PRIVACY POLICY

Last Revised: December 6^th, 2024 

 Thrillzz Inc. (“Thrillzz”, “we”, “us” or “our”), 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 Thrillzz mobile applications (“Thrillzz App”), and other online products and services provided by us that link to this Privacy Policy, including www.thrillzz.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”). The social sportsbook games and sweepstakes provided on the Thrilzz App and Site are offered and operated by Thrillzz Inc., using software developed by Geckos Games Ltd.

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 19 years) are not eligible to use our Services. 

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 and we may provide additional notice as required by applicable law. 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

We collect information you choose to share with us, including information you enter through the Services. This section sets out how and when we collect and process your personal information. 

• Account Information: 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 profile photo and social media handles).If you choose to log in, access or otherwise connect to Thrillzz, or contact Thrillzz, 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. In addition, 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. 
• Payment information: When you complete a transaction, provide a good/service requested by the consumer, or otherwise perform a contract with the consumer, we may collect information related to making purchases (such as billing and payment processing information, including credit card, bank account, ACH information, and other payment account information). 
• Usage information: When you use our Services, such as  entering and participating in a contest, and redeeming prizes, we may collect information (information related to your use of our Services and your interaction with our Services (such as your gameplay, online status, use history, content, purchases, location, and interaction with other Thrillzz users or public forums), as well as other information you enter through the Services (such as demographic information or contact information as part of signing up for updates and marketing). In addition, we collect the date and time of access, referring and exit pages, pages viewed, features used, cursor movements and clicks, customer service interactions, screen recordings, and other actions you take in connection with the Services, and other usage information. We also collect and analyze information about your transactions through our Services, including the type of services you requested or received, the date and time for which an order was placed or requested, and the amount charged. 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”).  
• Device Data. We collect and analyze information about the device(s) you use to access our Services. This information might include your IP address, information about your device’s hardware, the operating system on your device and the version of that operating system, your language preferences, unique device identifiers, advertising identifiers, and information about the mobile network you use.  
• Location Information. When you use the Services, we and our service providers may collect precise location information (in accordance with your device settings and permissions) as well as collect general location information from your computer or mobile device. “General” location information means information to identify the city and state in which your device is located based on its IP address. This information allows us to give you access to content that varies based on your general location (e.g., nearby locations or delivery status). We will ask your permission before collecting your precise GPS location information. In such instances, we may use your precise geo-location information to verify and authenticate your account and eligibility to use the Services, provide customized services, content, promotional offers, and other information that may be of interest to you. You can disable precise geolocation tracking on your device. For more information, see the “Your Choices” section below.
• Communication information: When you 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
• Information from Cookies and Similar Technologies. We and our service providers may collect information through the use of “cookies” and similar technologies, such as web beacons, tracking pixels, and scripts, to understand how you navigate through and interact with our Services, to learn what content is popular, to enhance the Services and provide you with a more relevant and personalized experience, for authentication and advertising purposes, to save your preferences, for fraud detection and security, and to collect certain usage, device and location information as described above. We may also collect this kind of information when you interact with email messages or other communications we send you. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our Services. 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; they are designed to collect usage information like ad impressions or clicks and email open rates, measure the popularity of our Services and associated advertising, and access cookies. We and our vendors (including Google Analytics) also use these technologies and the information collected by them for data analytics purposes. You can find more information about Google’s analytics practices at google.com/policies/privacy/partners. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on To generally update your cookies settings to notify you when a cookie is being set or updated or to disable cookies altogether, please consult your web browser settings. Please note that if you delete or choose not to accept cookies from us, you may miss out on certain features of our Services. 

HOW WE USE INFORMATION

We use your information to:

• Provide you with the Services and information you request;
• Manage, verify, and authenticate your account;
• Conduct audits, including counting online ad impressions to unique visitors, verifying positioning and quality of ad impressions;
• Engage in transactions, including contacting you about your account, billing, remitting, or charging you,  and processing payments;
• Short term transient use when the data is not stored, including contextual customization of ads shown as part of the same interaction;
• Facilitate prize payments and fund purchases and redemptions;
• Participate in promotions, events, surveys, and sweepstakes;
• 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 first party, internal analytics to improve the content, functionality, and usability of the Services, enhance the user experience, and improve our business;
• Engage in internal research for technological development and demonstration; 
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest;
• Invite you to participate in promotions, sweepstakes, surveys and provide feedback to us;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair services/products; 
• Verify and maintain the quality or safety of a service or device, and improving, upgrading, or enhancing the service or device. If possible, enter personal information that must be used or retained;
• 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.

YOUR RIGHTS

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your personal information. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.

1. Rights of access to your personal information:‍

You have the right to receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.

2. Right of data portability:

You have the right to request us to move, copy and transfer your personal information easily from one IT environment to another, in a safe and secure way, without affecting its usability.

