Privacy Notice

PRIVACY NOTICE

NOTE: Please review the updated Privacy Notice carefully before using the Hell’s Poker.

__________________________________________________________________________

This Privacy Notice (“Notice”) describes the privacy practices of Hell’s Poker, LLC and/or its subsidiary and affiliated entities (“Hell’s Poker,” “we” or “us”) with regard to Services where this Notice is posted.

This Notice explains how we collect, use, and share information about users who interact with our websites, applications, our content on connected televisions, or other interactive services that link to or reference this Privacy Notice (“Services”). This Notice does not apply to our collection of information from other features, services, or sources (unless specifically stated), or to third parties that provide information to Hell’s Poker.

By accessing and using the Services, you agree to our collection and use of your information in the manner described in this Notice. If you disagree with the terms of this Notice, you should not use the Services.

1. GEOGRAPHIC SCOPE OF THE NOTICE

The Services are operated in the United States and are intended for users located in the United States. The Services are therefore governed by and operated in accordance with the laws of the United States. If you are located outside of the United States, please be aware that information you provide to us or that we obtain as a result of your use of the Services will be collected in the United States and/or transferred to the United States and will be subject to U.S. law.

By using the Services and/or providing us with information, you (a) consent to the transfer and/or processing of any information to and in the United States, (b) acknowledge that U.S. law may provide a lower standard of protection for information than the laws of your location, (c) understand that we will collect, transfer, store, process and share your information from or about you in accordance with this Notice and U.S. law.

2. TYPES OF INFORMATION WE COLLECT FROM OR ABOUT YOU

When you interact with the Services, we collect information that directly identifies you (i.e., information that would allow someone to identify you or contact you, such as your full name, postal address, e-mail address, or telephone number), as well as information about your use of the Services. Below we describe the different types of information we collect from you and the devices you use when you interact with the Services.

Information you provide to us: Some of the Services may permit you to enter contact information and other information about yourself and others. We collect and store any information you enter through the Services. For example, you may provide:

• your name, postal address, e-mail address, phone number, profile picture, birthday, or other information, such as when you register with our Services, create or edit your user profile, sign up to receive newsletters, or enter in a contest or sweepstakes;

• certain demographic information, such as your age, gender, or income bracket, when you participate in a survey or poll;

• information in postings, comments, or forums (such as chat rooms, message boards, or similar public forums) within the Services, and in non-public messages you send to other users of the Services;

• nutrition and dietary preference information when you search for recipes within the Services;

• your first and last name, your address, and your credit card and billing information if you purchase of a product at the Hell’s Poker Store or subscribe to one of Hell’s Poker’s paid Services; or

• your e-mail address, communications, and files when you send to us a message by e-mail, through our Customer Support portal, or through other communication services.

Information we collect automatically from your devices: When you interact with the Services, certain information about your use of the Services is automatically collected. This information includes information about the devices used to access the Services, such as Internet Protocol (“IP”) address, your device ID and other unique device identifiers, mobile network information, information about how the device is interacting with our Services, hardware model, and the type and version of your device’s operating system or web browser. We also collect information about how you use our Services, such as pages viewed and the order of such pages, content (including video content) or advertising you view within the Services; the length of time you interact with the Services; search queries entered within the Services; error logs; websites and other services you visit before and after visiting a Hell’s Poker site; and other similar information. Much of this information is collected through cookies, web beacons, and other tracking technologies. Please see our Tracking Technologies Notice for further information, including your choices in relation to the use of these technologies.

Information from Social Media Networks and Other Third Parties: When you use certain features of the Services, you may give us permission to access information about you from services offered by third parties, including social media networks. For example, you may choose to register on our websites by using a social media account, or you may use a social media function on our Services such as a “share” button. Doing that allows us to obtain information from the social media platform. That information could include your friends or contacts, profile picture, birth date, gender, people/sites you follow, or other profile-related information, as well as any other information you have opted to share. The information we obtain from social media networks depends on your account/privacy settings with those third parties and those third-parties’ privacy policies, so be sure to check those policies and to adjust your settings to meet your preferences.

We may also obtain information about you from other third-party sources, such as our partners and advertisers, interactive applications offered through our services (such as embedded video players), and commercially available sources such as data aggregators and public databases. We may combine the information we receive from third parties with information we collect through the Services.

