform you of the specific categories retained and the legal basis justifying continued retention.

(4) Processing Timeline

Under the California Consumer Privacy Act (CCPA), deletion requests are processed within forty-five (45) calendar days of receipt. Where the complexity or volume of requests necessitates additional time, we may extend this period by an additional forty-five (45) days, provided that we notify you of the extension and its rationale within the initial response window.

Section VIII — Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) affords you specific rights concerning your personal information. This section details those rights and how to exercise them.

(1) Categories of Personal Information Collected

During the preceding twelve (12) months, Cash Avalanche may have collected the following categories of personal information:

  • Identifiers: real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number.
  • Personal information categories enumerated in Cal. Civ. Code § 1798.80(e): name, signature, Social Security number, physical characteristics, address, telephone number, passport number, driver’s license, financial information.
  • Commercial information: records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories and tendencies.
  • Internet or similar network activity: browsing history, search history, and information regarding interactions with our website, application, or advertisements.
  • Geolocation data: precise physical location derived from GPS, IP address, Wi-Fi, and cell tower data.
  • Biometric information: facial geometry derived from verification photographs, voiceprints from audio verification sessions.
  • Sensory data: audio, electronic, visual, or similar information collected during verification and support interactions.
  • Professional or employment-related information: where voluntarily provided during enhanced due diligence.
  • Inferences: profiles reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

(2) Purposes for Sharing Personal Information

We may share personal information with service providers and third parties for the purposes outlined in Section VI above, including service delivery, fraud prevention, regulatory compliance, advertising attribution, and analytics.

(3) Your Five Core Rights

  • Right to Know. You may request disclosure of the categories and specific pieces of personal information we have collected about you, the sources from which it was gathered, the business or commercial purposes motivating its collection, and the categories of third parties with whom it was shared.
  • Right to Delete. You may request the erasure of personal information we hold about you, subject to certain statutory exceptions including legal obligations, fraud detection, and exercising or defending legal claims.
  • Right to Correct. You may request that inaccurate personal information maintained about you be corrected, taking into account the nature and purposes of the data processing.
  • Right to Opt-Out of Sharing. You have the right to direct us to cease sharing your personal information for cross-context behavioral advertising purposes.
  • Right to Non-Discrimination. We will not deny you services, charge different prices, provide a different quality of service, or retaliate against you for exercising any of the rights granted by the CCPA/CPRA.

(4) How to Exercise Your Rights

To exercise any of the rights described above, submit a verifiable request to [email protected]. We will confirm receipt of your request and endeavor to substantiate your identity through information already in our possession.

Requests are processed within forty-five (45) calendar days. Should additional time be required, we may extend this period by a further forty-five (45) days upon notification to you.

(5) Authorized Agents

You may designate an authorized agent to submit CCPA/CPRA requests on your behalf. The agent must present valid written authorization signed by you, and we may independently verify your identity before processing the agent’s request. We reserve the right to deny requests from agents who fail to produce satisfactory proof of delegation.

  • Authorization documents must clearly identify the agent, the scope of delegated rights, and bear your original or electronic signature.
  • Agents representing multiple consumers must submit separate, individualized authorizations for each person.

(6) Opt-Out of Sharing for Behavioral Advertising

You may opt out of the sharing of your personal information for cross-context behavioral advertising by contacting us at [email protected]. Upon receipt of a valid opt-out request, we will cease sharing within fifteen (15) business days.

Opting out does not affect sharing necessary for operational purposes such as fraud prevention, legal compliance, or service delivery. You will continue to receive non-personalized advertisements and essential platform communications irrespective of your opt-out election.

Section IX — When We Share: Third-Party Disclosure Practices

Cash Avalanche may disclose your personal information to specific categories of recipients under defined circumstances. We do not sell your personal information for monetary consideration. The following outlines when and with whom data may be shared.

(1) Service Providers

We engage vetted third-party service providers who process data strictly on our behalf and subject to binding contractual safeguards:

  • Payment processors that handle deposit and withdrawal transactions, currency conversions, and chargeback management.
  • KYC and identity verification vendors, including Sumsub, that conduct document authentication, biometric analysis, and sanctions screening.
  • Cloud hosting and infrastructure providers that supply the computing, storage, and networking resources underpinning our platform.
  • Customer support platforms that facilitate ticket routing, live chat, email correspondence, and resolution tracking.
  • Analytics and advertising partners that measure platform performance, user engagement, campaign effectiveness, and audience segmentation.
  • Legal, accounting, and advisory firms that provide counsel on regulatory compliance, financial reporting, and dispute resolution.