3. Right of rectification:

You have the right to request rectification of your personal information in our control in the event that you believe the personal information held by Thrillzz is inaccurate, incomplete or outdated.

4. Right of deletion/erasure:

You have the right to request that Thrillzz erases or deletes personal information held about you at any time.

5. Right to restriction or objection to processing:

You have the right to request that Thrillzz restricts or ceases to conduct certain personal information processes at any time.

6. Right to withdraw your consent:

To the extent we process personal information on the basis of your consent, you have the right to withdraw your given consent at any time.

7. Right to limit use and disclosure of your sensitive personal information:

You have the right to request to limit the collection of your sensitive personal information, to that use which is necessary to perform our Services.

8. Right not to be subject to automated decision making:

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.

9. Right to opt-out of the sale or share of personal information:

In the event that we sell or share your personal information for behavioral advertising purposes, you have the right to submit a request to opt-out of the sale or share of your personal information. After you opt-out, we may continue disclosing some personal information to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.

10. Right to non-discrimination:

You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.

Please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.

We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Authorized agent

1. You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

1. The authorized agent is a natural person or a business entity; and
2. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

2. The request must:

3. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or an authorized agent. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you; and
4. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

3. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

4. Making a verifiable consumer request does not require you to create an account with us.

ONLINE ANALYTICS AND ADVERTISING

Analytics. We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive an email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Online Advertising. In using the Services, we may allow select third party advertising technology partners to place cookies or other tracking technologies on the browser of your device to collect information about you as discussed above. We sometimes also associate cookies with de-identified data linked to or derived from data you have submitted to us (e.g., your email address) and disclose such information with to advertising partners and vendors in hashed, non-human-readable form to provide you with more relevant ads when you use our Services or visit other websites and mobile applications. These third parties may use this information to serve relevant content and advertising to you as you browse the Internet, and access their own cookies or other tracking technologies on your browser to assist in this activity. If you are interested in more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Please note that these opt-outs apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Services. If you use these mechanisms, you may still see advertising on our Services or across the Internet, but it will not be tailored to you based on your online behavior over time.

Mobile App Advertising. You may also receive tailored in-app advertisements when using our Apps or other mobile apps. We may use third-party service providers to deliver ads on mobile apps or for mobile app analytics.  In your iOS for Apple device, you can withdraw your consent to personalized advertising experience at any time by using your device settings as follows: either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).Each operating system provides its own instructions on how to prevent the delivery of tailored in-application advertisements. Because we do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements, you should review the support materials and/or the device settings for the respective operating systems for information on opting out of tailored in-application advertisements.

Do Not Track (“DNT”). DNT is a privacy preference that web users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services through cookies and similar technologies, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. 

HOW WE DISCLOSE INFORMATION

We will disclose your information collected from and about you in the following ways: 

• Service Providers and Vendors: 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, shipping and fulfillment, legal services, and identity and contact information validation.
• 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.
• To Other Users: When you include information in your public profile, it may be available to other users as will your communications with other users through direct messages, group messages, and discussion boards. 
• 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 of residence, contests played, and photos) in connection with publicity purposes.
• Other Unaffiliated Third Parties. We may also disclose your information to other unaffiliated third parties such as the following:
  • Third party parties we collaborate with in connection with integration, co-marketing and certain other coordinated efforts.
  • Third parties whose offers we believe you may value.
• 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.
• Auditors and advisers: We may share your data with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers) for ensuring our compliance with regulatory requirements and industry standards.
• 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 take a variety of technical, physical, and organizational measures to protect information in our control. However, no data transmission over the Internet can be guaranteed to be totally secure. As such, we cannot guarantee the security of any information you transmit to us, and all disclosures of information to us are 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.

YOUR CHOICES

Marketing. If you supply us with your e-mail address, you may receive periodic communications from us with information on our programs and services. If you do not want to receive e-mail from us in the future, please let us know by sending your request via the unsubscribe link contained in all such e-mails. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you unsubscribe or opt-out, we may still send you service-related communications (e.g., if your credit card payment was declined). If you do not wish to receive them, you must delete your account with us.

Mobile Devices. We may send you push notifications through our applications. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. If you granted us permission to collect your precise GPS location information and you no longer wish for us and our service providers to collect and use such information, you may disable the location features on your device through the device’s operating system settings. Please note that if you disable such features, you may not be able to access or receive some or all of the services, content, and/or features made available via the Services.

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 Thrillzz, our users, and enforce our agreements.

CHILDREN’S PRIVACY

IF YOU ARE UNDER 19 YEARS OF AGE, YOU MAY NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER. 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. 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.

CONTROLLING VERSION

The Privacy Policy has been drafted in the English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Privacy Policy. 

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 support@thrillzz.com