Effective as of 13 July, 2022
2. Collection of Information
We collect information directly from you and by automated means as set out below. The type of information that we collect from you depends on your particular interaction with our Services and Game, but generally includes the below information.
3. Information We Collect
A. Account and Registration. Users may access our Game only if they register an Account with us. The personal information we collect as part of the Account creation process includes your first and last name, email, username, password, information to confirm you are old enough to use the Services and play the Game, payment information for Account funding and competition entry fees (for example, your name and email associated with your payment account). We may also ask you or allow you to submit certain optional information, which may include your updated usernames, preferences, and other profile information.
B. Identification Verification. We may collect certain personal information, such as first name, last name, shipping address, phone number, and Social Security number, to verify your identity when you deposit or withdraw cash from your account and by us and certain third-party service providers to monitor for fraudulent activity and verify that you can legally participate in competitions and receive prizes.
C. Prizes and Payments. Our payment processor or processors may collect information to process prize winnings, administer payments, comply with the law (including requiring W9 tax forms when necessary), and maintain records of prizes and payments, which may include your PayPal email, full name, mailing address, Social Security or Taxpayer ID number, and other information necessary to complete a 1099-MISC tax reporting form, and other relevant tax documentation.
D. Feedback. We collect and maintain records of customer service and other communications with users including survey responses, questions or comments sent to us (including the nature of the nature of the request, name and contact information), resumes provided, or other similar activities. This information may be used to enhance the Services or the Game, to market to you or others, and to allow us to make appropriate hiring decisions if submitted for that purpose.
E. Usage Data. We automatically collect information about your use of our Services and the Game through cookies, local storage, analytics tools and other technologies, such as your device ID, location information, device name and model, operating system type, name and version, the length of time that you are using our Services and your activities within our Services (“Usage Data”). We may combine Usage Data with other information that we have collected about you. Please see the section “Analytics and Tracking” below for more information.
F. Interactions and Activities. We collect information about your activities in the Game, such as competitions played, scores, game outcomes, and rankings. We collect your geolocation information for purposes of verifying that you are in state, province, or country where our Game and Services are offered, and for our own due diligence and verification purposes.
4. Personal Information
That You May Voluntarily Provide to Us:
A. In the course you acting as a job applicant to, an employee of, director of, officer of, or contractor of us, you may provide certain Personal Information to us in your applicable role. Said Personal Information could include email address, phone number, name, SSN, bank information and government identification numbers. For the purposes of the California Consumer Privacy Act (“CCPA”) this section provides the disclosure of categories of Personal Information we collect regarding the same.
B. Your email address and password to allow you to create an account and use our Services. Your email address may also be used for marketing and promotional emails as allowed by applicable law.
C. Username, if provided by you, to allow you to use the Services. Your username, name, password and email address are collectively referred to as your “Account Information”.
D. Birth date to verify that you are over the age of 18.
E. Mailing address to allow physical prize fulfillment.
F. Phone number to allow us to contact you, allow for the use of the Services, and to prevent fraud.
G. Your mobile device’s unique device ID to prevent fraud.
H. Any Personal Information you choose to add to your profile, such as an image. This Personal Information is used to enhance your use of the Services.
I. You may provide credit card information or your PayPal username to our payment processor(s) to use certain features of the Services. We will use third-party credit card processing companies to process your transactions. We will not have access to your credit card data.
J. Certain Personal Information, such as first name, last name, shipping address, phone number, and Social Security number, to verify your identity when you withdraw cash from your account and by us and certain third-party service providers to monitor for fraudulent activity and verify that you can legally participate in cash tournaments and withdraw funds.
K. Personal Information you may choose to submit to us through surveys, sending questions or comments, providing a resume, or other similar activities. This information may be used to enhance the Services, to market to you or others, and to allow us to make appropriate hiring decisions if submitted for that purpose.
5. Use of Information
We use your information, including your personal information, for the following purposes:
A. Providing and Improving Our Services and Game. To provide and maintain our Services and Game; to provide troubleshooting; to improve our Services and Game; to develop new features, products, or services; to perform technical operations, such as updating software; and for other customer service and support purposes.
B. Marketing and Communications. To communicate with you about your account and use of our Services via email and push notifications, including to send you product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. Please see the Your Choices section for more information about how to change your communications preferences.
C. Research and Analytics. To better understand how users access and use our Services and play our Game, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop additional products, services and features.
E. Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
F. General Business Operations. Where appropriate for the administration of our general business, accounting, recordkeeping and legal functions. As part of our routine business administration, such as employee training, compliance auditing and similar internal activities.
6. Disclosure of Information
In general, we may share your information, including personal information, as follows:
A. Users. User scores, achievements and competition results, as well as username and other user activity within the Game may be viewable by other users, such as participation in competitions. Users may also choose to share a game or competition on their personal social media accounts.
B. Service Providers. We may disclose the information we collect from you to service providers who perform functions on our behalf.
