Privacy Policy

Effective: 9/21/2021

Here at Challenger Interactive, Inc. (“Challenger”, “we”, “us”, “our”), we work hard to build and maintain a relationship of trust with you. This Privacy Policy (“Privacy Policy”) describes how we collect, use, and disclose information in connection with your access and use of all websites, applications, including the Challenger Windows Application (“Challenger App”), and other online products and services provided by us that link to this Privacy Policy, including www.playchallenger.com (and all related subdomains) (the “Site”) and related online and offline services thereto, including any services, transactions, or engagement you might have with us (collectively, the “Services”).

Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Services. If you do not agree with the Terms of Use and/or this Privacy Policy, you must refrain from using our Services. By accessing or using our Services, you agree to our use of your information consistent with the Terms of Use and this Privacy Policy. Minors (those under the age of 18 years) are not eligible to use our Services.
Please note that we process certain information on behalf of developer partners (“Partners”) who integrate our Services within their offerings (“Partner Data”). If you have any questions about a Partner’s privacy practices, please contact the applicable Partner. For more information about who is the controller of data and under what circumstances, refer to the “Data Protection Rights, Information, and Choices” section below.

PRIVACY POLICY CHANGES
This Privacy Policy is subject to change. We reserve the right to update or modify this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be made accessible through use of the Services with an updated “Last Revised” date. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Services.

INFORMATION WE COLLECT
Information You Provide To Us
We collect information you choose to share with us, including information you enter through the Services. For example, if you are a user of the Services or visitor to the Site, when you:

  • · Create an account to use the Services or request further information about the Services, we may collect contact information (such as your name, email address, phone number, and postal address), registration data (such as your username and password, date of birth, and the state or province where you are located, IP address), and account profile information (such as your gaming identities, profile photo and device id);
  • · Verify your identity, we may collect your Social Security Number, passport information, driver’s license information, permanent and temporary address, tax-related information, and other information and documentation required to verify your identity in compliance with applicable laws and regulations.
  • · Deposit funds, enter contests, and interact with the Services, we may collect information related to depositing funds (such as billing and payment processing information, including credit card, bank account, and ACH information), entering and participating in a contest, and withdrawing prizes (such as your contact information, location information, and billing and payment processing information), information related to your use of our Services and your interaction with video games played while using our Services (such as your gameplay captured via screen recording, online status, use history, content, purchases, location, and interaction with other Challenger users), as well as other information you enter through the Services (such as demographic information);
  • · Contact us with questions or for customer service, we may collect contact information (such as your name, email address, and phone number) as well as any information you provide in connection with your outreach; and
  • · Participate in promotions, events, surveys, and sweepstakes, we may collect basic contact information and any other information you provide in connection with these activities.

If you are a Partner, work for a potential Partner, or visit the Site, when you:

  • · Create an account to use the Services or request further information about the Services, we may collect contact information (such as your name, email address, business address, and phone number), business information (such as job position, function, and title, and the size, location, and needs of your company), and registration information (such as your username and password);
  • · Interact with the Services, we may collect information related to creating campaigns related to our Services, verifying your account (such as contact information, business information, including government identifiers, and third-party authentication credentials), remitting and charging amounts owed (such as financial information, including credit card, bank account, and ACH information), as well as other information you enter through the Services;
  • · Contact us with questions or for customer service, we may collect contact information (such as your name, email address, and phone number) as well as any information you provide in connection with your outreach;
  • · Participate in promotions, events, and surveys, we may collect basic contact information and any other information you provide in connection with these activities.

Screen Recording
Our Services may require use of screen recording technologies to provide certain features and functions. We collect information from you and your device that you provide in connection with and through such recording, to the extent you consent to such recording. By installing and using our application, you acknowledge and agree that (i) we may collect information from all visible windows (not just those related to the Challenger App or video game) present on your screen during the course of the screen recording, and (ii) you are responsible for providing sufficient notice to all individuals who may be recorded and obtaining any consent necessary for such recording, according to applicable laws.

