🔍Privacy Policy

Last Updated: [January 30, 2023]

This Privacy Policy (“Policy”) describes how PlayEstates, Inc. and its affiliates (collectively, “PlayEstates”, “we” “us”, “our”) collects, uses, and discloses information related to our customers and prospective customers, and users of any domains or subdomains of our website at http://www.PlayEstates.com (the “Site”), as well as any current or future mobile application associated with the Site or when you access or use any products, services, features, content, widgets, materials, or other tools offered by PlayEstates (collectively, the “Services”). This Policy does not govern information you choose to exchange directly with other users of the Site, including communications or transactions with other users via the Discord channel, as we have no direct control over the collection or use of this information or any websites, software applications, and any other online properties and services that do not link to this Policy. Please note that your relationship with PlayEstates is governed by our Terms of Use, available at [ https://docs.playestates.com/terms-of-use] (“Terms of Use”) and any other agreements you may enter in connection with accessing our Services, which includes applicable terms governing limitations on liability and the resolution of disputes.

This Policy is intended to inform you of:

• The types of information we collect

• How we use the information we collect

• How we share information we collect

• How we safeguard the information we collect

• Other important privacy information

By using the Services, you accept and agree to the practices described in this Policy. If you do not agree with this Policy, please do not use the Services or provide us with any Personal Information (as defined below).

Personal Information. For purposes of this Policy, unless otherwise required by applicable law, “Personal Information” means any information that identifies, relates to, describes, or is reasonably capable of being associated, linked or linkable with a particular individual or household, including any information that is subject to applicable data protection laws.

Individual rights. Please see the Your Data Rights section below for a description of the choices we provide and the rights you have regarding your Personal Information. If you are a California resident, please also review the Important Additional Information for California Residents section below for information about the categories of Personal Information we collect and disclose and your rights under California privacy laws.

Collection of Personal Information

The Personal Information we collect varies depending upon the nature of the Services provided or used and our interactions with individuals.

Categories of Personal Information. While the Personal Information we collect varies depending upon the circumstances, we may collect the following categories of Personal Information (subject to applicable legal requirements and restrictions):

• Name, contact information and other identifiers: identifiers such as a name, username, account name, address, phone number, email address, online identifier.

• Customer records: paper and electronic customer records containing Personal Information.

• Device information: internet protocol (IP) address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

• Protected classifications: characteristics of protected classifications under applicable law such as race, sex, age, and disability.

• Communications: direct communication, web forms, online polls, or interactions with our blogs and posts.

• Commercial information: including records of tokens and cryptocurrency purchased, obtained, or considered, or other purchasing or use histories or tendencies.

• Usage data: internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.

• Geolocation data: precise location information about a particular individual or device, general location information (for example, your IP address may indicate your more general geographic region).

• Audio, video and other electronic data: audio, electronic, visual, or similar information such as, CCTV footage, photographs, audiovisual recordings, and call recordings.

• Profiles and inferences: inferences drawn from any of the information identified above to create a profile reflecting a resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.

Sources of Personal Information. We may collect Personal Information about individuals:

• Directly from you: such as when you create an online account with us (the “User Account”), make a purchase, or register to receive marketing and other communications from us, or contact us for customer support purposes.

• From third parties: such as affiliate and other third-party retailers that sell our products, public records, third-party providers of services to us (e.g., fraud detection, identity verification and security), consumer data resellers, social networks, joint marketing partners and affiliate companies.

• Related to your use of our Services: including information we collect automatically when you use our Site, or interact with us, or information we derive about you and your preferences or interests based on the Personal Information we collect and our interactions with you.

Information We Collect From You. We may collect Personal Information from you related to:

• Registration, accounts and profiles: when you register for a User Account with us, we collect your name and email and password; we may also collect additional information such as your preferences, location, date of birth, and payment details.