C. Business Transfers. We may disclose your information to another entity in connection with an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer, including during negotiations related to such transactions.
E. Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
F. Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for research, compliance, or other purposes.
7. Analytics and Tracking
A. Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through the Services for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services and play the Game, while others allow us to track your activities in our Services and the Game.
B. Local Storage Objects. We use local storage objects to collect and automatically store information to the local / cached data repository on your mobile device regarding your use of our Services and your preferences, which we use enhance your experience on our Services and the Game.
8. European and California Users
If you are a citizen of the European Union (“EU”) or the state of California, you may have some or all of the following rights with respect to our processing of your personal data:
A. Updating Your Information. If you would like to update personal information that you have provided to us, you can do so by accessing your Account and editing your profile.
B. Marketing Communications. You can opt-out of receiving marketing communications from us by clicking “unsubscribe” in any marketing email communications we send you, or by sending an email to email@example.com. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.
C. Additional Rights for the EEA and Certain Other Territories. If you reside in certain territories (such as the European Economic Area), you may have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with the GDPR. We may need to retain certain information for record-keeping purposes, legal purposes, and/or to complete transactions that you began prior to requesting any deletion. You can contact our Data Privacy and Protection office by sending an email to firstname.lastname@example.org.
D. Right Not to Provide Consent or to Withdraw Consent. We may seek to rely on your consent in order to process certain personal information and to render the Services. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect any actions based on consent before its withdrawal.
E. Right of Access. You may have the right to access the personal information that we hold about you.
F. Right of Erasure and Right to be Forgotten. In certain circumstances, you may have the right to the erasure of personal information that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).
G. Right to Object to Processing. You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications.
H. Right to Correct. You may have the right to require us to correct any inaccurate or incomplete personal information.
I. Right to Restrict Processing. You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is not accurate or lawfully held).
J. Exercise of Rights. If you would like to exercise any of the above rights, please contact email@example.com and firstname.lastname@example.org so that we may consider your request under applicable law. To protect your privacy and security, we may take steps to verify your identity before complying with the request. You also have the right to lodge a complaint to your local data protection authority at: https://edpb.europa.eu/about-edpb/board/members_en
K. California Privacy Rights. As a California resident, you may be ableCivil Code section 1798.83 requires us to exercisedisclose to our California customers, upon request, the following rights (subject to certain limitations at law):
1. The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
(a) The specific pieces of personal information we have collected about you;
(b) The categories of personal information we have collected about you;
(c) The categories of sources of the personal information;
(d) The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
(e) The categories of personal information we have sold and the categories of third parties to whom the information was sold; and
(f) The business or commercial purposes for collecting or selling the personal information.
2. The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions (please note that we may be unable to provide you with access to our services if you choose to delete certain personal information, but we will always let you know if that is the case).
3. The Right to Opt Out of Personal Information Sales to third parties now or in the future.
4. You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
6. Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California. In order to verify your identity, we will generally either require the successful authentication of your membership, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your email, address, and phone number.
7. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
8. In certain circumstances, California residents are permitted to use an authorized agent to submit requests to know or delete personal information on their behalf through the designated methods set forth in this Notice, where we can verify the authorized agent’s authority to act on their behalf by:
(a) receiving a power of attorney valid under the laws of California from the consumer or their authorized agent; or
(b) receiving sufficient evidence to show that the consumer has provided the authorized agent signed permission to act on their behalf; verified the consumer’s own identity directly with us pursuant to the procedures set forth herein; and directly confirmed with us that the consumer provided the authorized agent permission to submit the request on their behalf.
9. California’s Civil Code Section §1798.83 provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please contact us at email@example.com and firstname.lastname@example.org and provide your contact information to be added to our suppression list.
9. Account Deletion.
After receiving your request to delete your account in accordance with our Terms of Service, we will make reasonable efforts to ensure that all of your personal information stored in databases we actively use to operate the Services will be updated, corrected, changed, or deleted as appropriate, as soon as reasonably practicable. However, we reserve the right to retain in our archival files any information we remove from or change in our active databases, subject to any obligations under any applicable law. Where permissible, we may retain such information to resolve disputes, troubleshoot problems, and enforce our Terms of Service, consistent with the Federal Trade Commission’s “privacy by design” recommendations to retain data until the data has outlived its legitimate purpose and any anti-money laundering/know-your-customer regulations that may be applicable to us. In addition, it may not be technologically possible to remove every record of the information you have previously provided us, as a copy may exist in a non-erasable form that will be difficult or impossible for us to locate.
10. Your Choices
We may send periodic informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.
Our Services and Game are for a general adult audience and are not designed for minors under 18, and we do not intentionally collect information on our Services or Game from those we actually know are under 18. If we discover that a minor under 18 has provided us with personal information, we will delete such information from our systems.
12. Changes to this Policy
13. Contact Us.
If you have questions or concerns about the privacy aspects of our Services, Game, or anything else, or would like to make a complaint, please contact us by email at email@example.com