Information We Collect Through Automated Means
We may automatically collect, receive, and store certain information in connection with the actions you take on the Services and in connection with use of the Services (“Device and Usage Data”). As discussed further below in the “Cookies & Similar Technologies” section, we and our service providers, may use a variety of technologies, including cookies, to assist in this information collection. For example, each time you use the Services, we automatically collect the type of web browser and operating system you use, the type of device you use (including mobile and gaming devices and consoles), your IP address, Internet service provider, unique device identifiers, device hardware specifications, other installed software and other information in accordance with your device settings and permissions. We may also collect the pages you view, referring and exit pages, the date and time of your visit, the number of clicks to, from, and within the Services, time spent on each page, usage preferences, and search terms.
In order to provide the Services, operate the contests, and assess a user’s performance in a contest, we may also collect information about the video games you play, the levels, scenarios, and rules of the games you play, your gaming identities, your interaction with other video game participants, and gameplay activity and information (such as the number of times you complete a task, the time it takes you to complete a task, and your ranking in a given video game campaign or challenge).

We may also collect different types of information about your location, including general location information (such as your IP address and ZIP code) and more specific information (such as GPS-based functionality on mobile devices used to access the Services), and we 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, service providers, 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 We Collect from Other Sources
We may collect information from other sources, such as payment service providers, Partners, analytics service providers, security service providers, survey providers, marketers, social networks, and researchers. For example, we utilize certain analytics tools to improve the Services experience for users and Partners. In addition, if you choose to log in, access or otherwise connect to Challenger, or contact Challenger, through a social networking service, we may collect your user ID and username 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”). We may aggregate the characteristics and browsing habits of users, on an anonymized basis, to provide products and services that are more tailored to users and Partners. We obtain contact and business information used to communicate with you about the Services from conferences, events, sales partners, and public records.

HOW WE USE INFORMATION
We use your information to:

  • · Provide you with the Services and information you request;
  • · Manage, verify, and authenticate your account;
  • · Engage in transactions, including contacting you about your account, billing, remitting, or charging you, and processing payments;
  • · Facilitate prize payments and fund deposits and withdrawals;
  • · Improve the Services, including customization and personalization;
  • · Provide you with effective customer service;
  • · Communicate with you about the Services and contact you with special offers, promotional information, content, publications, and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us) via mail, email, telephone, text messaging, and/or push notifications and display media;
  • · Analyze use of the Services and improve the content, functionality, and usability of the Services, enhance the user experience, and improve our business;
  • · Invite you to participate in promotions, sweepstakes, surveys and provide feedback to us;
  • · Secure the Services and investigate and help prevent fraud, security issues, and abuse;
  • · Understand, detect, and resolve problems with the Services and other issues being reported;
  • · Comply with any procedures, laws, and regulations where necessary for our legitimate interests or legitimate interests of others;
  • · Establish, exercise, or defend our legal rights where necessary for our legitimate interests or the legitimate interests of others, including the enforcement of our Terms of Use, other usage policies and agreements, and other legal terms or controls, or to engage in other legal matters; and
  • · Fulfill other requests with your consent and for any other purposes disclosed at the time you provide personal information.
    Combined information

For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

Aggregate/De-identified Information
We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties in our discretion.

LEGAL BASES FOR USE OF YOUR INFORMATION
The laws of some jurisdictions, including the European Economic Area (“EEA”) and the United Kingdom (“UK”), require that companies only process your “Personal Data” (as that term is defined in the applicable law, like the EU General Data Protection Regulation) if they have a “legal basis” (or justifiable need) for processing your Personal Data. To the extent those laws apply, our legal bases for processing Personal Data are as follows:

  • · To perform our obligations pursuant to a contract (or pending contract) with you. For example, we will process your Personal Data to comply with our Terms of Use to enter into a contract with you, and to honor our commitments in any contracts that we have with you.
  • · For our legitimate interests or the legitimate interests of others, including Partners. For example, we will process your Personal Data to: operate our business and our Services; identify and fix any issues with our Services; provide customer service; secure the Services; learn more about how our customers use the Services; perform internal analytics; improve the Services and users’ experiences; conduct marketing; provide you with certain information about new products, special offers or other information that we think you may find interesting using the email address which you have provided in accordance with applicable law; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud; engage in a business change (e.g., sale, merger); and to know the customer to whom we are providing Services.
  • · To comply with our legal obligations, such as our obligation to share data with tax authorities.
  • · With your consent. Where we rely on this basis, you may have the right to withdraw your consent at any time as described in the “Data Protection Rights, Information, and Choices” section below.

