"Personal Information" is information that identifies you as an individual or relates to an identifiable individual. The Website and Services collect Personal Information, including: (i) name; (ii) email address; (iii) country; (iv) username and password;(v) social media handle; (vii) IP address (we may also derive your approximate location from your IP address); and (viii) in-game activity, such as transactions therein.
COLLECTION OF PERSONAL INFORMATION
We and our service providers collect Personal Information in a variety of ways, including:
Through the Website and/or Services, for example, when you register an account to access the Website and/or Services, complete a survey, apply to participate in our play-to-earn games on the Website and/or other promotion or, when you contact customer support. We may also receive your Personal Information from other sources, for example, third party payment providers.
USE OF PERSONAL INFORMATION
We and our service providers use Personal Information for the following purposes:
Providing the functionality of the Services and fulfilling your requests: (i) to provide the Services' functionality to you, such as arranging access to your registered account, completing your transactions, and providing you with related benefits, special promotions, or customer service; (ii) to respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about our Services; and/or (iii) to send administrative information to you, such as changes to our terms, conditions, and policies.
We will engage in these activities to manage our contractual relationship with you and/or to comply with legal obligations to which we are subject to: (i) providing you with our marketing materials and facilitating social sharing; and/or (ii) to send you marketing related emails, with information about our Services, new products, and news about Quiiiz.
Such activities will be engaged subject to your consent or where we have a legitimate interest, by analyzing Personal Information for business reporting and providing personalized services to: (i) analyze or predict our users' preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services: (ii) improve our understanding of your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests: and (iii) improve our understanding of your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law. Allowing you to participate in sweepstakes, contests, or other promotions: (i) we may offer you the opportunity to participate in a sweepstakes, contests, or other promotion; (ii) some of these promotions have additional rules containing information about how we will use and disclose your Personal Information, which we recommend you read before choosing to participate.
We use this information to manage our contractual relationship with you, by: (i) aggregating and/or anonymizing Personal Information. We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, provided that it no longer identifies you or any other individual; (ii) accomplishing our business purposes: (a) for data analysis, for example, to improve the efficiency and quality of our Services; (b) debug, identify and repair errors that impair the intended functionality of our Services; (c) for audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements; (d) for fraud prevention and fraud security monitoring purposes, for instance, to detect and prevent cyberattacks or attempts to commit identity theft; (e) for developing new products and services; (f) for enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures; (g) for identifying usage trends, for example, understanding what parts of our Services are of most interest to our users; (h) for determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and (i) for operating and expanding our business activities, by understanding which parts of our Services are of most interest to our users so we can focus our efforts on meeting our users' interests.
DISCLOSURE OF PERSONAL INFORMATION
OTHER USES AND DISCLOSURES
We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so to: (i) comply with applicable law and regulations, which may include laws outside your place of residence; (ii) cooperate with public and government authorities; (iii) respond to a request or to provide information we believe is necessary or appropriate. Note that these may include authorities outside your place of residence; (iv) cooperating with law enforcement, such as, we respond to law enforcement requests and orders or provide information we believe is important; (v) for other legal reasons, such as enforcing our terms and conditions, and to protect our rights, privacy, safety or property, and/or that of our affiliates and subsidiaries; (vi) in connection with a sale or other business transaction, such as to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
"Other Information" means any information that does not constitute Personal Information, which does not directly or indirectly identify you as an identifiable individual.
Collection of Other Information
Uses and Disclosures of Other Information
Unless we are legally required otherwise, we may use and disclose Other Information for any purpose. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as set forth in this Policy. In some instances, we may combine Other Information with Personal Information, which we will treat such combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. However, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contacting Us" section below.
CHOICES AND ACCESS
You are free to make choices regarding our use and disclosure of your Personal Information for marketing purposes. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking the unsubscribe link in such email.
We will comply with your request(s) as soon as reasonably practicable. However, do note that if you opt out of receiving marketing-related emails from us, we will remain entitled to send you important administrative messages, from which you cannot opt out.
How you can access, change, or delete your Personal Information
If you would like to request to access, correct, update, removed, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the "Contacting Us" section below. We will respond to your request consistent with applicable law. In your request, make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information removed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we retain the right to verify your identity before implementing your request, should we find this to be necessary. We will comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such promotion).