Location Information: We collect general information about your location through the Services, such as the city, state, and/or zip code associated with your IP Address. If you agree, we may collect more specific location information that is provided through the GPS functionality on your mobile device used to access the Services. That location information is used to present information and advertising that is of relevance to you in your geographic area and to allow you to take advantage of certain features of the Services such as tailoring live class schedules to your time zone or providing you with local grocery store options for recipe ingredient delivery. If you grant permission for us to collect more specific GPS location information, you can disable such access through your mobile device settings.

Information You Provide About Others: If you send someone else a communication using the Services, such as sending content to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise in accordance with applicable legal requirements. Please be aware that when you use any send-to-a-friend functionality on our Services, your e-mail address may be included in the communication you send.

3. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect to provide and improve the Services; to communicate with you; to deliver advertising; and to develop and provide additional products, features, and offerings, as explained in more detail below.

Provide the Services you request, including to maintain and service your account

, for example to:

• Fulfill your requests for products, services, or information;

• Process your payments and ship your products;

• Enable your access to the Services and participation in special features of the Services, such as recipe boxes, surveys, polls, and message boards;

• Provide technical and other support, including to understand and resolve technical issues with the Services;

• Send you service-related communications;

• Display user-generated content; and

• Process your entries into sweepstakes, contests or promotions.

Communicate with you and provide customer service to support the Services

, including to:

• Provide customer service support or respond to your inquiries, requests and comments;

• Send you electronic newsletters or enter you into sweepstakes or contests; and

• Provide you legal notices or other notices with respect the Services, including service-related communications.

Develop and improve the Services and personalize your experience with the Services

, including to:

• Analyze patterns in the use of the Services, study site traffic, and understand customer needs and trends to improve our Services and develop new ones;

• Provide you with a customized product experience, including viewing and other content recommendations;

• Send you personalized newsletters, surveys, and information about products, services and promotions offered by us, our partners, and other organizations with which we work;

• Customize the content on the Services based on your activities and interests;

• Create profiles about you, including adding and combining information we obtain from third parties, which may be used for analytics, marketing and advertising; and

• Use inferences about your preferences and interests for any and all of the above purposes.

Provide our marketing and third-party advertising to you

, including to:

• Send you newsletters, promotional e-mails, surveys, and information about products, services and promotions offered by us, our partners, and other organizations with which we work;

• Customize advertising that our third-party partners deliver on the Services (e.g., personalized third-party advertising);

• Create and update inferences about you and audience segments that can be used for targeted advertising and marketing on the Services, third party services and platforms, and mobile apps;

• Create profiles about you, including adding and combining information we obtain from third parties, which may be used for analytics, marketing, and advertising; and

• Measure the placement, frequency, efficacy, and compliance of advertising and ad impressions.

Security, Fraud, and Legal Compliance,

including:

• Monitor prevent, and detect fraud, such as through verifying your identity;

• Combat spam or other malware or security risks;

• Monitor, enforce, and improve the security of our Services;

• Comply with any applicable procedures, laws, and regulations, subpoenas, governmental requests or legal process, or in connection with a legal investigation, if in our good faith opinion such is required or permitted by law; and

• Establish, exercise, or defend our legal rights (e.g., to enforce compliance with our Terms of Use, Visitor Agreements, Privacy Policies, or other contracts or legal rights).

Please note that all of the information we collect about you may be combined together in order to facilitate all of the above purposes.

4. WHEN WE SHARE INFORMATION

We may disclose the information we collect as described below and supplemented by our Tracking Technologies Notice. By accessing and using the Services, you consent to our sharing practices, as described in this Notice, and subject to any choices you have made.

Third-party service providers: We engage third-party service providers to perform a variety of services and functions on our behalf, such as customer support, administering our promotions, marketing or promotional assistance, data analytics, online advertising, technology services and platforms, processing payments, and other services.

The Hell’s Poker family of companies: We may share information about you within the family of Hell’s Poker companies, including our subsidiary and affiliated companies and joint venture partners, to provide and improve our products and services, as well as to provide you with information about products or services that may interest you.

Sweepstakes, contests & promotions: When you register or enter a promotion, sweepstakes, or contest through our Services, we may share the information you provide for such purposes with authorized third-party service providers (as described above), participating sponsors, and advertising partners. Further, by entering any promotion, you are agreeing to the official rules that govern that promotion, which may require you to take certain actions, including, except where prohibited by law, allowing Hell’s Poker and/or the sponsor(s) of the promotion to use and publicly release your name, voice, and/or likeness in advertising or marketing associated with the promotion. Please review the relevant promotion, sweepstakes, or contest rules for more information.