• Purchases, orders and payments: if you make a purchase or sign up for certain Services, we collect information in order to process your payment, order or refund, fulfill your order, including name, billing and shipping address and details, payment type, as well as credit card number or other payment account details (e.g., PayPal).

• Marketing and surveys: if you sign up to receive news, updates, offers and other marketing communications from us, we may collect your name, contact information, and information about your preferences. We may also collect your name, age, email address, and other information when you submit surveys or feedback to us.

• Your communications and requests: when you email us, call us, or otherwise send us communications, we collect and maintain a record of your contact details, communications and our responses.

• User content: if you post content or submit reviews and comments to us (“User Content”), we may maintain a record of your User Content, including the location, date and time of submission.

• Mobile applications: if you use our mobile Apps, we collect information on and/or through these mobile Apps, which may include (with your permission) access to your location, camera, photos and contacts, as well as permission to send you push notifications.

We do not save or store any sensitive wallet information or private keys though we may index transactions recorded on public blockchains. We do not administer or control any public blockchains.

Information We Collect or Derive About You Automatically. We may collect or derive Personal Information about your use of our Site or other interactions with us.

• Site: We and our third-party providers may use cookies, pixels, tags, log-files, and other technologies to collect information about a user from their browser or device, including, without limitation, your browser type, device type, operating system, software version, phone model, phone operating system, platform-dependent information, requested document, referring URL, date and time of your visit, clickstream data (e.g. about the pages you view, links you click and date and time stamps for your activities on our Site) and the IP address associated with your transactions in the system. This information that we collect automatically may be linked with other Personal Information we have collected. For more information, see the Cookies and Tracking section below.

• Profile and Interests: we may create profiles relating to you in order to show you the content that we think you might be interested in and reach you with more relevant ads and marketing.

• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. For more information about cookies, and how to disable them, please see the “Cookies and Analytics” Section below.

Use of Personal Information We Collect

We may use your information for any of the following purposes, including, without limitation:

• Providing support and services: including to provide our Services, operate our Site and online services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, process your payments and provide technical support; and for other and support purposes.

• Analyzing and improving our business: including to better understand how users access and use our Services and Site, to evaluate and improve our Site, Services and business operations, and to develop new features, offerings and services; to conduct surveys and other evaluations (such as customer satisfaction surveys); to monitor consumer interest in our products and Services; to troubleshoot problems that may arise on the Site; to improve the accuracy of our customer database; to increase our understanding of our customer database; to increase our understanding of our customers; and for other research and analytical purposes.

• Personalizing content and experiences: including to tailor content we send or display on our Site and other Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences. To assist in these purposes, as well as the other purposes identified in this Policy, at certain times, we create a profile relating to you in order to show you the content that we think you might be interested in and to display the content according to your preferences.

• Advertising, marketing and promotional purposes: including to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Services, products, or other information we think may interest you; and to identify potential new customers.

• Securing and protecting our business: including to protect and secure our business operations, assets, Services, network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct.

• Defending our legal rights: including to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties.

• Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business.

• Complying with legal obligations: including to comply with the law, our legal obligations and legal process, such as warrants, subpoenas, court orders, and regulatory or law enforcement requests.

• For our legitimate business interests: including where the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• To perform any contracts in place between us and you: where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

How We Share Personal Information We Collect

We do not share Personal Information with third parties for their direct marketing or similar purposes without your consent. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or services in exchange for your data.

The manner in which partners, service providers, and others with whom we share and/or disclose your information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in this case, we will only share information that is directly related to the applicable service(s). This may include the incorporation of your Personal Information into databases maintained to validate information for identity verification, including verification for anti-money laundering and “Know Your Customer” protocols.

