DROP-IN GAMING, INC. PRIVACY NOTICE
Last Updated March 15, 2021
This is the privacy notice (“Privacy Notice”) for Drop-In Gaming, Inc. and our affiliates and subsidiaries (collectively, “Drop-In Gaming,” “us,” or “we”). It is governed by and part of our Terms and Conditions of Use. We encourage you to read this Privacy Notice carefully to understand how we collect and use your information. We may provide additional notices about our privacy practices, each of which will be considered to form part of this Privacy Notice.
This Privacy Notice describes the collection and treatment of information through our websites, online gaming platform, mobile application, other digital properties and services, social network, and other channels we own or operate, and your communications with us by any means (collectively, the “Services”). It DOES NOT apply to information collected via a website or platform not owned or controlled by Drop-In Gaming.
This Privacy Notice also provides information specific to residents of California, Nevada, and the European Union.
By using our Services, you consent to the collection and use of your information as described in this Privacy Notice. Your use of our Services is subject to this Privacy Notice and our Terms and Conditions of Use, including its applicable limitations on damages and the provisions regarding resolution of disputes. If you do not agree with this Privacy Notice, do not use our Services.
When we say, “Personal Information,” we mean information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or device, such as:
- Identifiers (e.g., name, address, telephone number, email address, username);
- Sensitive Personal Information (e.g., birthdate, government ID, login, health information);
- Protected classification information (e.g., race, citizenship, marital status, medical condition, sex, sexual orientation, veteran or military status);
- Biometric information (e.g., voice, keystrokes, behavioral or biological characteristics);
- Internet or other similar activity (e.g., geolocation, browsing history);
- Employment-related information (e.g., current or past employment);
- Non-public educational information, including information protected under FERPA; or
- Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
Personal Information does not include (i) publicly available information (ii) aggregated information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (iii) deidentified information that cannot be easily linked back to the individual.
COLLECTION AND USE OF PERSONAL INFORMATION
Drop-In Gaming only collects and uses your Personal Information (i) when applicable, with your consent, (ii) if we have a legitimate interest in doing so, or (iii) as authorized or required by law. We only collect Personal Information as reasonable and necessary.
Categories. During the preceding 12 months, we have collected these categories of Personal Information:
- Sensitive personal information
- Biometric Information
- Internet or other similar activity
- Commercial information
Sources. As set out in more detail below, Drop-In Gaming collects Personal Information directly from you with your consent and indirectly from your use of our Services to achieve one or more legitimate interests.
We collect Personal Information directly from you, with your consent from:
- Your registration with Drop-In Gaming. When you register with Drop-In Gaming, we will collect your name, address, email, phone, gamer tags, and your date of birth. We use this information to create your player profile, verify your eligibility to use our Services, and provide you with our Services. Your player profile will show your gaming handle, gamer tags, list of friends and followers on the Services, counts and player statistics. If you link a third-party gaming account or social media account to your Drop-In Gaming account, we may receive additional Personal Information about you from the third-party account, and those account usernames will be included in your player profile. We use this information to create your account, communicate with you, and provide you with the Services.
- Your use of our Services. The Drop-In Gaming player dashboard allows you to control your player profile and certain interactions with our Services. We collect the information you choose to submit to us via the player dashboard. If you participate in our voice chat or messaging features, while participating in a game or otherwise, we may collect additional identifiers or your player identification number to verify your account and provide access to the feature. We may also create and maintain recordings or transcripts of voice chat or messaging features. By using our voice chat or messaging features, you consent to these recordings. We use this information to provide and improve our Services.
- Your Online Transactions. When you register for a gaming event, purchase merchandise, or request other transactions via the Services, we collect commercial history information related to your registration history and the transaction. We use this information to facilitate your transaction and use of the Services, and to offer you customer support. Note that Drop-In Gaming does not collect or maintain any payment information. Drop-In Gaming provides you the option to pay entry fees and receive payouts on our platform using a PCI-compliant payment processing Service Provider. We never see your payment information, and we do not process your transactions.
- Your communications with Drop-In Gaming. We will collect your name and email if you contact us by any means, whether to inquire about our Services, sign up for our email newsletters, or for another purpose. If you contact us for customer service, we will also collect your date of birth and player identification number to verify your account, and information necessary to provide you with customer support. From time to time we ask players to complete online surveys. If you choose to complete a survey, we will also collect any information you include in your responses. We use this information for the purposes stated at the time of collection, to provide you with our Services, and to communicate with you or send you direct marketing communications.
We also collect Personal Information and non-personal information indirectly from your use of the Services to achieve our legitimate interests of providing, improving, and promoting our Services. More specifically, we collect this information from:
- Your Interactions with the Services. We automatically collect details about device when you interact with the Services, like your visits to our website and use of the platform to participate in a game. The information we collect may include your (i) search queries; (ii) device information (e.g., IP address, operating system, browser type, device ID, language, mobile network information, caller ID); (iii) usage details (e.g., content engagement, transactions, traffic data, and the features or resources you access and use); (iv) stored information (e.g., metadata); and (v) geolocation. We use this information to personalize the Services to you, facilitate your use of certain features, analyze trends in the use of the Services, and detect security incidents.
