Privacy Policy

Challenger Interactive, Inc. Privacy Policy Last Update Posted: February 28, 2018

Introduction
Challenger Interactive, Inc. (“Challenger,” “we,” or “us”) understands that people who use Challenger’s Services (“you” or “users”) value privacy. This Privacy Policy describes how we collect, use, process and share information that we collect about you on Challenger’s website located at www.playchallenger.com (the "Site"), through our software, including any Challenger application programming interfaces, or other features, tools, materials, or other services (including co-branded or affiliated services) offered from time to time by Challenger or its affiliate companies (collectively, the “Services”). Challenger provides this Privacy Policy to help you make an informed decision about whether to use or continue using the Service
This Privacy Policy should be read in conjunction with our Terms of Use and End User License Agreement (“Terms”). By downloading or accessing the Services, or interacting with our Site, you agree to the use of your information in accordance with this Privacy Policy. If you have any concerns about providing information to us or it being used as described in this Privacy Policy, you should not use the Services.
Your use of the Services and any information you provide through that use remains subject to the terms of this Privacy Policy and our Terms, as each may be updated from time to time. As set out in our Terms, you must be at least 18 years old to access and/or use our Services. We do not knowingly collect personal data about children under the age of 13.
Any questions, comments or complaints that you might have should be emailed to support@playchallenger.com or forwarded in writing to:

Challenger Interactive
7040 Avenida Encinas, Suite 104_433
Carlsbad, CA 92011

Information Challenger Collects
Information you provide. You provide certain personal information to Challenger when you choose to participate in the various activities on and through our Services, such as registering for an account, downloading the Services, running the Services, posting messages, comments, and ideas, taking advantage of promotions, responding to surveys or subscribing to newsletters or other mailing lists. The personal information we collect from you generally may include: your name; email address; postal mailing address; telephone number; date of birth; PayPal, credit card billing information, or other payment processing information; contacts you choose to submit; profile photo; username; gaming identities; location; your preferences; submissions to various competitions and promotions; responses to surveys; communications sent to us by you; your subscriptions to newsletters and services offered by us; and any other information you submit to Challenger when choosing to participate in various activities on the Service. We also collect and process information about your use of our Services and your interaction with video games played while running our Services. This can include information about your device, your location, your interaction with other Challenger users, your gameplay, your online status, your use history, your content, and your purchases.
Identity verification. In addition to the above, we may need to verify your identity in order for you to use some aspects of the Service. For purposes of verification, we may also collect the following personal information from you: Social Security Number; passport information; driving license information; other identification documents; permanent and temporary address; tax-related information; and other information as may be required to verify you in accordance with applicable laws and regulations.
Devise and usage information. We may automatically collect certain information about the computer or devices (including mobile and gaming devices and consoles) you use to access the Site and Services. For example, we may collect and analyze information such as (a) IP addresses, geolocation information, unique device identifiers including mobile advertising identifiers and other information about your mobile phone or other mobile device(s) (such as IDFA or Android Ad ID, browser types, browser language, operating system, hardware type, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Site and Services, such as: referring and exit pages and URLs, platform type, clicked items, interaction with advertisements, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, mouse hover including location and time spent on each area of the page, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.

Location information
We may collect different types of information about your location, including general information (e.g., IP address, ZIP code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to detect eligibility rules violations or customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in downtown San Diego, the Services may be customized with downtown San Diego-specific information and advertisements. In order to do this, your location information may be shared with our agents, vendors or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer's instructions for further details.
Information from third parties. We may obtain additional information about you from third parties such as marketers, partners, researchers, social networks, data services companies (e.g., for data enhancement) and others. We may also obtain information from third-party services regarding your use of such services, including about your use of the video games played while running our Services. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or services we provide. In addition, if you choose to log in, access or otherwise connect to Challenger, or contact Challenger, through a social networking service (such as Facebook), we may collect your user ID and user name associated with that social networking service, as well as any information you make public using that social networking service. We may also collect information you have authorized the social networking service to share with us (such as your user ID, public profile information, email address, birthday, friends list, and pages you have "liked").