The primary situations in which we may share your Personal Information are as follows:

• Service Providers

To operate the Services, we may share information about you as needed with our service providers, including, but not limited to, hosting providers, accountants, auditors, lawyers, consultants, advisors, and affiliates

• Affiliates

We may share information with companies closely related to us if any, – our “Affiliates” – for certain purposes under this Policy. By "Affiliate," we mean an entity that controls, is controlled by, or is under common control with PlayEstates, whether the control results from equity ownership, contract, overlapping management, or otherwise. In this context, "control" means the ability to replace the officers or directors or otherwise materially influence or control management decisions. Our Affiliates will be entitled to enjoy our rights under this Policy, and we will be responsible for our Affiliate's conduct under this Policy.

• Legal compliance

We may be required to share Personal Information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful. In addition, we may share certain Personal Information when we believe that doing so is reasonably necessary to protect the rights, property and safety of our company and/or others.

• Business transfers

We may disclose and/or transfer Personal Information as part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.

• Protect our rights

We may disclose Personal Information where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and/or to protect the rights, property or safety of PlayEstates, Inc. or our affiliates, clients, customers and/or others.

Third-Party Sites

The Site may contain links to third-party websites and may redirect you to third-party websites. These sites include, among others, service providers who may or may not have a relationship with PlayEstates. Third party websites are not under our control, and we are not responsible for any third-party websites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes, or updates. This Policy does not apply to third-party websites that are accessible through the Site, unless such website directs users or visitors to this Policy. When you click on one of these links, you will be transferred out of the Site and connected to the website of the organization or company that maintains that website. Even if an affiliation exists between the Site and a third-party website, we exercise no control over linked websites. The inclusion or access to these websites does not imply an endorsement by PlayEstates, the provider of such content or services, or any third-party website. Please be aware that when you enter a third-party website, any information you provide, including financial information, is subject to the terms of use and privacy policy of that website. We encourage you to read the privacy policies of those other websites to learn how they collect, use, share and secure your information before providing any Personal Information.

Cookies and Analytics

We use cookies, pixels, tags, and other technologies, which may be provided by third parties, on our Site to enable certain functionality and for security and fraud detection and prevention, as well as to collect usage information about our Site and the emails that we send and to personalize content and provide more relevant ads and information. We may combine the information we collect via these technologies with other information, including Personal Information.

Cookies. By placing a small file known as a “cookie” on your device, our and our third party providers’ servers passively gather information about all visitors’ use of the Site for the following purposes: statistics collection and analysis, system optimization, analytics (as described below), market research, and maintenance of user login information. The information that we and our third party providers track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the Site, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the Site), how you were directed to the Site, which specific pages you access on the Site, how long you view each page, the time and date you access our Services and the total number of visitors to the Services and any portions thereof. We, and/or our third party providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while utilizing the Services. This data helps us and our third party providers improve our respective product and services. Types of Cookies. Our Site uses four kinds of cookies: Strictly Necessary cookies, Performance cookies, Functionality cookies and Analytical cookies.

• Strictly Necessary Cookies. Strictly Necessary cookies are used for technical reasons and are necessary to enable the Site to operate efficiently so that you can navigate our Site with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Site may not operate effectively.

• Performance Cookies. Performance cookies are used to obtain statistics about the number of users of the Site and how such users interact with our Site. These cookies collect personal data that is aggregated and therefore cannot be used to ascertain an individual's identity. Such personal data allows us to improve our Site continuously and to provide users with a better online experience.

• Functionality Cookies. Functionality cookies are used to improve the functionality of the Site and make it easier to use. They help us to identify you as a repeat user of our Site and help us remember your preferences (for example, your choice of language or region), improving your user experience.

• Analytical Cookies. Analytical cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this personal data to make our Site and the advertising displayed on it (if any) more relevant to your interests. We may also share this personal data with third parties for this purpose.

To give you control, we provide you with a Cookie Consent Tool, which allows you to review the first-party and third-party cookies placed through our Site and adjust your cookie settings, including whether to accept or decline such cookies. You can access the Cookie Consent Tool by clicking the “Cookie Consent” link at the bottom of every page and modify your preferences in our cookie banner. In addition, you can manage cookies through the settings of your internet browser. You have the right to withdraw your consent to cookies at any time by clicking on the Cookie Consent link and modifying and saving your preferences. In the settings of your Internet browser you can choose which cookies to accept and reject. Please be aware that if you decide to disable or block cookies, parts of the Site may not function correctly, or at all.