COOKIES & SIMILAR TECHNOLOGIES
To collect the information in the “Information We Collect Through Automated Means” section above, we and our service providers use web server logs, cookies, tags, SDKs, tracking pixels, localstorage and similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future.

  • · A web server log is a file where website activity is stored.
  • · An SDK is a set of tools and/or code that we embed in our applications and software to allow third parties to collect information about how Users interact with the Services.
  • · A cookie is a small text file that is placed on your computer or mobile device when you use the Services, that enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. Some cookies are placed in your browser cache while those associated with Flash technologies are stored with your Adobe Flash Player files.
  • · Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of the Services and associated advertising; and (3) access user cookie.
  • · LocalStorage is a web storage object for storing data on the client – that is, locally, on your computer. Data stored locally has no expiration date and will exist until it's been deleted.

As we adopt additional technologies, we may also gather information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). You can also manage the use of Flash technologies, including flash cookies and local storage objects with the Flash management tools available at Adobe’s website. Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services. To manage your information and consent preferences click here.

ONLINE ANALYTICS AND ADVERTISING
Analytics. We may use third-party analytics services (such as those of Google Analytics, Heap) as well as self hosted data collection services on our Services to collect and analyze usage information through cookies and similar technologies; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To manage your information and consent preferences click here.

Advertising. When you use the Services, we may display advertising to you about our products, services, and related features that we think may be of interest to you.

We work with a number of companies that assist in marketing our services to you on third party websites. These companies may collect information about online activities conducted on a particular computer, browser or device over time and across third-party websites or online services for the purpose of delivering advertising that is likely to be of greater interest to you, including about our Services, on sites and apps of third parties. These companies may use cookies and other similar technologies, often in conjunction with unique (anonymous) cookie identifiers, to collect data about your activities and interests, including the technologies described above. Some of these partners may use mobile device identifiers, such as Apple IDFAs and Google/Android Advertising IDs. Doing this allows the ad companies to recognize your computer or device each time they send you an online or mobile advertisement. In this way, the ad companies may compile information about where you, or others who are using your computer or device, saw their advertisements and measure your interaction with each ad. This information allows ad companies to deliver targeted advertisements that may be of increased interest to you. We, or our advertising partners, may use these technologies and data points (e.g., mobile identifiers, cookie identifiers, location-based data), through other services, to target advertising on other sites or mobile apps. Sometimes, these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising as well, for instance, to evaluate which ads or content our users prefer, or which are most effective. In addition, sometimes we or an advertising partner may tailor advertising to you across different devices.

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 by non-affiliated, third-party providers. As described below, these providers may offer you a way to opt-out of the collection of information that is used for our interest-based advertising to you. We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each third-party service provider, not us.
If you are interested in more information about interest-based advertising and how you can generally control cookies other tracking technologies from being put on your computer to deliver such 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. You also should use the privacy options available from these vendors:

· LinkedIn: https://www.linkedin.com/help/linkedin/answer/62931
· Google: https://www.google.com/ads/preferences
· Facebook: https://www.facebook.com/help/568137493302217

Notice Concerning Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Because of the changing state of technology and indecision within the industry regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals. Learn more about Do Not Track.