Business partners: We may share information with third parties with whom we have business relationships, such as our co-promotional partners, advertisers, ad networks, and data marketing services, for purposes such as offering products and services that may interest you.

Business transfer: In the event we go through a business transition such as a merger, acquisition, bankruptcy, reorganization, or sale of all or a portion of our assets, or a diligence process in connection with a potential business transaction, the information we collect and maintain may be disclosed, sold, or transferred as part of that transaction. If such transfer is subject to additional restrictions under applicable laws, we will comply with such restrictions.

Legal requirements and protection of Services and users: We will disclose the information we collect where we have a good faith belief that such disclosure is: (a) required by law (or to respond to subpoenas, warrants, government requests, or similar process served on us); (b) pursuant to our DMCA notice and take-down policy and procedures; and/or (c) necessary to protect or defend our legal rights or property, our Services, you, or other third parties, or ensure the safety and security of our Services, systems, and of our customers or the general public.

With your consent: We may share or disclose information about you if you ask or authorize us to do so, including by intentionally interacting with third-parties on our sites. Additionally, when you choose to share information in a public forum, that information may be seen or collected by anyone, including third parties that do not adhere to our Privacy Notice. We are not responsible for events arising from the distribution of any information you choose to share publicly through our Services.

Aggregate information: We may aggregate and/or de-identify information such that it is no longer linked to you or your device. This Notice does not limit our ability to disclose aggregated or de-identified information that is not linked to you. We may use and disclose such information to our partners, advertisers, and any other third parties in our discretion.

5. Hell’s Poker Online Poker Game

Hell’s Poker Ventures, LLC provides an online poker game that is not fiat based. It is for gaming purpose only. The online poker is for fun, education and training.

6. CHOICES YOU HAVE REGARDING THE COLLECTION, USE, AND SHARING OF INFORMATION

You have many choices regarding how we use and share your information. These choices are described in more detail below.

Subscription and Registration Services: The Services may include subscription and registration management tools that allow you to make changes regarding your preferences for receiving communications. Regardless of whether these tools are available through the Services, you may contact us as at privacy_policy@HellPoker.com if you: (a) have questions or comments about this Notice; (b) wish to make corrections to the information you have provided to us; (c) want to opt-out from receiving future commercial correspondence, including e-mails, from us (we may continue to send you transactional messages such as responding to your inquiries or notices of updates to this Notice); or (d) do not want us to share information that identifies you with third parties for such third parties’ direct marketing purposes.

We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note:

• you may be required to verify your identity to make certain changes;

• we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Services;

• it is not always possible to completely change, remove, or delete all information about you from our databases for legal and other reasons; and

• we generally do not remove public postings you may have made on the Services, such as in forums or blogs.

E-mail communications: In connection with certain features on the Services, we may allow you to set your preferences for receiving e-mail communications from us (such as agreeing to some communications but not others). In other instances, you may “opt out” of receiving future commercial e-mail communications from us by clicking the “unsubscribe” link or following the other instructions included at the bottom of most e-mails we send, provided, however, we reserve the right to continue to send you transactional e-mails, such as customer service communications and shipping confirmations.

Targeted advertising: To find out more about our advertising and how to opt out of receiving interest-based advertising from companies that participate in the Digital Advertising Alliance, please see our Tracking Technologies Notice.

Mobile device location information: If you access the Services through a mobile device and you do not want your device to provide us with specific, GPS location-tracking information, either do not agree to allow your device to share this information with us or disable the GPS or other location-tracking functions on your device. Your device manufacturer should provide instructions on how to disable GPS or other location-tracking functions. If you initially consent to the collection of location information, you can subsequently stop our collection of location information at any time by changing the preferences on your mobile device or by uninstalling the application from your mobile device.

7. HOW WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES

Like many companies, we use cookies and other tracking technologies on our Services. For detailed information about the tracking technologies we use, how we use those technologies, and additional options you have regarding the use of those technologies, please visit our Tracking Technologies Notice. Additionally, as more fully explained in that Tracking Technologies Notice, your browser or device may include “Do Not Track” functionality. Our information collection and disclosure practices, and the choices that we provide, will continue to operate as described in this Notice and the related Tracking Technologies Notice, whether or not a Do Not Track signal is received.

8. ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, California law requires us to provide you with some additional information regarding the “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)) we collect from and about you, and your rights with respect to your personal information.

