We are dedicated to protecting your privacy and handling your Personal Information (defined below) with care and respect.  This Privacy Policy (“Policy”) describes the policies and procedures of CrowdPlay Inc. (“we”, “our” or “us”) on the collection, use, retention, transfer, disclosure, and destruction of your Personal Information in connection with your use of the loyalty engagement program (the “Program”). We host, administer, and manage this Program for our own purposes or on behalf of business and contracting parties (“Business Partners”) through networks, mobile devices, mobile applications, and websites operated by us or any of our Business Partners as well as any other websites or services where this Policy is posted or any associated or ancillary services, features, content or applications are offered through the Program (collectively, the “Services”).

We are the data controller of the Personal Information we hold about you.  We receive Personal Information about you from various sources, including without limitation: (i) when you or any other individual register and sign up to participate in the Program (each, a “Participant”) by setting up an account (“Account”); (ii) your use of the Services generally; and (iii) from third party websites and services. When you participate in the Program or use the Services, you consent to the collection, use, retention, transfer, disclosure and destruction and other uses of your information as described in this Policy.

Before registering for or installing our Program or using our Services, please read both this Policy and our Terms of Use to understand how we monitor and hold your Personal Information. If you do not agree to any of the provisions of this Policy or Terms of Services, you should not use the Program or Services.

We may update this Policy from time to time and if we do, we will change the date above. Changes to this Policy are effective when posted, and your continued use of the Program or Services constitutes your agreement to changes to the Policy.

What Does This Policy Cover?
This Policy covers the treatment of and the ways that we collect, store, process, transfer, share, and use your personally identifiable information (“Personal Information”) gathered when you are using or accessing the Program and Services. This Policy also covers our treatment of any Personal Information that we receive from our Business Partners or that we share with our Business Partners.

This Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services, and applications (each a “Third Party Service”) that you elect to access through the Program or Service or any individuals that we do not manage, control, or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we do not take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Information Do We Collect?
We collect Personal Information that you voluntarily submit directly to us when you sign up for and interact with the Program or use our Services. If you choose not to provide such Personal Information, we may not be able to provide the Service to you or respond to your other requests. This includes information you provide to us when you register for the Program or use our Services, fill out an online form requesting information related to our Services, create, or edit your Account, correspond with us by phone, SMS, e-mail, or otherwise, engage with the Program, or use any of our Services. In order to register for the Program or access some Services, you will create an Account, which will include at a minimum, your first and last name, username, gender and password. Certain Personal Information is required in order for us to provide you certain features of the Services. You may also be asked to voluntarily provide certain additional information, but except as noted in the proceeding sentence, we do not require that you to provide any demographic information, such as age (except to confirm that you are old enough to use the Program or Services), education, nationality, ethnicity, or religion, in order to register for the Program or use our Services.

The information we gather enables us to market, personalize, improve, and continue to operate the Program and provide the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information and other information you enter upon making an Account. We collect the following types of information:

Account Information:
If you create an Account, you may be required to provide information that could be Personal Information, such as your first and last name, gender, phone number, email address, postal address and age (so we can ensure you are old enough to use our Program and Services). Additionally, if you register for or access the Services using a Third Party Service (such as your social media account login credentials), we may receive Personal Information that you allow such Third Party Service to share with us.  You acknowledge that this information may be personal to you, and by creating an Account and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services. You may unsubscribe from some of these messages by emailing us at privacy@crowdplayapp.com although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes. Personal Information you provide us may be combined with information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

We may use anonymized Personal Information that does not identify you for any valid business purpose, including testing, research, data analysis, improving our Services, advertising, marketing, and developing new products and features. We may also share such anonymized information with others without limitation.

Information Regarding Your Social Networks:
As mentioned above, you may be able to register for or access the Program or use the Services through a Third Party Service, such as one of your social media accounts (e.g., Facebook, Twitter, Instagram, etc.).  Occasionally, you may also use your Account on other Services we offer.  You acknowledge that some account information from your account on the applicable Third Party Service may be transmitted into your Account with us, and that such information is covered by this Privacy Policy.  Some of your information from the Services may be shared with the Third Party Service and others, and we encourage you to read the privacy policies and other policies of any Third Party Services, including without limitation any applicable social networks, you use in connection with the Services.