The following websites provide useful information about cookies, and may permit you to control the use of cookies by certain third parties:

• http://www.aboutads.info/choices/, if you are based in the US

• http://www.youronlinechoices.eu or http://www.allaboutcookies.org, if you are based in the EU

Log files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version and internet browser type and version. This information is gathered automatically and stored in log files.

Pixel tags and embedded script (aka clear GIFs and web beacons). Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixel tags are embedded invisibly on web pages. We may use these, in connection with our Site to, among other things, track the activities of the users of our Services, improve ads, personalize and manage content, and gather usage information about our Site. We may also use these in HTML emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third-Party Analytics Tools. Our Site uses automated devices and applications operated by third parties, such as Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and you can opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track Requests. Certain state laws require that we indicate whether we honor “Do Not Track” settings in your browser. We adhere to the standards set out in this Policy and do not monitor or follow any Do Not Track browser requests.

Interest-based Advertising:

We work with third-party ad networks, channel partners, affiliates, measurement services, analytics and others (“Third-Party Ad Companies”) to display advertising on our Services, and to manage or measure our advertising on third-party sites, social media platforms, mobile apps and online services, as well as to send you promotional materials or offers via email or direct mail. We and these Third-Party Ad Companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these Third-Party Ad Companies use this information to provide you more relevant ads and content and to evaluate the success of such ads and content.

Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

How We Safeguard Your Personal Information

Security Systems and Processes: We have put in place security systems designed to prevent unauthorized access to or disclosure of Personal Information, and we take all reasonable steps to secure and safeguard this information, including:

• We use industry-standard encryption technology for any information we store;

• PlayEstates employees are required to acknowledge that they understand and will abide by this Policy with respect to the confidentiality of Personal Information;

• Where applicable, companies that we do business with agree to apply similar safeguards to Personal Information;

• We provide access to our databases containing Personal Information on a need-to-know basis only;

• We use automated tools to monitor network traffic to identify unauthorized attempts to upload information, change information, or otherwise seek to "hack into" our systems.

Our security systems are therefore structured to deter and prevent hackers and others from accessing the information you provide to us. However, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your Personal Information safe, such as choosing a strong password and logging out of your User Account and closing your web browser when finished using the Services. Due to the nature of Internet communications and evolving technologies, we cannot provide, and we also disclaim assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

CHILDREN’S PRIVACY

Our Site is not directed to children under the age of 18, and PlayEstates does not knowingly collect or maintain Personal Information online from children we actually know at the time of collection are under the age of 18. Should we discover that we have collected Personal Information online from a child who is under 18, we will promptly delete that Personal Information. If you have concerns over the collection of children’s Personal Information on the Site, please contact us at the information provided in the Contact Us section below. Although our Site is not directed to children under the age of 18, if your child uses our Services and we learn that we’ve collected the Personal Information of a child under the age of 18, we will take reasonable steps to delete the personal data. This may require us to delete the account for that child.

Opting Out of Communications.

If you wish to stop receiving marketing or promotional communications or to opt-out of the use of your information for the purposes described in this Policy, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language), in those communications. You can also contact us at [e-mail] to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our Terms of Use or this Policy. Please understand that you will not be allowed to opt-out of certain communications required to comply with applicable laws, rules, and regulations, or other legal and related notices concerning your relationship to the Site.

Updating or Deleting Personal Information

All users may review, update, correct or delete the Personal Information furnished by a user by contacting us at [e-mail]. If you request, we will take reasonable steps to remove your Personal Information from our databases. Please understand, however, that certain Personal Information may remain in our databases following the deletion of your account pursuant to our data retention policy.