(2) Corporate Transactions

In the event of a merger, acquisition, corporate restructuring, asset sale, or similar business transformation, your personal information may be among the assets evaluated, transferred, or assigned. Should such a transaction occur, the acquiring entity will be bound by the commitments set forth in this Privacy Policy until a revised policy is communicated to you.

We will provide advance notification of any corporate transaction that materially alters the stewardship of your personal information, affording you the opportunity to exercise deletion rights before the transfer is consummated.

(3) Legal Compliance Disclosures

We may disclose personal information when required or permitted by law, including in response to:

  • Federal, state, local, or foreign statutes mandating disclosure.
  • Lawfully issued subpoenas, civil discovery requests, or interrogatories.
  • Court orders, judicial mandates, or administrative tribunal directives.
  • Regulatory investigations, examinations, or audits conducted by gaming commissions or financial supervisory bodies.

(4) Rights Protection

Disclosure may occur where reasonably necessary to:

  • Enforce our Terms of Service, Acceptable Use Policy, or other binding agreements.
  • Protect the property, intellectual assets, and operational integrity of Spruce Interactive Inc.
  • Safeguard the personal safety and welfare of our users, employees, or the general public.
  • Detect, investigate, and deter fraud, cheating, collusion, or other deceptive practices.

(5) Contractual and Regulatory Obligations

Certain mandated disclosures arise from our contractual relationships and licensing requirements:

  • Gaming regulators and licensing authorities that oversee our operational compliance and may audit our user records.
  • Payment networks (e.g., Visa, Mastercard) whose rules require the sharing of certain transactional data for dispute adjudication and network integrity.

Section X — Advertising, Analytics, and Tracking Technologies

Cash Avalanche integrates software development kits and tracking mechanisms to measure performance, attribute marketing campaigns, and deliver relevant content. This section describes the technologies deployed and the choices available to you.

(1) SDKs and Tracking Instruments

Our applications embed third-party SDKs that automatically collect device information, usage telemetry, and advertising identifiers. These instruments operate within the permissions framework of your device’s operating system and may be controlled through your device settings.

(2) Analytics and Advertising Providers

We partner with the following providers, each serving distinct analytical or promotional functions:

  • Google Analytics: captures usage patterns, session durations, page flows, and demographic approximations to inform product decisions.
  • Firebase: monitors application performance metrics, crash frequency and diagnostic details, and supports remote configuration management.
  • AppsFlyer: delivers mobile attribution data linking app installs and in-app events to specific marketing campaigns and channels.
  • Meta/Facebook: facilitates advertisement attribution, audience targeting, conversion tracking, and lookalike audience construction.
  • Google Ads: powers campaign management, conversion measurement, remarketing list population, and return-on-ad-spend analysis.

(3) Cookies and Similar Technologies

Our web-based interfaces employ cookies and comparable tracking mechanisms for the following purposes:

  • Session cookies that maintain your authenticated state and preferences during a browsing session.
  • Analytics cookies that compile aggregate usage statistics to guide platform improvements.
  • Targeted advertising cookies that enable the delivery of advertisements aligned with your demonstrated interests.
  • Functionality cookies that remember your settings, language selections, and customization choices across visits.
  • Fraud detection cookies that flag suspicious behavioral patterns and correlate activity across sessions.

(4) Monetary Sale Versus Sharing Under CCPA

Cash Avalanche does not engage in the monetary sale of personal information. However, certain data-sharing arrangements with advertising and analytics partners may constitute “sharing” for cross-context behavioral advertising as defined under the CCPA. You may exercise your right to opt out of such sharing as described in Section VIII above.

We maintain an inventory of all data-sharing relationships and regularly assess whether each arrangement constitutes a “sale” or “sharing” under evolving regulatory definitions. This inventory is updated no less frequently than annually.

Section XI — Links to External Platforms

(1) Third-Party Websites and Applications

Cash Avalanche may contain hyperlinks, embedded references, or integrations that direct you to websites, applications, or services operated by third parties. These external destinations are not under our control, and their inclusion does not signify endorsement or responsibility for their content, practices, or policies.

(2) Review External Privacy Policies

We strongly advise you to examine the privacy policy of every external platform before furnishing any personal information. Spruce Interactive Inc bears no liability for the data collection, processing, or security practices of third-party operators, and your interactions with such platforms are governed exclusively by their own terms and policies.