Cookies information
When you visit the www.playchallenger.com website or use the Services, we may use cookies or other similar tracking technologies to (a) store your username and password; (b) monitor and analyze the usage of our site and Services by collecting the information discussed in section 2.3 above; (c) customize the Site or Services to your explicit and inferred preferences; (d) automatically update the Services on your system; (e) tailor advertising displayed by the Site or Services, as well as advertisements that may be displayed on other websites or mobile applications; and (f) monitor the effectiveness of marketing campaigns. which may enable us or others to uniquely identify your browser. Challenger uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser help file directions. Session cookies are temporary and typically disappear after you close your browser.
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser's toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Site or Services, and the advertisements you see may not be as relevant to you. We may also use Flash cookies. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove Flash cookies. To learn more about how to manage Flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel. Please note that limiting third-party cookies through your browser controls will not necessarily opt you out of first- or third-party interest-based advertising, as some technologies (including those we or our partners may use) may not respond to these browser controls. To opt-out of interest-based advertising that is enabled by many industry platforms and providers (including much of the advertising described in this section), please see the choices we have described in Sections 6.2 and 6.3.

Log file information
When you use our Service, our servers may automatically record certain information that your device sends whenever you visit any website and use certain apps. These server logs may include information such as your web or app request, Internet Protocol ("IP") address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.
Clear GIFs information. When you use our Service, we may employ technology such as "clear GIFs" (a.k.a. Web Beacons) which are used to track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.

Collection across multiple devices
Sometimes, we (or our service providers) may use the information we collect—for instance, log-in credentials, IP addresses, hashed email addresses, and unique mobile device identifiers—to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, video game devices or consoles, or computers), or work with providers that do this, in order to offer the Services, better tailor content, features, and advertising, and provide you with a seamless experience across the devices you use to access the Services.

How Challenger Uses Your Personal Information
-We use your personal information to operate, maintain, and provide to you the features and functionality of our Services, including but not limited to: providing you with our Services; processing and responding to inquiries; personalizing your use of the Services, alerting you to new features, special events, products and services, or certain third-party products or services in which we think you will be interested; enforcing the legal terms that govern your use of the Services; providing customer service support; maintaining records; and investigating and protecting the integrity of Challenger’s Services.
-We may use your information (both personal and non-personal information) to send you marketing and advertising content, including sending you advertising through multiple channels, such as direct mail, email, push notifications and display media. We may send you advertising or content regarding our products and services, or products and services that we market on behalf of another company, such as a video game developer, e-sports league, or other entity. If you want to stop receiving promotional materials, you can go to your account settings once you have logged in to the Challenger Services or follow the unsubscribe instructions at the bottom of any email from us. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.
-We may use your information to communicate with you about: our products and services in which you may be interested provided that you have not requested otherwise; newsletters and information for which you have signed up; and non-marketing or administrative purposes (such as notifying you of major changes to the Services or for customer service purposes or communicating)
-We use your information: to optimize and improve the quality of our Services; to create new features, promotions, functionality, and services such as by storing, tracking, and analyzing user preferences and trends; and to understand the usage trends of our users.
-We also use cookies, clear gifs, log file information, and mobile app information such as device identifiers for purposes such as (a) remembering information so that you will not have to re-enter it during your visit or the next time you visit our Service; (b) providing custom, personalized content and information; (c) monitoring the effectiveness of our marketing campaigns; (d) monitoring aggregate metrics such as total number of visitors, pages viewed, etc.; and (e) tracking your entries, submissions, and status in promotions, sweepstakes, and contests. You can learn more about how these technologies are used in the Section below, Third Party

Advertising and Analytics
We may anonymize, de-identify, or aggregate your information for any legitimate business purposes, including for reporting and research, analysis, or advertising. Such anonymized and/or aggregated data does not personally identify you. Sometimes, this information may be used to target more relevant content or offers to you across different devices – for instance, we may provide you with offers and content on your mobile device, based on your web-based activity. Our use of anonymized, de-identified, or aggregate information is not subject to any restrictions under this Privacy Policy.

When Challenger Discloses Information
We may disclose the information we collect or receive from you to our subsidiaries, affiliated companies, agents, or other businesses, or service providers who process your information on our behalf in order to provide or operate the Services or otherwise carry out your instructions. For instance, these entities may have access to your information for purposes including (but not limited to) billing and accounting, fulfilling orders or other user requests, hosting, analytics, maintenance, security, marketing, promotional and email services, customer and technical support, and for the purpose of accepting deposits and paying withdrawals and processing such information on our behalf, and in each case, may use the information to make improvements to the services they provide to us. Our agreements with these service providers limit the kinds of information they can use or process and require them to use reasonable efforts to keep your personal information secure.

