SharePlay Privacy Policy

Effective: May 18, 2023

Last Updated: Mar 16, 2024

  1. Welcome
  2. Changes to this privacy
  3. Information you provide us
  4. Information we obtain from others
  5. Information we automatically collect
  6. How we use your information
  7. How we share and disclose information
  8. Your choices
  9. European and UK residents
  10. US state specific provisions
  11. Security
  12. Information retention
  13. Data processing and data transfers
  14. Information security
  15. Links to third-party websites
  16. Children’s information
  17. Contact us

Welcome!

One of SharePlay Interactive LLC's ( "SharePlay", "we", "us", or "our" ) key values is educating its users and empowering them with information. This privacy policy (this "Privacy Policy") explains how SharePlay.tv collects, uses, discloses, and applies the information collected when you use or access our online website and any of our related websites, products, and services that link to this Privacy Policy (the "Services").

You agree to this Privacy Policy by using our Services or interacting with our platforms and teams. The types of information that we collect vary depending on your intent. General visitors, a free subscriber to our Services, or a paid subscriber to the Services. Please read the following carefully to understand how we collect, use, disclose and maintain the information associated with, or which relates to, you and/or could be used to identify you ("Personal Data"). In addition, this Privacy Policy describes your choices for use, access, and correction of your Personal Data. If you disagree with being bound by this Privacy Policy, please, stop using the Services immediately, including deactivating your account

Changes to this Privacy Policy.

We may amend, update or replace this Privacy Policy from time to time. If we make alterations, we will notify users after publishing and update the "Last Updated" alert at the top of this Privacy Policy accordingly. In the event of significant changes to this Privacy Policy, we will attempt to notify you directly by e-mail or provide information via our home page before modifications come into effect. We encourage you to review our Privacy Policy whenever you use the Services to stay informed of ways you can protect your privacy.

Information You Provide to Us.

We collect Personal Data that you decide to share with us directly. At times, we may also require you to provide certain information in order to use certain parts of our Services, fulfill your requests, or provide you with certain services.

2.1 Account Information. When you create an account, you may provide us with your name, Playtag, password, e-mail address, phone number (for verification purposes), date of birth, profile picture, and any other information you choose to upload to your account.

2.2 Paid Services. If you buy any paid Services (i.e., subscriptions, tokens, and merchandise), we may ask you to provide your name, billing address, telephone number, and e-mail address, as well as certain financial information (e.g., credit or debit card number) for purposes of processing that payment. Our payment processors receive and process your payment information. Depending on the processor, we may also receive and store certain billing information, including the last four digits of the credit card number associated with the transaction. Please note that our payment processors may use your payment-related information in accordance with their privacy policies.

2.3 Interactive Features. Our Services include certain interactive features and functionalities. This includes any content you upload to the Services, such as messages to other users, including drafts, comments, voice and image during streams, and any shared files. In connection with our interactive features, we may also collect the names of other users you choose to follow, including your public-facing profile and optional avatar photo. You may also share your location to find other users playing similar games in your geographic region. Note that any Personal Data you provide will be considered "public" when using our interactive features. Please exercise caution before revealing any information that may identify you in the real world to other users.

2.4 Social Media Data. We have pages on social media services such as Instagram, Facebook, and Twitter (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data you elect to provide to us, such as your contact details and messages sent. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

2.5 Contacting Us. You may interact with us through our Services, including through an online contact form, e-mail, surveys, or any other communication mechanism. If you contact us directly, we may receive additional information about you such as your name, e-mail address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

Information We Obtain from Others.

We may obtain additional Personal Data from third parties and sources other than the Services. For example, we may receive additional Personal Data from advertisers, games, or services you use, or social media networks for which you have approved our access. When you access the Services through social media networks or connect the Services to social media networks, you authorize SharePlay to collect, store, and use such Personal Data and content according to this Privacy Policy. We may also obtain Personal Data from third-party services regarding your use of such services, including your use of the content you choose to broadcast through the Services.

Information We Automatically Collect.

4.1 Log Information. We log usage data when you visit or otherwise use our Services, including our sites, app, and platform technology, such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles or apply for jobs. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use

4.2 Device and Location. When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL information of your origin and destination, including the time of your visit. We also acquire information about your network and device (e.g., IP address, proxy server, operating system, web browser, add-ons, device identifier and features, cookie IDs and/or Internet Service Provider, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

4.3 Crash and Error Information. If the Services crash or return an error, we may collect data to determine the cause of the error using first- or third-party services. The crash or error information collected may include the following: Device IP address, device name, operating system version, application configurations(s), the time and date, and other statistics.

4.4 Cookies and Other Technologies. Cookies and similar technologies (e.g., pixels and ad tags) (collectively, “Cookies”) are small files that, when placed on your device, enable us to collect certain information, including Personal Data, from you to provide certain features and functionality. Our service providers, business partners, and Shareplay use Cookies to collect data and recognize you and your device(s) on the Services and elsewhere across your different devices. We do this to better understand the effectiveness of the services' advertising and enhance your user experience. To learn more about cookies, please see Cookie Policy.