Other Uses. In addition to the specific uses above, we might use also your Personal Information to:
- Monitor your compliance with any of your agreements with us.
- Protect your privacy and enforce this Privacy Notice.
- If we believe it is necessary, to identify, contact or bring legal action against persons or entities who may be causing injury to you, to Drop-In Gaming, or to others.
- Comply with a law, regulation, legal process or court order.
- Fulfill any other purpose to which you consent.
Children’s Privacy. Drop-In Gaming Services are designed for users at least 16 years of age and are only available to users who are eligible for registration and use as provided under our Terms and Conditions of Use. In no case do we permit children under 16 to register or use our Services, and we do not knowingly collect Personal Information from children under 16. If we discover that a child under 16 has provided us with Personal Information, we will delete such information from our systems. If you believe we might have any information collected online from a child under 16, or if you become aware of any unauthorized submission of information to Drop-In Gaming, please contact us at email@example.com or 866-376-7464.
DISCLOSING PERSONAL INFORMATION
Categories. In the preceding 12 months, all categories of Personal Information collected by Drop-In Gaming may have been disclosed for a business purpose to one or more of the recipients described in this section.
Recipients. Drop-In Gaming may disclose Personal Information to the following recipients:
- Service Providers. Vendors that provide us with services (collectively, “Service Providers”) may have access to your Personal Information in order to perform their contractual obligations. Our Service Providers include but are not limited to media partners, merchandise vendors, payment processors, survey providers, IT service providers, and email and data hosting providers. We prohibit our Service Providers from selling or disclosing the Personal Information we provide or using it for their own marketing purposes, and we require all Service Providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information. The type of information that we provide to a Service Provider will depend on the service that they provide to us.
- Business partners. From time to time, we may partner with third parties to offer you promotions, events, tournaments or other goods or services jointly or on behalf of the business partner. We will obtain your consent before sharing your Personal Information with our business partner for these purposes. A business partner’s collection and use of your Personal Information is subject to their privacy notice, not ours.
- Affiliates. We may disclose the Personal Information we collect to Drop-In Gaming’s business affiliates or subsidiaries. If we do disclose your Personal Information to our affiliates or subsidiaries, their use and disclosure of your Personal Information will be subject to this Privacy Notice.
- Law enforcement, and other governmental agencies, as permitted or required by law.
- Cookie information recipients, subject to their respective privacy notices.
- Other Third Parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
Aggregated and Deidentified Information. We reserve the right to share aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research or other purposes, without restriction.
YOUR PRIVACY RIGHTS
Depending on where you reside, your legal rights to control your Personal Information may include some or all of the following:
- Changing your registration.
- Changing your preferences for how and about what we communicate with you.
- Correcting, updating, and deleting the Personal Information in your account. Please note that certain legal obligations may limit or prevent our ability to fulfill these requests, and that copies of information that you have updated, modified, or deleted may remain viewable in cached and archived pages of the Site or Software for a period of time.
- Requesting access to the Personal Information we hold about you.
- Choosing whether to receive marketing communications from us.
- Controlling how the cookies we use interact with your device.
Residents of California or Nevada or residents of the European Union may be eligible to additional privacy rights, as detailed below.
Do Not Track. Do Not Track signals are signals sent through a browser informing us that you do not want to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed below.
Exercising Your Privacy Rights. Drop-In Gaming provides you the option to directly view, modify, or delete your Personal Information via the player dashboard, and you can control the data we collect automatically by adjusting your device settings or selections on your third-party accounts. If you wish to exercise your rights under applicable privacy laws beyond these methods, or if you want to express concerns, lodge a complaint or request information, please submit a verifiable Consumer Privacy Request form or by contacting us at firstname.lastname@example.org or 866-376-7464.
We endeavor to respond to a verifiable Consumer Privacy Request within the period required by applicable law. If we require more time, we will notify you in writing of the reason and extension period. We will deliver our written response by mail or electronically, at your option. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
CALIFORNIA PRIVACY RIGHTS
This section provides residents of the State of California (“California Consumers”) with the disclosures and notices required under the California Consumer Privacy Act of 2018 (“CCPA”). The following paragraphs apply solely to California Consumers and describe the specific rights afforded under the CCPA. California Consumers may exercise the rights over their Personal Information as described below, subject to our receipt of a verifiable Consumer Privacy Request and any exceptions or limitations that may apply.
- Right to Disclosure. You have the right to request that we disclose information to you about our collection and use of your Personal Information over the past 12 months, such as (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting or selling that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; and (v) if we sold or disclosed your Personal Information for a business purpose, two separate lists stating (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Drop-In Gaming is only required to respond to two disclosure requests within a 12-month period.
- Right to Access. You have the right to request that we provide you with access to specific pieces of Personal Information we have collected about you over the past 12 months (also called a data portability request). If you submit a right to access request, we will provide you with copies of the requested pieces of Personal Information in a portable and readily usable format. Please note that Drop-In Gaming is prohibited by law from disclosing copies of certain pieces of Personal Information because the disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, our business systems, or your account. Drop-In Gaming is only required by law to respond to two access requests within a 12-month period.