When you choose to share information with social media services about your interactions with Challenger by, for example, connecting your social media account to our Services, then Challenger may share your personal information and information about your use of our Services with such social media sites. Please make sure to read the terms and privacy statements of such sites prior to connecting to our Services in this way.
In the event that you win a promotion run by us, we may be required to either publish or make available upon request your name and county in accordance with applicable legislation.

Where you post personal information about yourself through our Services to public areas of our Services, you acknowledge and agree that this personal information will be publicly available.
We may publish and make publicly available a profile page about you that includes your username, the video games your play, your state and country of residence, the date you became a member, your stats from previous contests, a score comparing you to other Challenger users, and any information you post to public areas of our Services, including comments and pictures.

When you participate in a contest, we may publish your username and, if you uploaded one, your profile picture on a list of the contest participants, along with a link to your profile page.
In the event that you win a prize we may use your personal information (such as your name, username, state and country of residence, games played, gaming identities, and photos) in connection with publicity purposes.
We may share your personal information with selected third parties for their commercial or marketing use. We also may share personal information in other situations with your consent (including as set out in this Privacy Policy).

In addition, we may disclose to third-parties various types of your information for targeted online or mobile advertising, as further described in the Section titled “Third Party Advertising and Analytics.”
We may disclose to others anonymized, de-identified, or aggregated information about you. Our disclosure of anonymized, de-identified, or aggregate information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

Challenger reserves the right to: disclose personal information that we believe, in good faith, is appropriate or necessary to enforce this Privacy Policy, our Terms, or any other agreement with you; take precautions against liability or fraudulent, abusive, or unlawful uses; to investigate, respond to, and defend ourselves against third-party claims or allegations; to respond to court orders, judicial or other official government requests, subpoenas, or warrants in the manner legally required; to comply with U.S. state and federal laws and regulations, including but not limited to sharing with appropriate tax authorities, or other applicable laws around the world (for example, in the country of your residence); to protect the security or integrity of our Site or Services; to respond to your requests for customer service; to report violations of Challenger’s eligibility rules to third parties; and to protect the rights, property, or safety of Challenger, our employees, our users, or others.

In the event that Challenger is involved in (or is contemplating) a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, or other change of control, there may be a disclosure of your personal information to another entity related to such event.

Your Choices
Challenger will process your personal information in accordance with this Privacy Policy, and as part of that Challenger provides you with certain choices about how we process your personal information. These choices are set out below.

You may decline to share certain information with Challenger, in which case Challenger may not be able to provide to you some of the features and functionality of our Services.
You can access and update certain personal information Challenger holds about you at any time by logging into your account via the Services. You can update your marketing preferences and whether or not you would like us to send you newsletters in your account. You can also unsubscribe to marketing emails and newsletters by using the 'unsubscribe' feature in the communication. For other requests to review, update, delete, or otherwise limit Challenger’s use of information that you have provided directly to us, you may contact support@playchallenger.com.

We may occasionally send display media to you, in a targeted way, whether through web or mobile browsers or mobile applications. You may opt out of many third parties that support and send this type of targeting advertising by going to aboutads.info, and you may learn more about this type of advertising in the below Section titled “Third Party Advertising and Analytics.” You may opt out of tracking for mobile advertising through the settings on most smartphones, and you may learn more about these settings through those mobile device platforms.

If you have a registered account, you can ask us to deactivate that account by contacting us at support@playchallenger.com. We may ask you for other information before we are able to deactivate your account. If you deactivate your account, Challenger may retain certain information about you for the activities described in this Privacy Policy, or as permitted or required by applicable law.
-Change your settings by logging in and go to Manage Notifications.
-For GDPR go to our support specific requirements.

Third Party Advertising and Analytics
Certain ads appearing on our Services are delivered by our advertising partners. When you use the Services, Challenger (or its third-party partners) may serve you with ads based on various factors such as the content of the page you are visiting, information you provide, your searches, demographic and geographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be tailored to your interests.