How We Use Your Information.

We may use your Personal Data for the limited purpose of providing the Services and related functionality and services, as described in this Privacy Policy and as permitted by applicable law. These purposes include circumstances where it is necessary to provide or fulfill the Services requested by or for you or where you have given us your express consent. We may use your Personal Data as follows:

(i) To provide and maintain our Services;

(ii) To manage your account and to provide you with effective customer service;

(iii) For the performance of a contract such as the development, compliance, and undertaking of the purchase contract for the products, items, or services you have purchased or of

(iv) To communicate with you by e-mail, text message, phone, and other methods of communication;

(v) To contact you with special offers, promotions, and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);

(vi) To contact you with information and notices related to your use of the Services;

(vii) To provide the information, products, and services you request;

(viii) For internal administrative and auditing purposes;

(ix) To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities;

(x) For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services,

(xi) To share content with other users at your direction;

(xii) To invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);

(xiii) To enforce our policies or other agreements;

(xiv) To combine information collected through the Services and from other sources so that such information can no longer be linked to you or your devices (“Aggregate/De-Identified

(xv) To use for any other purpose for which we provide notice at the time of collection; and

(xvi) To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

How We Share and Disclose Information.

6.1 Service Providers and Third-Parties. We do not sell Personal Data. We do not otherwise disclose the Personal Data we collect about you, except as described herein or otherwise disclosed to you at the time the data is collected. We may share your Personal Data with third-party vendors that perform tasks on our behalf and at our instruction. These third-party vendors may use your Personal Data only in connection with the services they perform on our behalf. They are bound to protect your Personal Data in a manner substantively consistent with our own policies and practices. In addition, you may choose to use certain features on our website for which we partner with other entities. These features are operated by third parties that are not affiliated with us. These third parties may use your Personal Data in accordance with their privacy policies. The relevant third parties are identified on the parts of the Services on which these features are offered. We strongly suggest you review the third-parties’ privacy policies if you use the relevant features.

6.2 Interactive Areas. When you share Personal Data or otherwise interact in the public areas with other users, other users may view such information. It may also be publicly available outside of the Services. Therefore, you should not expect privacy concerning such content.

6.3 Your Consent. We may share your Personal Data for other purposes under your consent or further direction.

6.4 Aggregate/De-Identified Data. From time to time, we may share Aggregate/De-Identified Information about the use of the Services, such as by publishing a report on usage trends. The sharing and our other use of such data are unrestricted.

6.5 Legal Reasons. We may also disclose your Personal Data 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 Personal Data to prevent or investigate a possible crime, such as fraud or identity theft, to protect the security of our Services, to enforce or apply our policies or other agreements, or to protect our rights or property, or the rights, property or safety of our users or others. We will attempt to notify our users about legal demands for their Personal Data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority.

6.6 Sale, Merger, or Other Business Transfer. 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), Personal Data may be among the transferred assets. If a portion or the entirety of our assets are sold or transferred to a third party, your Personal Data would likely become transferred as a business asset. We will comply with restrictions if such transfer is subject to additional mandatory conditions under applicable laws.

Your Choices.

(a) If you have registered for an account, you may access, review, update, or delete specific Personal Data provided to us by logging into your account and using available features and functionalities or by contacting us per the “Contact Us” section below. You may also contact us to delete your account. Please note that we will need to verify that you have the authority to delete the account. Particular activity generated before deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.

(b) Most web browsers are set to accept Cookies by default. You can set your browser to remove or reject Cookies if you prefer. Please note that if you choose to remove or decline Cookies, this could affect the availability and functionality of our Services. For more information, please see our Cookie Policy.

(c) You have a choice, at any time, to stop us from sending you e-mails for marketing purposes by following the "unsubscribe" link included in these messages. Please note that despite any indicated e-mail marketing preferences, we may continue to send you administrative e-mails, including, for example, notices of updates to our policies, including this Privacy Policy, if we choose to provide such statements in this manner.

(d) In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data required to use some features of our Services, you may be unable to utilize those features. We will tell you what Personal Data you must provide to receive the Services.

(e) Some browsers offer a “do not track” (“DNT”) option. Since no common industry or legal standard for DNT has, to date, been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make commercially reasonable efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

European and UK Residents.

8.1 Generally. If you are a resident of the European Economic Area or the United Kingdom (collectively, “Europe”), subject to any exemptions as provided by law, you may have certain rights regarding the Personal Data we maintain. We offer you specific choices about what Personal Data we collect from you, how we use that information, and how we communicate with you. If, at any time, you wish to exercise your rights, please reach out to us per the “Contact Us” section below.