Additionally, we may collect and receive your social media account login credentials in connection with providing you with the Services. We will use such login information only as set forth in this Policy (as it may be amended) or as otherwise expressly authorized by you.

Location Information:
We may collect and process information about your actual location. Additionally, we may collect and/or receive location information from your use of the Services generally, which can come from a variety of sources, including, but not limited to IP address, GPS, and other sensors, depending on how you use or access the Services.

Our Program and some of our Services may include features based on Participants’ actual location or geolocation data, which may include information that is generated by, derived from, or obtained by the operation of an electronic device that can be used to identify the past, present, or future location of an electronic device, or an individual (together “Location-Based Services”).  To the extent you voluntarily opt to use any Location-Based Services, we may collect and store information about your location at the time you use those Location-Based Services.

IP Address Information and Other Information Collected Automatically:
‍Generally, the Program and Services automatically collect usage information, such as the number and frequency of visitors and Participants to the Program or Services. We automatically receive and record information from your web browser and device when you interact with the Program and Services, including your IP address and cookie information and other mobile identifiers. This information is used for fighting spam and malware and also facilitates collection of data concerning your interaction with the Program and Services (e.g., what links you have clicked on).

We may use this data in an anonymized and aggregate form that does not identify you personally. This type of data enables us, our Business Partners, and authorized Third Parties to figure out how individuals interact with the Program and Services so that we can analyze and improve them.

We may collect some device-specific information when you access the Program and Services using a device.  Device information may include but is not limited to unique device identifiers, network information, operating system and hardware model, as well as information about app usage information and how the device interacts with our Program and Services.

Email, Text, and Push Notification Communications:
We may communicate with you via push notification, email, SMS, MMS or other text message (“Messages”) (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email, read a message or receive a push notification. We use this information to improve our Program and Services, including without limitation our customer service.

You may unsubscribe from receiving Messages at any time by changing your preferences in your Account or opting out via the unsubscribe link at the bottom of your email, or by following the opt-out instructions to the SMS message or other electronic message as specified in the message. Even if you opt out of receiving promotional messages, you agree that we may continue to send you Messages concerning your Account.

Aggregate Information:
We collect statistical information about how both unregistered and registered participants, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser.

How, and With Whom, Is My Information Shared?
Information you provide or that we collect may be used by us, our affiliates, Agents (defined below), Business Partners including, without limitation, any sponsors of ours or our Business Partners (“Sponsors”), or service providers who process information on our behalf to provide the Services to you (“Authorized User” or if more than one, “Authorized Users”). If you elect to receive promotional communications, we or any Authorized User may use information collected from you to contact you about the Services or other products or services that may be of interest to you (including special offers and promotions), to fulfill or respond to your requests, to send notifications, to improve and personalize the Services, to conduct research, to solicit feedback about the Services, and to tailor advertisements on or through the Services. We or Authorized Users may combine this information with information from other sources so that we may further improve the Program or Services, offer products and services, or tailor advertisements delivered on or through the Program or Services.

We or our Authorized Users may use Account information and other information you provide to us to interact with you regarding the Program, which may include providing activation codes, widgets or other similar electronic interfaces, update you on reward point accumulation, any rewards that you earn or are eligible to earn, and to fulfill any rewards you seek to redeem or to provide you with other services in connection with the Program (“Rewards Rules”). Reward Rules are found in the Terms of Use, but each Program may have applicable rules regarding earning reward points, redemption of reward points, and if necessary, may post supplemental privacy provisions. To the extent there is a conflict between those privacy provisions and this Policy, the privacy provisions for the specific Program will govern but solely to the extent of the conflict.

Public Information About Your Activity on the Services:
Some of your activity on and through the Program or Services is public. This may include, but is not limited to, content you have posted publicly, through or in connection with the Services, including without limitation on public portions of Third Party Services, such as your social media accounts.

Registered Participants may have some of this information associated with their Account. Unregistered participants will not have this association, but information concerning their use of the Programs and Services (such as what pages they have visited) may be tracked.

If you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We suggest that you think carefully about including any specific information you may deem private before signing up for the Program or Services.