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.
The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and provide the Services to you (for instance, for as long as you have an account with us or keep using the Services); (ii) whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Website and/or Services you understand that your information will be transferred to countries outside of your place of residence, which may have data protection rules that are different from those of your place of residence. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
ADDITIONAL INFORMATION REGARDING THE EEA AND THE UK
Some non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these "specified countries" is available at: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en) . For transfers from the EEA or the UK to countries not considered adequate by the European Commission or the UK government (as applicable), we have put in place adequate measures, such as standard contractual clauses adopted by the relevant authority to protect your Personal Information.
Unless we specifically request, we ask that you do not send us, and do not disclose, any sensitive Personal Information (such as, social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership), on or through the Website and/or Services or otherwise to us.
THIRD PARTY PAYMENT SERVICE
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
ADDITIONAL INFORMATION REGARDING THE EEA AND THE UK
You may lodge a complaint with a data protection authority for your country or region where you have you reside or where your place of work is or where an alleged infringement of applicable data protection law occurs. A list of European Economic Area (EEA) data protection authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
ADDITIONAL INFORMATION REGARDING CALIFORNIA
Pursuant to the California Consumer Privacy Act of 2018 ("CCPA"), we are providing the following additional details regarding the categories of Personal Information that we collect, use, and disclose about residents whose residence is in California. This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role with us.
Collection and Disclosure of Personal Information
Note that we disclose to our affiliates and subsidiaries, service providers, business partners, joint marketing partners, contest sponsors and/or legal authorities the following categories of Personal Information about users whose place of residence is California, as well such categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months: (i) Identifiers, such as username, contact information, government-issued ID, IP address and other online identifiers; (ii) Personal information as defined in the California customer records law, such as name, contact information and government-issued ID; (iii) commercial Information, such as transaction information and purchase history; (iv) Internet or network activity information, such as interactions with our online properties; (iv) Geolocation Data, such as approximate location derived from IP address; and (v) Audio/Video Data. Audio, electronic, and similar information.
We do not "sell" and have not "sold" Personal Information for purposes of the CCPA in the last 12 months.
Sources of Personal Information
As set forth above, we collect these categories of Personal Information from you and from third party providers, when they share the information with us.
Use of Personal Information
As set forth above, we use these categories of Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including using Personal Information to: (i) fulfill your requests and respond to your inquiries; (ii) develop, improve, repair, provide and maintain our products and services; (iii) personalize, advertise, and market our products and services; (iv) allow you to participate in sweepstakes, contests or other promotions; (v) conduct research, analytics, data analysis, data aggregation, and data anonymization; (vi) maintain our property and our records, and undertake quality and safety assurance measures; (vii) conduct risk and security control and monitoring, and detect and prevent fraud; (viii) perform identity verification, accounting, audit, and other internal functions, such as internal investigations and record-keeping; (ix) carry out corporate transactions, such as mergers, joint ventures or acquisitions; and (x) comply with law, legal process, and internal policies, and exercise and defend legal claims.
Individual Rights and Requests
If you reside in California, you may request that we disclose to you the following information covering the 12 months preceding your request: (i) the categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information; (ii) the specific pieces of Personal Information we collected about you; (iii) the business or commercial purpose for collecting Personal Information about you, the extent applicable; and (iv) the categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.
Delete Personal Information we collected from you
To make a request for the disclosures or deletion described above, please contact us at firstname.lastname@example.org, or through the option inside the application setting. We will verify and respond to your request consistent with applicable law, considering the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as email address, in order to verify your identity to protect against fraudulent requests. If you make a deletion request, we may ask you to confirm your request before we delete your Personal Information.
You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.
If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which may include: (i) proof of your registration with the California Secretary of State to conduct business in California; (ii) proof of a power of attorney from the resident pursuant to Probate Code sections 4121-4130; and (iii) signed permission that the resident has authorized you to make a request on the resident's behalf. If you are an authorized agent and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to: (a) verify the resident's own identity directly with us; or (b) directly confirm with us that the resident provided you permission to make the request.
Last Updated: September 21, 2023