8.2 Right of Access. If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with specific other details. If you require additional copies, we may need to charge you a reasonable fee.

8.3 Right to Rectification. If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.

8.4 Right to Erasure. ou may ask us to erase your Personal Data in some circumstances, such as where we no longer require it, or withdraw your consent (where applicable), and there is no other legal basis for processing.

8.5 Right to Restrict Processing. You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as if you contest its accuracy or object to us processing it.

8.6 Right to Data Portability. You have the right to obtain Personal Data provided to us under consent or provided to us as necessary in connection with our contract with you. This includes data provided for processing by automated means.

8.7 Right to Object. You may ask us, at any time, to stop processing your Personal Data, and we will do so: (a) if we are relying on a legitimate interest to process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise, or defend legal claims; or (b) we are processing your Personal Data for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt-out choices are respected in the future and to comply with data protection laws.

8.8 Right to Withdraw Consent. If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.

8.9 Right to lodge a Complaint. If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

US State Specific Provisions.

9.1 California Residents.

(a) If you are a resident of the State of California, you have certain rights afforded to you under the California Consumer Privacy Act or the "CCPA". When we say "Personal Information" in this Section, we indicate information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is aggregated or information that cannot be reasonably linked to you.

(b) We collect Personal Information and non-Personal Information for the business and commercial purposes described in the Section above titled "How We Use Your Information", and we share Personal Information with the categories of third parties described in the Section above titled "How We Share and Disclose Information". We do not presently sell (as such term is defined in the CCPA) the Personal Information we collect (and will not sell it, in the future, without providing a right to opt-out). Please note that we use third-party cookies for our advertising purposes, as described in the above section titled "Information We Automatically Collect".

(c) Subject to certain limitations, the CCPA provides California residents the following rights:

(i) You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and enquire about our data practices;

(ii) You have the right to request that we delete the Personal Information that we have collected from you;

(iii) You have the right to request that we no longer sell your Personal Information to third parties; and

(iv) We will not discriminate against you for exercising these rights.

(d) California residents may make a request pursuant to their "right to know", "right to request deletion", and/or "right to opt-out" under the CCPA by contacting us per the "Contact Us" section below. To verify your request to learn or delete information, we may require you to provide us with certain information to be used solely for the purpose of verifying your identity.

(e) Under the CCPA, you may exercise these rights yourself or designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent's identity.

9.2 Nevada Residents. Under State of Nevada law, certain Nevada consumers may opt-out of the sale of "personally identifiable information" for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by contacting us per the "Contact Us" section below. Please note that we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

Security.

We take reasonable precautions intended to help protect the Personal Data that we collect. Unfortunately, no system or online data transmission is entirely secure, and we cannot guarantee the security of data transmitted across the Internet. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information below.

Information Retention.

We will retain Personal Data required to comply with privacy requests, and manage active accounts, as required by law, to resolve disputes or enforce our agreements. We will retain the Personal Data we process on behalf of our users as directed by them. We may also retain copies of your Personal Data for disaster recovery purposes, prevent fraud or future abuse, or for legitimate business purposes.

Data Processing and Data Transfers.

To provide you with the Services, we may store, process, and transmit data in the United States and locations worldwide — including those outside of your country. Therefore, your Personal Data may be subject to privacy laws that are different from those in your country. Personal Data collected within Europe may, for example, be transferred to and processed by third parties located in a country outside of Europe. In such instances, we shall ensure that the transfer of your Personal Data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.

Information Security.

The security of your information is important to us. We use reasonable administrative, technical, and physical procedures, practices, and safeguards designed to protect the personal information we collect from unauthorized access, use, alteration, exfiltration, or destruction. Although we work hard to ensure the integrity and security of our systems, it must be recognized that no information system is 100% secure and, therefore, we cannot guarantee the security of such information. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the protection of user information at any time.

Links to Third-Party Websites.

The Services may contain links to other websites not operated or controlled by us, including social media services (“Third-Party Websites”). The information you share with Third-Party Websites is governed by the specific privacy policies and terms of service of said Third-Party Websites and not by this Privacy Policy. By providing these links, we do not imply that we endorse or have reviewed these websites. Please contact the Third-Party Websites directly for information on their privacy practices and policies.

Children’s Information.

The Services are directed to individuals aged thirteen (13) and over. Our Terms of Service require all users to be at least eighteen (18) years old. Minors who are at least 13 years old but are under 18 years old may use a parent or guardian's SharePlay account, but only with the involvement of the account holder. We do not knowingly collect Personal Data from individuals under the age of 13. If we become aware of individuals who have provided us with Personal Data and are under the age of 13, we will take steps to deactivate the account and delete the Personal Data. If you become aware of information from individuals under the age of 13 provided to us, please contact us per the "Contact Us" section below.

Contact Us.

If you have any questions or concerns about our Privacy Policy, please contact us via e-mail at privacy@shareplay.tv.