Data Retention Period

We retain information we collect for as long as you use the Services or as necessary to fulfill the purposes for which it was collected, such as providing our Services, resolving any disputes, establishing legal defenses, enforcing our agreements, and complying with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Policy Changes and Updates

Each time you visit our Site or use our Services, the current version of this privacy Policy will apply. When you use our Site or the Services, you should check the date of the last update to the Policy (which appears at the top of the Policy) and review any changes since the last version. Our business changes frequently and this Policy is subject to change from time to time. Unless stated otherwise, our current Policy applies to all information that we have about you. If you continue to access or use our Services after being provided with the notice of changes, you acknowledge your acceptance of the updated Policy. You are advised to review this Policy from time-to-time for any changes. Changes to this Policy are effective when they are posted on this page.

YOUR DATA RIGHTS

Depending on where you live, you may have certain rights, such as to request access to or correction of your Personal Information that we hold about you. To make a request, please email: [e-mail].

European Union and United Kingdom. The following additional information and rights only apply to Personal Information associated with users who visit the Site from the European Economic Area (“EEA”), including those based in the United Kingdom.

Data controller

PlayEstates located at [2225 Greenfield ave, Arcadia California, US 91006], acts as the data controller for the Personal Information we process in connection with the use of the Site by visitors in the EEA. If you have any questions about how PlayEstates processes your Personal Information or would like to make use of your rights as a data subject, please contact:

[William Guo, CEO, [e-mail]]

Information Rights under GDPR

Your rights with respect to your own Personal Information include the following:

• Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.

• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your Personal Information (also known as the “right to be forgotten”). This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process, when you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons that will be notified to you and because of our technology.

• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it affects your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

• Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:

  • If you want us to establish the data’s accuracy.

  • Where our use of the data is unlawful, but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format.

• Not be subject to automated decision making including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. We do not carry out this type of automated decision making in the Services.

• Withdraw Consent at any Time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• No Fee Usually Required. You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

• What We May Need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

• Time Limit to Respond. We try to respond to all requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Information Uses and Legal Bases

We will only use your Personal Information under the circumstances permitted by the law or you.

Pursuant to GDPR, we will use your personal data in one or more of the following circumstances:

Information Uses	Information Processing Legal Basis
Performance of any Contract between Us and You	Where we need to perform the contract we are about to enter into or have entered into with you.
Providing Support and Services	When it's necessary for us (or a third party) to process your personal data to: comply with obligations under a contract with you. This includes our obligations under the Terms of Use to provide the Services to you, or verify information before a new contract with you begins, Respond to your messages when you contact customer services, Spot unusual data or behavior in our logs which might indicate a bug or other issue.
Improve our Services and customization	Where it is necessary for our legitimate interests (or those of a third party) to provide or improve Services, including our interest to provide you improved and personalised Services, and where your interests and fundamental rights do not override those interests.
For Advertising, Marketing and Promotional Purposes where the law may or may not require us to collect your consent.	The law requires us to collect your consent for marketing or advertising, for example, when we use cookies to understand your interests or the law requires consent for email marketing. Where we need your consent for the information use, we will seek your prior consent. We may use your personal data for our legitimate interests and where the law does not require your consent, for example, when we use your personal data to tailor advertising to your interests, provided that your interests and fundamental rights do not override those interests.
Communication	Where you are a registered user, the information uses might be required to perform the contract with you. In other cases and where it is necessary for our legitimate interests (or those of a third party) to communicate with you and your interests and fundamental rights do not override those interests. Where we need your consent for the information use, we will seek your prior consent.
Comply with a request from law enforcement, courts or other competent jurisdictions	When we must process your personal data to comply with a law and our legitimate interest. Our legitimate interest here includes assisting law enforcement authorities to prevent or detect serious crime.
Securing and Protecting Our Business	Where it is necessary for our legitimate interests to protect our intellectual property and original content as well as to investigate and protect our Services and our users against fraud and illegal activity.
To establish, exercise or defend legal claims	Where it is necessary for our legitimate interests to seek legal advice and protect ourselves, our users or others in legal proceedings. For example, if we are involved in litigation and we need to provide information to our lawyers in relation to that legal case.
Legal Compliance	Where it is necessary to meet our legal obligations. This might be an obligation under the law of the country/region you are in.