9. ADDITIONAL PRIVACY INFORMATION FOR NEVADA RESIDENTS

Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. In some circumstances, we may share your information with certain third parties that we believe can provide you with offers and promotions for products and services of interest to you. This sharing may qualify as a sale under Nevada law. If you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of “sales” activity emailing us at privacy_policy@HellPoker.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

10. HOW WE PROTECT CHILDREN’S INFORMATION

Hell’s Poker Services are generally directed to adults and not intended for use by children under the age of thirteen (13), we do not allow children to provide their “personal information” (as defined by the U.S. Children’s Online Privacy Protection Act or “COPPA”) on these Services, and we will delete such information in a reasonable period of time if we become aware of it. In some limited cases, Hell’s Poker does offer Services that are intended for use by children under thirteen (13); please see the privacy notices posted on those services for more information. If you have any questions about our practices with respect to children’s privacy or to request that we delete personal information provided by your child, please contact us at privacy_policy@HellPoker.com.

11. HOW WE MAINTAIN AND SECURE THE INFORMATION WE COLLECT

We maintain the information we collect for as long as necessary to provide the Services, for so as long as reasonably required to satisfy the purpose for which you submitted the information or our business purposes, or as required by law.

We take technical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk.

If you create an account or register with any of our Services, you are responsible for maintaining the secrecy of your password at all times.

12. THIRD-PARTY SITES, SERVICES, AND FEATURES

Our Services may contain links to third-party websites (e.g., online stores that offer products for purchase), third-party plug-ins (e.g., social-sharing buttons), and third-party features (e.g., banner advertisements). These third-party services may collect information from or about you when you interact with them, and in some cases, they may track your activity, including through the use of cookies or other tracking technologies, without you needing to interact with them. We are not responsible for the content or practices of such third parties, and their collection, use, and disclosure of your information will be subject to their privacy policies, and not this Notice. We urge you to read the privacy and security policies of these third parties.

13. GOVERNING LAW AND VENUE

This Notice and all disputes arising hereunder or relating hereto shall be governed by, and will be construed under, the laws of the Oregon, without regard to choice of law principles. Those who choose to access the Services from locations outside the United States do so on their own initiative and are responsible for compliance with local laws if and to the extent local laws are applicable. By using the Services, you agree that the exclusive jurisdiction for any dispute not subject to any applicable arbitration clause in our Terms of Use or Visitor Agreement shall be the state and federal courts located in New York.

14. UPDATES TO THE NOTICE

We may change this Notice from time to time as our services, technology, and legal obligations change. If we make changes, we will post the updated Notice and revise the “Last Updated” date. Any changes will be effective immediately upon posting of the revised Notice, and your continued use of the Services after that date will indicate your consent to any changes, unless applicable law requires us to provide another form of notice and/or seek your agreement to such changes.

15. HOW TO CONTACT US

For any questions or complaints regarding this Notice or Hell’s Poker privacy practices, please contact us at: privacy_policy@HellPoker.com

California Privacy Notice

This Notice applies to website visitors, app users, and customers in California. This Notice gives California residents additional information about our information collection and use practices required by the California Consumer Privacy Act of 2018 (“CCPA”), and also provides California residents with specific privacy rights.

Information About the Personal Information we Collect

This following chart provides information about the categories of personal information that we collect, the purposes for which we use the information, the sources of the information, and the categories of third parties to whom we disclose the information for business purposes.

Categories of information collected Purposes of use

(see “How We Use The Information We Collect” in our Privacy Notice for additional information) Sources of personal information Categories of third parties to whom we disclose the information

(see “When We Share Information” in our Privacy Notice for additional information)

Information you provide to us:

Registration, subscription, or contact information

such as e-mail address, name, phone number, and billing information

  • Provide the Services

• Communicate with you and provide customer service

• Personalize your experience

• Our marketing and third-party marketing and advertising purposes

• Bug detection and error reporting

• Auditing consumer interactions

• Security, fraud, and legal compliance • You

• Other users who provide information about you

• Consumer data resellers

• Public records databases

• Events

• Our affiliates • Service providers

• Our affiliates

• Other individuals, services, and partners at your request

• contests and promotions partners

• Marketers

• Social media networks

• Entities for legal purposes

• Entities for sales or transfer of business or assets

• Service providers

Customer service information

such as questions and other messages you address to us through online forms, by e-mail, over the phone, or by post; and summaries or voice recordings of your interactions with customer care • Provide the Services