The presence of a hyperlink on our platform does not imply that we have audited, endorsed, or approved the linked destination. Exercise independent judgment and due diligence before sharing sensitive information with any external service.

Section XII — Unsolicited Submissions and Feedback

(1) Deemed Non-Confidential and Non-Proprietary

Any ideas, suggestions, concepts, proposals, feedback, enhancement requests, or other materials you voluntarily transmit to Cash Avalanche through any channel—including but not limited to email, social media, forums, or in-app submissions—will be treated as non-confidential and non-proprietary unless a separate written agreement explicitly states otherwise.

(2) License Grant

By submitting such materials, you grant Spruce Interactive Inc an unrestricted, irrevocable, perpetual, royalty-free, worldwide license to use, reproduce, modify, adapt, publish, translate, distribute, display, and create derivative works from your submissions in any medium now known or hereafter devised, without any obligation of attribution or compensation to you.

(3) No Infringement Warranty

You represent that any materials you submit do not infringe upon the intellectual property rights, privacy rights, or any other rights of any third party. Spruce Interactive Inc assumes no responsibility for verifying the originality or legal status of unsolicited submissions and disclaims all liability arising from their use.

If you wish to submit materials under a confidentiality obligation, you must obtain our prior written consent establishing specific confidentiality terms before transmitting any such materials.

Section XIII — Compelled Disclosures for Legal and Safety Purposes

(1) Circumstances Warranting Compelled Disclosure

Spruce Interactive Inc may disclose your personal information without your prior consent when compelled or permitted by the following circumstances:

  • Compliance with any applicable federal, state, local, or foreign law, rule, or regulation.
  • Response to governmental requests, including those from regulatory bodies with supervisory jurisdiction over our operations.
  • National security or law enforcement demands issued by authorized agencies.
  • Enforcement of our Terms of Service, Privacy Policy, or other binding agreements between you and Cash Avalanche.
  • Protection of the safety, rights, or property of our users, employees, contractors, or the public at large.
  • Response to fraud incidents, cybersecurity threats, or other emergency situations posing imminent harm.
  • Compliance with judicial orders, warrants, court-issued subpoenas, or administrative process lawfully served upon us.

(2) Advance Notice Where Legally Permissible

Where the nature and terms of a compelled disclosure permit, we will make reasonable efforts to provide advance notice to affected users before releasing their personal information. However, such notice may be delayed or withheld entirely where prohibited by the terms of the legal process, court order, or government directive, or where providing notice could compromise an active investigation or jeopardize public safety.

When compelled disclosures occur, we limit the scope of information released to the minimum necessary to satisfy the legal obligation. We maintain a log of all compelled disclosures for internal audit and compliance review purposes.

Nothing in this section shall be construed to create an obligation for Cash Avalanche to challenge every governmental request. We exercise judgment in evaluating the validity, scope, and proportionality of each demand and may seek legal counsel before responding.

Section XIV — How to Reach Us

Should you have questions, concerns, or requests regarding this Privacy Policy or our data handling practices, we welcome your correspondence.

Spruce Interactive Inc
4017 Rawlins St #102 Cheyenne, WY 82001
Email: [email protected]

We endeavor to respond to all legitimate inquiries within a reasonable timeframe, typically no later than fifteen (15) business days from receipt.

For matters requiring urgent attention, such as suspected data breaches, unauthorized account access, or child safety concerns, please indicate the urgent nature of your communication in the subject line to facilitate expedited routing.

Spruce Interactive Inc reserves the right to amend, modify, or replace this Privacy Policy at any time. Material changes will be communicated to registered users through in-app notifications, email correspondence, or prominent placement on our platform. Continued use of Cash Avalanche following such notification constitutes acceptance of the revised policy.

This Privacy Policy is effective as of September 21, 2026.

Acknowledgment

By creating an account on Cash Avalanche, you confirm that you have read this Privacy Policy in its entirety, comprehend the data practices described herein, and consent to the collection, processing, and sharing of your personal information as outlined above.

Your continued use of our platform following any amendments to this Privacy Policy constitutes binding acceptance of the revised terms. We recommend reviewing this document periodically to remain informed of any changes.

Copyright © 2026 Spruce Interactive Inc. All rights reserved. Cash Avalanche is owned and operated by Spruce Interactive Inc. The registered address of Spruce Interactive Inc is 4017 Rawlins St #102, Cheyenne, WY 82001.
Email support (at) [email protected].