United States Residents. US data protection laws grant California, Colorado, Connecticut, Nevada, Utah, and Virginia residents the following data rights:

• Right to Know and to Access. You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. This information is disclosed in the “Collection of Personal Information” Section of this Policy.

You also have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our users Personal Information, we are required to verify your identify before we can act on your request.

• Right to Portability. You have the right to request that we provide a copy of the personal data we have collected about you, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Once we receive your request and confirm your identity, we will provide to you a copy of your data as required under the applicable data protection laws. We may provide this data to you through your User Account with us, or via email to the email address you have provided with your request.

• Right to Delete. Subject to certain exceptions, you have the right to request that we delete any of your personal data. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify personal data not subject to one of these exceptions from our records and will direct our service providers to take similar action.

• Right to Correct. Subject to certain exceptions, you have the right to request that we correct inaccurate personal data that we have collected about you. Once we receive your request and confirm your identity, we will review your request, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information to see if we can correct the data. We may also request additional information showing that the information you want to correct is inaccurate.

• Non-Discrimination. We will not discriminate against you for exercising any of your data privacy rights.

• Exercising Your Rights. To exercise your rights described above, please submit a request by emailing us at [e-mail].

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal data. You may also make a request to know or delete on behalf of your child.

Certain data protection laws limit the ability to make a request to know to twice within a 12-month period, and allow us to charge a reasonable fee for responding to numerous requests from the same user. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal data associated with that specific account.

We will only use personal data provided in the request to verify the requestor’s identity or authority to make it.

California Residents

• Right to Opt-Out of Closing of Sale or Sharing of Personal Information. We do not sell or share your Personal Information with third parties, as those terms are defined under the California law.

• California Shine the Light. Where applicable, California Civil Code Section 1798.83 allows California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request please contact us using the information provided in the Contact Us section below.

Colorado, Connecticut, and Virginia Residents

• Right to Opt-Out. You have the right to out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. We do not process your Personal Information for (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

• Right to Appeal. If you make a request to exercise any of the above data access rights and we are unable to comply with your request, you may request to appeal our decision. To appeal any data privacy request decision, please contact us by emailing [e-mail] with the subject line “Data Access Request Appeal.” If after you complete the appeal process with us, you are still unsatisfied with our response, you may contact your Attorney General to file a complaint. Below are the contact information for the appropriate entity where you can inquire about filing an appeal:

Virginia Residents

Office of the Attorney General

202 North 9th Street

Richmond, Virginia 23219

Phone: [phone]

https://www.oag.state.va.us/

Colorado Residents

Office of the Attorney General

Colorado Department of Law

Ralph L. Carr Judicial Building

1300 Broadway, 10th Floor

Denver, CO 80203

[phone]

https://coag.gov/

Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at [e-mail] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

Utah Residents

• Right to Opt-Out. You have the right to out of the processing of the personal data for purposes of (i) targeted advertising and (ii) the sale of personal data. We do not process your Personal Information for (i) targeted advertising or (ii) the sale of personal data.

Residents of Other Jurisdictions

If you wish to exercise rights granted to you by laws of any jurisdiction other than the EU or the United States, please contact us for assistance. We will endeavor to act upon your request in accordance with applicable law. We will not discriminate against you for exercising these rights.

Contact Us

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Email address: [e-mail]

Postal address: [2225 Greenfield Ave, Arcadia CA US 91006]

You have the right to make a complaint at any time to your local data protection supervisory authority. We would, however, appreciate the chance to respond to your concerns before you approach them so do contact us in the first instance.