• Improve the Services

• Communicate with you & provide customer service

• Bug detection and error reporting

• Security, fraud, and legal compliance • You

• Our affiliates • Service providers

• Our affiliates

• Entities for legal purposes

• Entities for sales or transfer of business or assets

Demographic, statistical, and interest information

such as your age, date of birth, gender, interests, lifestyle, and household information, and hobbies • Provide the Services

• Improve the Services

• Communicate with you & provide customer service

• Personalize your experience

• Our marketing and third-party marketing and advertising purposes

• security, fraud, and legal compliance • You

• Other users who provide information about you

• Consumer data resellers

• Our affiliates

• Public records databases

• Conferences and other events

• Marketers

• Social media networks, in accordance with your preferences • Service providers

• Our affiliates

• Other individuals, services, and partners at your request

• Contests and promotions partners

• Marketers

• Social media networks

• Entities for legal purposes

• Entities for sales or transfer of business or assets

Financial and transactional information

such as credit or debit card number, verification number, and expiration date, to process payments and information about your transactions and purchases with us • Provide the Services

• Communicate with you & provide customer service

• Security, fraud, and legal compliance • You

• Third-party payment processors who collect this information on our behalf and who also have an independent relationship with you

• Third party partners or co-branded partners • Service providers

• Our affiliates

• Third parties for legal purposes

• Entities for sales or transfer of business or assets

Employment or Education Information when you register for events or for networking insights services

such as education history, employment experience, and business contact information • Provide the Services

• Communicate with you & provide customer service

• Personalize your experience

• Our marketing and third-party marketing and advertising purposes • You

• Other users who provide information about you

• Consumer data resellers

• Our affiliates

• Public records databases

• Conferences and other events

• Marketers

• Social media networks, in accordance with your privacy preferences on such services • Service providers

• Our affiliates

• Other individuals, services, and partners at your request

• Contests and promotions partners

• Marketers

• Social media networks

• Entities for legal purposes

• Entities for sales or transfer of business or assets

User-generated content

such as comments on articles, photos, videos, audio, any information you submit in public forums or message boards, reviews and feedback or testimonials you provide about our Services • Provide the Services

• Communicate with you & provide customer service

• Personalize your experience

• Our marketing and third-party marketing and advertising purposes

• Bug detection and error reporting

• Security, fraud, and legal compliance • You

• Other users who provide information about you in connection with their event or profile • Service providers

• Our affiliates

• Other individuals, services, and partners at your request

• Contests and promotions partners

• Marketers

• Social media networks

• Entities for legal purposes

• Entities for sales or transfer of business or assets

Research, survey, or sweepstakes information (including personal identifiers and user generated content)

collected if you participate in a survey or sweepstakes; includes information needed for you to participate (such as contact information), and to fulfill your prize • Provide the Services

• Improve the Services

• Communicate with you & provide customer service

• Personalize your experience

• Our marketing and third-party marketing and advertising purposes

• Bug detection and error reporting

• Auditing consumer interactions

• Security, fraud, and legal compliance • You

• Survey or sweepstakes partners

• Researchers and analysts • Service providers

• Our affiliates

• Other individuals, services, and partners at your request

• Contests and promotions partners

• Marketers

• Social media networks

• Entities for legal purposes

• Entities for sales or transfer of business or assets

Contact Information about others (including personal identifiers)

such as name and mailing address to send a gift or use our send-to-a-friend functionality. • Provide the Services

• Communicate with you & provide customer service

• Auditing consumer interactions

• Security, fraud, and legal compliance • You

• Other users (if you are the recipient of a communication)

• Our affiliates • Service providers

• Our affiliates

• Other individuals, services, and partners at your request

• Entities for legal purposes

• Entities for sales or transfer of business or assets

Social media information

if you link your account or access the Services through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings such as your name, e-mail address, friend list, photo, gender, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, and Twitter) • Provide the Services

• Communicate with you & provide customer service

• Personalize your experience

• Our marketing and third-party marketing and advertising purposes

• Bug detection and error reporting

• Auditing consumer interactions

• Security, fraud, and legal compliance • You

• Social media networks, in accordance with your privacy preferences on such services • Service providers

• Our affiliates

• Other individuals, services, and partners at your request

• Contests and promotions partners

• Marketers

• Social media networks

• Entities for legal purposes

• Entities for sales or transfer of business or assets

Information we collect automatically from you and/or your device:

Categories of information collected Purposes of use

(see “How We Use Personal Information” in our Privacy Notice for additional information) Sources of personal information Categories of third parties to whom we disclose the information (see “When We Share Information” in our Privacy Notice for additional information)

Device information and identifiers

such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers • Provide the Services

• Personalize your experience

• Improve the Services

• Our marketing and third-party marketing and advertising purposes

• Bug detection and error reporting

• Auditing consumer Interactions

• Security, fraud, and legal compliance • You (through your device)

• Advertising providers

• Analytics providers

• Cookies and tracking technologies • Service providers

• Our affiliates

• Advertisers, ad networks and advertising partners

• Social media networks

• Entities for legal purposes

• Entities for sales or transfer of business or assets

Internet network and device activity data

such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services, the web sites you visit after this web site; and other web usage activity and data logged by our web servers, whether you open an e-mail and your interaction with e-mail content, access times, error logs, and other similar information.

See Tracking Technologies Notice for more information about how we collect and use this information. • Provide the Services

• Personalize your experience

• Improve the Services

• Our marketing and third-party marketing and advertising purposes

• Bug detection and error reporting

• Auditing consumer Interactions

• Security, fraud, and legal compliance • You (through your device)

• Advertising providers

• Analytics providers

• Cookies and tracking technologies

• Marketers

• Our affiliates • Service providers

• Our affiliates

• Advertisers, ad networks and advertising partners

• Social media networks

• Entities for legal purposes

• Entities for sales or transfer of business or assets

Geolocation information

such as city, state and ZIP code associated with your IP address; and precise geolocation information from GPS-based functionality on your mobile devices, in accordance with your mobile device settings • Provide the Services

• Personalize your experience

• Improve the Services

• Our marketing and third-party marketing and advertising purposes

• Bug detection and error reporting

• Auditing consumer Interactions

• Security, fraud, and legal compliance • You

• Advertising providers

• Analytics providers

• Marketers

• Our affiliates • Service providers

• Our affiliates

• Online advertisers, ad networks and advertising partners

• Social media networks

• Entities for legal purposes

• Entities for sales or transfer of business or assets

Information We Infer or Inference Information We Receive from Third Parties:

Categories of information collected Purposes of use

(see “How We Use The Information We Collect” in our Privacy Notice for additional information) Sources of personal information Categories of third parties to whom we disclose the information (see “When We Share Information” in our Privacy Notice for additional information)

Inference Data

such as information about your potential preferences that we infer from your activities on the Services, and information you provide or inference information we receive from other parties • Provide the Services

• Communicate with you & provide customer service

• Personalize your experience

• Improve the Services

• Our marketing and third-party marketing and advertising purposes • You, if we infer it from your information and activities

• Our affiliates

• Consumer data resellers

• Analytics providers • Service providers

• Our affiliates

• Online advertisers, ad networks and advertising partners

• Entities for legal purposes

• Entities for sales or transfer of business or assets

California Information & Deletion Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, 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; and

• Provide you with information about the financial incentives that we offer to you, if any.

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.

Verification: We will take reasonable steps 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, e-mail address, and physical address.

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.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please submit your request using the following intake form:

California Information & Deletion Requests

Notice of Right to Opt-Out of Sale of Personal Information

California residents may opt out of the “sale” of their personal information. Under the CCPA, “sale” is broadly defined to mean the sharing of personal information with third parties who are not acting as our service providers or who are otherwise not restricted from using data only on our behalf or pursuant to an applicable CCPA exception.

In some circumstances, we may share certain of your information with third parties to provide you with offers, promotions, and opportunities that may be of interest to you, which may be considered a “sale” under the CCPA. Under the CCPA, “sale” may also include allowing third parties to “collect” certain information, such as IP address, and/or browsing behavior, through cookies and similar technologies, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.

If you would like to opt out of our use of your information for such purposes that are considered a “sale” under California law, 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 without legally-required affirmative authorization.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion or sale opt out rights.

California “Shine the Light” Disclosure

If a company shares “personal information” (as defined in California’s “Shine the Light” law, Civil Code § 1798.83) with third parties for their direct marketing purposes (e.g., to send offers and information that may be of interest to you), California law requires either providing a mechanism by which consumers can obtain more information about such sharing over the prior calendar year, or providing a mechanism by which consumers can opt out of such sharing. As discussed above, we provide an opt out for this sharing. If you are a California resident and would like to opt out of sharing pursuant to this law, please use the “Do Not Sell My Personal Information” link above.


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