HOW WE SHARE INFORMATION
We will share your information collected from and about you in the following ways:

  • · Service Providers: We may provide access to or share your information with select third parties who perform services on our behalf, such as online hosting and maintenance, marketing and promotion design and management, management of e-commerce systems, payment processing, data storage and management, marketing and email delivery, analytics, customer service, security and fraud prevention, legal services, and identity and contact information validation.
  • · Partners: We may share information about your interaction with our Services with our Partners in relation to personalizing in-Service marketing, advertising, and integrations as well as contests incorporated with or related to their services.
  • · Business Transfers: As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, user information would likely be one of the transferred assets. If such transfer is subject to notifications or restrictions under applicable laws, we will comply with such requirements.
  • · Publicity for Winners: When you participate in a contest and win a prize, we may also publicly share your personal information (such as your name, username, state and country of residence, games played, gaming identities, and photos) in connection with publicity purposes.
  • · Comply with Laws and Protect Our Rights and the Rights of Others: We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of the Services; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property, or safety of our users or others.
  • · With Your Consent or At Your Direction: We may share information with third parties when you direct us to do so or if you have consented to additional sharing of your information (including as set out in this Privacy Policy). For example, 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 Credits, 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.

SECURITY
We recognize the importance of implementing a variety of security safeguards designed to protect the confidentiality of your information. However, no data transmission over the Internet or other network is completely secure. As a result, while we strive to protect information you transmitted on or through our Services, you do so at your own risk.

When you create an account, you may be prompted to create a username or password. If you create an account with us, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. We are not responsible for any loss or damage arising from your failure to maintain the confidentiality of your password. We urge you to change your passwords often, use a combination of letters and numbers, and make sure you are using a secure browser. If you have reason to believe that your interaction with us is no longer secure or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “Contact Us” section below.

THIRD PARTY LINKS AND FEATURES
Please be aware that third-party websites accessible or recommended through our Services may have their own privacy and data collection policies and practices. These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through these third-party links and features, nor any association with their operators. We are not responsible for any actions, content of websites, or privacy policies of such third parties. We urge you to read the privacy and security policies of these third parties.

HOW LONG WE RETAIN YOUR DATA
We will retain your information for as long as we have a business need for it or as needed to comply with applicable legal obligations. We also retain and use your information as necessary to resolve disputes, protect Challenger, our Users, and Partners, and enforce our agreements.

DATA PROTECTION RIGHTS, INFORMATION, AND CHOICES
You may have certain rights with respect to your personal information as further described in this section, in addition to any rights discussed elsewhere in this Privacy Policy. Please note your rights and choices vary depending upon your location.
Marketing Communications

You may instruct us not to use your information to contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information in the “Contact Us” section below. In commercial email messages, you can opt out by following the instructions located at the bottom of such emails. Removing your name from the email list may take a reasonable amount of time. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Additional Choices
You can also make certain choices by using the options described in our “Cookies & Similar Technologies” and “Online Analytics and Advertising” sections above.

Rights with Respect to Your Information
Depending on where you live, you may have certain rights with respect to your information. For example, under local laws, including in the EEA, UK, and Canada, you may have some or all the following rights:

  • · The right to access personal information we hold about you.
  • · The right to have any inaccurate personal information we hold about you corrected or updated.
  • · The right to object to our processing of your personal information or prevent the processing your personal information for direct-marketing purposes.
  • · The right to withdraw your consent at any time if and to the extent we are relying on consent as the basis for processing your personal information.
  • · The right to restrict the use of your personal information.
  • · The right to have the personal information we hold about you deleted in certain circumstances.
  • · The right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, with certain exceptions.

To exercise your data protection rights or to receive more details in connection with them, you can submit requests via privacy@playchallenger.com or make a request online at Data Subject Request. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

We will consider all such requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims. Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled. If you are a California resident, please see the “Privacy Information for California Residents” section below for information about your specific rights under California law.

If applicable, you may make a complaint to your local data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

Identifying the Data Controller and Processor
Data protection laws in certain jurisdictions differentiate between the “controller” and “processor” of information. In general, Challenger Interactive, Inc. is the controller of data collected in relation to your use of the Services, such as information collected or maintained in relation to a user’s account, Device and Usage Data (including, internet or other network or device activity, Services metadata, log data, location information), cookie information, and other information provided to us, except that it is the processor of Partner Data.