Third parties, including without limitation those whose products or services are accessible or advertised via the Services, may place cookies or other tracking technologies (such as mobile 'SDKs,' which function like a mobile version of a browser cookie and are embedded in mobile applications) on your computer browser, mobile phone applications, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and mobile applications and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites, mobile applications, and use of our Services. We also allow other third parties (e.g., ad networks and ad servers such as Google AdSense, DoubleClick and others) to serve tailored ads to you on the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services so that tailored ads may be delivered to you when you are using other websites and mobile applications. We also may share with third-party advertisers a hashed version of your email address, which may be identified by a service provider for purposes of delivering tailored advertising on the Services, other websites, and/or mobile applications.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your computer, mobile phone, or other device you use to access the Services by non-affiliated, third-party ad technology, ad servers, ad networks or any other non-affiliated third parties. Those parties that use these technologies may offer you a way to opt-out of ad targeting as described below. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver interest-based advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out link, the Digital Advertising Alliance's (DAA's) Consumer Opt-Out link, or TrustArc's Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs. You may also use the links available in advertisements that appear in the Services and learn more about our advertising practices through the About Our Ads link that may be available through the Services.

If you have a Google account, we may use Google Analytics to display advertising to you. You can opt-out of Google Analytics for display advertising or customize Google display network ads by visiting the Google Ads Settings page. You will need to log in to Google via the Sign In link if you are not already logged in when you visit that page.

Please note that to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt-out of tailored advertising. In that case, the ads will just not be tailored.
You can also opt-out of 'cross-app' advertising -- interest-based advertising that is associated with your use of our or other mobile applications. To do so, please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. (We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each mobile platform, not us.). For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

We may work with platform providers who serve advertising across devices. For instance, we may want to reach our web-based customers when they are on their mobile devices. This is done, generally, by correlating common attributes (such as IP addresses, other browser or device information or hashed email addresses) across devices, to infer a common identity across multiple channels. To opt-out of this type of advertising, you can do so by opting out of each separate device or browser, as we have described above.

California Do-Not-Track Disclosure Requirements.

We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide above the Network Advertising Initiative's Consumer Opt-out link, Digital Advertising Alliance's Consumer Opt-Out Link, TrustArc's Advertising Choices page, and the Google opt-out link information in Sections 6.2 and 6.3. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.

Information Security
We are committed to protecting the security of your personal information. We implement a variety of administrative, technical, and physical security measures, technologies, and procedures to help protect your personal information from unauthorized access, use, destruction, alteration, or disclosure. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology.

Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot guarantee that information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.
We will keep your information for as long as we consider necessary for the purposes described above, or as long as the law allows.
To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your email address, name, address, telephone number and/or password) to verify your identity before granting you profile access or making corrections.
You should ensure your password is kept secret at all times. You will be responsible for maintaining the secrecy of your password and account information.
Challenger stores your data on servers located in the United States and elsewhere.

Your California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their ‘personal information’ (if any, and as defined under applicable California law) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to support@playchallenger.com.

No Rights of Third Parties
This Privacy Policy does not create rights enforceable by third parties.

Children’s Privacy
As required by our Terms, Challenger’s Services are not intended for persons under the age of 18. By using the Services, you hereby represent that you are at least 18 years old. IF YOU ARE UNDER 18 YEARS OF AGE, YOU MAY NOT USE OR ACCESS THE CHALLENGER SERVICES AT ANY TIME OR IN ANY MANNER.

Links to Third Party Websites and Services
We may provide links to third party applications, services or websites from our Site or Services (including advertising that may link to a third party). You understand that when you click on these links any data which you provide afterwards is subject to that third party’s privacy policy and not to our Privacy Policy. We can take no responsibility for the content, safety, privacy or security of any third party application, service or website.

Changes and Updates
This Privacy Policy may be revised periodically to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will post the updated Privacy Policy on our Site and will include a "Last update posted" date. Please revisit this page to stay aware of any changes. If a revision to this Privacy Policy, in our sole discretion, is material, we will notify you by contacting you through the email address associated with your account. Your continued use of the Services following the posting of changes to this Privacy Policy will mean you accept those changes.

Contact Information: Please contact Challenger with any questions or comments about this Privacy Policy by emailing support@playchallenger.com.