- Right to Deletion. You have the right to request that we delete any of your Personal Information that we collected from you and retained, with certain exceptions. Drop-In Gaming may permanently delete, deidentify, or aggregate the Personal Information in response to a request for deletion. If you submit a right to deletion request, we will confirm the Personal Information to be deleted prior to its deletion, and we will notify you when your request is complete.
- No Selling or Sharing Personal Information. Drop-In Gaming does not sell your Personal Information or share your Personal Information with third parties for cross-contextual behavioral advertising purposes. If this changes in the future, we will update this Privacy Notice and provide you with a method to opt-out of such sale and sharing.
- Limited Use and Disclosure of Sensitive Personal Information. Drop-In Gaming does not use or disclose sensitive Personal Information for the purpose of inferring characteristics about any consumer. If this ever changes in the future, we will update this Privacy Notice and provide you with methods to limit use and disclosure of Sensitive Personal Information.
- Right to Nondiscrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by law, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under the CCPA.
- Right to Disclosure of Marketing Information. California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California residents to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.
California Consumer Privacy Requests. California Consumers may exercise these rights by submitting a verifiable Consumer Privacy Request as instructed above in Exercising Your Privacy Rights. We endeavor to respond to Consumer Privacy Requests from California Consumers within 45 days of receipt. Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. If we cannot comply with part or all of your request, we will explain the reasons in our response.
NEVADA PRIVACY RIGHTS
Residents of the state of Nevada residents who have used our Services have the right to opt out of the “sale” of certain of their Personal Information, as that term is defined under Nevada law. The types of Personal Information covered under this Nevada law includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. As discussed above, we do not sell your Personal Information. Nonetheless, if you are a Nevada resident who has used our Services, you may submit a request to record your preference to opt out as instructed above in Exercising Your Privacy Rights.
EUROPEAN UNION PRIVACY RIGHTS
Drop-In Gaming adopted this section to comply with the European Union’s General Data Protection Regulations (“GDPR”). This section applies solely to residents of the European Union (“EU Residents”). Drop-In Gaming provides the Services to EU Residents as a data controller. If you are an EU Resident, you have the following rights in relation to Personal Information we hold about you:
- Right to know how we process your Personal Information. We have set the required notices in this Privacy Notice. We may provide you with additional notices about other ways we process your Personal Information, such as by sending you a notice via email or by other means of communication.
- Right to access your Personal Information. You can request to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example in order to protect the rights of other individuals.
- Right to restrict processing of your Personal Information. You can request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object.
- Right to rectify your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., change of address), please inform us and we will update our records.
- Right to data portability. In some circumstances, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
- Right to erasure (a.k.a. the “right to be forgotten”). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.
- Right to object to certain processing of your Personal Information. Upon your request, and in certain circumstances and where we are required to do so by law, we will limit our processing of your Personal Information as you request.
- Right to not be subject to Automated Decision-Making (“ADM”). Drop-In Gaming does not use automated decision-making or profiling as part of the Services. If this changes in the future, we will update this Privacy Notice and provide you with an option to exercise your privacy rights related to Personal Information processed using ADM.
EU Residents may exercise these rights over their Personal Information as instructed above in Exercising Your Privacy Rights, subject to any exceptions and limitations that may apply. We endeavor to respond to Consumer Privacy Requests from EU Residents within 30 days of receipt. If we cannot comply with part or all of your request, we will explain the reasons in our response.
We implement technical, organizational, and physical measures in place to help protect your information from unauthorized access, processing, or disclosure. We maintain internal policies to govern the collection, processing, access, and handling of data. We use technical safeguards to protect information online and stored on our systems. Please note, however, that no transmission of data over the Internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.
Your Account. When you register or create an account with us, you will have a login and password. We encourage you to take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your login and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized activity.
Data Transfers. Drop-In Gaming is owned and operated in the United States and is intended for use by players present in the United States. If you access or use our Services from outside of the United States, Personal Information we collect about you will be transferred to our servers in the United States and maintained there indefinitely. This may require the transfer of your Personal Information out of your country of origin with laws governing data collection and use that may differ from or be more restrictive than U.S. law, or may result in governments, courts, law enforcement or regulatory agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.
THIRD PARTY WEBSITES
This Privacy Notice applies only to information collected by Drop-In Gaming. We may provide links to third-party websites from our Services for the convenience of our visitors and Customers, but we have no ability to control, and we are not responsible for, the privacy and data collection, use, and disclosure practices of third-party websites, including Customer websites. Any access to and use of linked websites is not governed by this Privacy Notice, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites. We encourage you to review and understand the privacy notices of such websites before providing them with any information.
CHANGES TO THIS PRIVACY NOTICE
If we make material changes to how we treat your Personal Information, we will post the revised Privacy Notice on this page. Your continued use of the Services after we make changes is deemed to be your acceptance of those changes. The date that this Privacy Notice was last revised is identified at the top of the page. You are responsible for periodically checking this Privacy Notice for changes.
If you have questions about our privacy practices or would like to make a complaint, please contact us at email@example.com or 866-376-7464.