Automated Decision-Making
We may use automated decision-making, such as inferences drawn from our screen recording of your gameplay, where such use is necessary for the performance of the contract between Challenger and you or where you explicitly consent to our use of automated decision-making. Challenger shall implement reasonable measures to protect your rights and freedoms and legitimate interests in relation to our use of automated decision-making. You may have the right to obtain human intervention on the part of Challenger, to express your point of view as to the decision, and to contest the decision, though your right may be limited where necessary for the performance of a contract with you, such as participation in a contest. If you would like to make such a request please contact support@playchallenger.com.

Privacy Information for California Residents
California Privacy Rights
Terms used in this section and not otherwise defined have the meaning given to them under the California Consumer Privacy Act (“CCPA”).
California law requires us to provide some additional information regarding your rights with respect to your “personal information.” In many cases, if you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, unless certain exceptions apply, the CCPA allows you to request us to:

  • · Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
  • · Provide access to and/or a copy of certain personal information we hold about you.
  • · Delete certain personal information we have about you.
  • · Provide you with information about certain financial incentives that we offer to you, if any.

You also have certain rights under the CCPA not to be subject to certain negative consequences for exercising CCPA rights.
We reserve the right to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, phone number, or other information. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you or to comply with legal obligations, so we would need to either reject your request to delete the information or, if we are legally permitted to delete it, we would need to terminate our provision of the Services to you after deleting it. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please email privacy@playchallenger.com or submit online at Data Subject Request.

With regard to Partner Data, Consumers should direct requests to exercise applicable rights to the Partner on whose behalf we handle the data. If we receive a request from a User directly in relation to Partner Data, we will either alert you to redirect your request to the applicable Partner or refer that request to the appropriate Partner and await the Partner’s instructions on how to handle it.

Collection, Use, and Disclosure of Californian’s Personal Information
During the 12 months leading up to the effective date of this Privacy Policy, we collected (and continue to collect) all of the categories of information listed in the chart below and described in the “Information We Collect” section of our Privacy Policy. That section also explains the sources from which we collect information about you, including, for example, you, service providers, other users, Partners, analytics providers, cookies and tracking technologies, survey partners, and marketing partners.

The “How We Use Information” section of this Privacy Policy explains how and why we use your personal information. Generally speaking, we use your information to provide our Services, manage and verify your account, offer contests, facilitate prize payments and fund deposits and withdrawals, bill, remit, charge, and process payments, send communications, personalize the Services, provide customer service, analyze, research, develop, and improve the Services, enforce legal terms and defend our rights, investigate and prevent security issues, fraud, and abuse, comply with laws, and as described when collecting your information.

We share certain information as set forth in “How We Share Information” section and in the chart below, and we allow third parties to collect certain information about your activity, for example through cookies, as explained in the “Cookies & Similar Technologies” section. Consistent with applicable laws, we may share Aggregate/De-Identified Information, including game play history, telemetry data, user-generated content, in-app friends and connections, screen recordings, consumer profiles and preferences, age, device identifiers, and web logs, with third parties.
California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include allowing third parties to receive certain information such as cookies, IP address and/or browsing behavior for interest-based advertising or related purposes. It may also cover certain disclosures of personal information by Challenger to other entities. Although Challenger does not currently sell personal information in exchange for any monetary consideration, we may share personal information for other benefits that could be deemed a “sale” as defined by the CCPA. We also share certain information as set forth in “Cookies & Similar Technologies” section. For details on how to opt out of cookies, please see the “Cookies & Similar Technologies” section.

If you or your authorized agent would like to opt out of Challenger’s use of your information for such purposes that are considered a “sale” under the CCPA, you may do so as outlined on the following page: Do Not Sell My Personal Information. Please note that we do not knowingly sell the personal information of minors under 16 years of age.