IP Address and Device Information:
While we collect and store IP address and device information, that information is not made public. We do at times, however, share this information with our Authorized Users.

Information You Elect to Share:
You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within our Program or Services. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Policy only governs information collected through the Program or Services.

Aggregate and Non-Personally Identifiable Information:
We share aggregate information with Authorized Users.  We may also share information with Authorized Users that is (i) not Personal Information or (ii) derived from Personal Information but has been anonymized so that it is no longer personally identifiable (collectively with aggregate information, “Non-Personal Information”). We use and share this type of data so that we and our Authorized Users can understand how and how often people use our and their services or websites, which facilitates improving our Services, their services and how our Services interface with their services. In addition, these Authorized Users may share with us non-private, aggregated or otherwise Non-Personal Information about you that they have independently developed or acquired.

User Profile Information:
User profile information including your username and other information you enter may be displayed to other Participants to facilitate participant interaction within the Services. We will not directly reveal Participant email addresses to other Participants.

Registered Participants are displayed by a username along with information about location(s) where you interact with the Program or engage with the Services. You may also receive messages from other Participants through the Program or Services. We are not responsible for the content of such messages.

Social Media Account Login Credentials:
If you share your Third Party Services account login credentials with us, we may retain this information.  Except as provided in this Policy, we will never share or disclose your login credentials outside of our company.

Information Shared with Our Agents:
We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide the Program or Services to you. Except as provided in this Policy, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

Information Shared with Our Business Partners:
We share Personal Information with Business Partners in order to administer, improve or otherwise manage the Program or provide Services to you. Our Business Partners have the right to use and you hereby consent to our sharing Personal Information or other information with them.

Information Disclosed Pursuant to Business Transfers:
In some cases, we may choose to buy or sell assets. In these types of transactions, Participant information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, participant information would be one of the assets that is transferred or acquired by a Third Party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Policy.

Information Disclosed for Our Protection and the Protection of Others:
We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Policy and our Terms of Service, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to participant support requests or (v) protect our rights, property or safety, our Participants and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Is My Information Secure?
We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. We store all of our information, including your IP address and device information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.  Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of Participant information at any time.

Security measures are in place to protect your Personal Information that is under our control against accidental or unlawful destruction, loss, change or damage. All Personal Information you provide via our websites and devices will be protected by encryption technology. However, no security measures are perfect or impenetrable, and we do not guarantee the security of the information you provide to us.

Additionally, you are responsible for preventing unauthorized access to your Account and Personal Information by protecting your Account credentials and limiting access to your mobile or other device used to access the Program. You should protect against unauthorized access to your password, computer, and mobile and internet-enabled devices, by taking reasonable steps such as signing off after using a shared computer, inserting a password on your internet-enabled device, choosing a distinct password that you keep private, and periodically change. We are not responsible for any activity on your account via unauthorized password activity.

What Information of Mine Can I Access?
If you are a registered Participant, you can access information associated with your Account by contacting us at privacy@crowdplayapp.com. California Privacy Rights: California residents may be entitled under certain circumstances to ask for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 209 West Central Street, Suite 201A, Natick, MA 01760.

How Can I Delete My Account?
Should you decide to delete your Account, you may do so by emailing privacy@crowdplayapp.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, any public activity on your Account prior to deletion will remain stored on our servers, retained by us and Authorized Users, and will remain accessible to the public.

What Choices Do I Have Regarding My Information?
You will not be able to use the features of the Program or Services without registering.

You may always opt not to disclose certain information to us, but please note that required information must be provided in order for you to engage with the Program and Services we offer.

You may contact us to delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be accessible to our Authorized Users.

You can choose to opt out of certain communications or communication methods; however, if you do so, you may not be able to take advantage of the Program or some of our Services or features.

What Happens When There Are Changes to this Privacy Policy?
We, in our sole discretion, may amend this Policy from time to time. Use of information we collect now will be subject to the Policy then in effect at the time regardless of the Policy in effect at the time it was collected. If we change the way we collect or use information, we will notify you as noted above.

What If I Have Questions or Concerns?
If you have any questions or concerns regarding privacy using the Program or Services, please send us a detailed message to privacy@crowdplayapp.com. We will make every effort to resolve your concerns.