In the 12 months since the effective date of this Privacy Policy, we made the following disclosures of personal information about California residents in addition to disclosures of identifiers, location data, gameplay data, and photos to the public for publicity purposes in the case that you participate in a contest and win a prize:

Category of personal information collected by Challenger

Categories of third parties to which the information was disclosed for a business purpose

Identifiers, such as name, username, driver’s license and passport information, Social Security Number, and other similar identifiers.

· Service providers who perform functions on our behalf, such as data storage and hosting providers, account verification providers, email and notification providers, network and system management providers, communication tools, IT support providers, CRM providers, payment providers (“Service Providers”)

· Partners

· Data analytics providers

· Advertising services

· Other individuals, services, and partners at your request or with your consent

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Contact and account registration data, such as name, email address, phone number, postal address, or other contact information.

· Service Providers

· Partners

· Data analytics providers

· Advertising services

· Other individuals, services, and partners at your request or with your consent

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Demographic information, such as interests and date of birth.

· Service Providers

· Data analytics providers

· Advertising services

· Other individuals, services, and partners at your request or with your consent

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Customer service information, such as questions and other messages you address to us and summaries or voice recordings of your interactions with customer care.

· Service Providers

· Data analytics providers

· Other individuals, services, and partners at your request or with your consent

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Business and commercial information, such as position, title, business address, business email address, phone number, size, location, and needs of your company.

· Service Providers

· Data analytics providers

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Inferences about your preferences and characteristics, such as game genre interest, hardware usage and preferences, demographics and behavioral interests.

· Service Providers

· Data analytics providers

· Advertising services

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Financial and transactional information, such as billing information and financial account information and information about your transactions with us.

· Service Providers

· Partners

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Device information and identifiers, such as IP address, browser type and language, operating system, platform type, device type, and software and hardware attributes.

· Service Providers

· Data analytics providers

· Advertising services

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Connection and usage data, such as telemetry data, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, time spent on each page, search terms, and information about network web traffic (including traffic from a specific user).

· Service Providers

· Data analytics providers

· Advertising services

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Geolocation data, such as city, state, country, and ZIP code associated with your IP address, and GPS location.

· Service Providers

· Data analytics providers

· Advertising services

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Information provided via research, surveys, sweepstakes, and/or other marketing research efforts

· Service Providers

· Data analytics providers

· Advertising services

· Other individuals, services, and partners at your request or with your consent

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes

Other information, such as any other information you choose to directly provide to us in connection with your use of the Services.

· Service Providers

· Partners

· Data analytics providers

· Advertising services

· Other individuals, services, and partners at your request or with your consent

· Entities involved in actual or potential significant corporate transactions

· Third parties for legal purposes


California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes within the meaning of that law.

Privacy Rights for Nevada Residents
Under Nevada law, certain Nevada residents may opt out of the “sale” of “covered information” (as such term is defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. We do not engage in such activity as of the effective date of this Privacy Policy. To request please visit: Do Not Sell My Information.

CHILDREN’S PRIVACY
The Services are intended for general audiences and not for children. We do not knowingly collect, maintain, or use personal information (as defined by the United States Children’s Online Privacy Protection Act) from children in the United States under the age of 13 or a European Union resident under the age of 16 without legally-valid parental consent. If you believe that we might have any such information from a child, please contact us using the information in the “Contact Us ” section below. If we discover that personally identifiable information of a child has been submitted without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

INTERNATIONAL TRANSFERS
Your personal information may be transferred to, stored in, accessed from, or processed in the United States or other jurisdictions in which we or our service providers maintain facilities. You understand that these jurisdictions may have different data protection regimes than in the country in which you are located.

Where legally required, we will use an adequate transfer method. For example, whenever we transfer your personal information from the EEA and UK to the United States, we use standard contractual clauses approved by the European Commission which give personal information the same protection it has in Europe. Where applicable, you are entitled, upon request, to receive a copy of the relevant safeguard (e.g., EC standard contractual clauses) that have been taken to protect personal information during such transfer. For a copy of the relevant safeguard please email us at privacy@playchallenger.com.

CONTACT US
If you have any questions about our Services or this Privacy Policy, or to contact our data privacy officer, please email us at privacy@playchallenger.com.