Last Updated: July 22, 2020

INTRODUCTION

This Privacy Policy governs the way TriviaMaker (“TriviaMaker”, “we”, “our”, or, “Company”) collects, uses, maintains and discloses information collected from and about you as well as your rights and choices regarding such information. It applies to your use of any online service location that posts a link to this Privacy Policy including, without limitation, the Trivia Maker website or application (“Site”) and any offline location that makes this Privacy Policy available to you. This Privacy Policy does not describe information collection practices on other websites, including those linked to or from our website. Please see the “Other Parties” section below for more details.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Complaints and Contact Information” section. If you are a Nevada resident, California resident, or data subject in Europe, please see the additional disclosures at the end of this Privacy Policy.

PURPOSE OF THIS PRIVACY POLICY

The purpose of this Privacy Policy is to help you better understand how we store, collect, and process your information. In particular, by using the Site or interacting with us offline, you agree to our Terms of Use and you consent to our collection, use, and disclosure of your information, and other activities as described in this Privacy Policy, including any updates or revisions to this Privacy Policy. If you do not agree, discontinue use of the Site.

CHANGES TO THIS PRIVACY POLICY

TriviaMaker has the discretion to update this Privacy Policy at any time. When we do, we will revise the updated date. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of the Site indicates your consent to the Privacy Policy then posted.

INFORMATION TRIVIAMAKER COLLECTS

When you engage in certain activities via the Site, including but not limited to creating an account, sending feedback, or otherwise participating in the Site, or interacting with us offline, we collect certain information about you. We collect the following categories of information:

  • Account Data, including your username, password, and information for authentication and account access.
  • Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
  • Contact Data, including your email address.
  • Profile Data, including games you created, your collections, and your favorites.
  • Content, including content within any messages you send to us (such as feedback and questions to customer support).

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.

INFORMATION COLLECTED AUTOMATICALLY

In addition, we automatically collect information when you use the Site. The categories of information we automatically collect include:

  • Service Use Data, including data about features you use, pages you visit, emails, and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
  • Device Data, including data about your device’s identification number and device type, your device’s operating software, your internet service provider, your device’s regional and language settings, device identifiers such as IP address and Ad Id, your mobile carrier, and your mobile carrier user identification.
  • Location Data, including imprecise location data (such as location derived from an IP address or data that indicated a city or postal code level) and, with your consent, location data (such as latitude/longitude data).

COOKIES AND RELATED TRACKING TECHNOLOGIES

Our Site uses tracking technologies to automatically collect information. The types of tracking technologies we use include:

Log files, which are files that record event that occur in connection with your use of the Site.

Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Site and can be used to track your session on the Site. They expire when you close your browser. Persistent cookies are used to customize our website content for you as an individual, remember your preferences, and support security features. Additionally, persistent cookies allow us to bring you advertising off the Site. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.

Pixels (also known as web beacons), which is code embedded when you access our Site, in our emails with you, and in our products and services that send information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). We use pixels in combination with cookies to attribute visits to our websites to other sources, to serve ads from our vendors, to measure performance and engagement, and to provide you with additional functionality.

Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.

App Technologies, which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps include SDKs, including the Facebook SDK, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.

Location-Identifying Technologies, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.

INFORMATION WE COLLECT FROM OTHER SOURCES

We also collect information from other sources. The categories of sources from which we collect information include:

  • Social networks with which you interact.
  • Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
  • Publicly available sources, including data in the public domain.

PURPOSE FOR USING YOUR INFORMATION

TriviaMaker collects and uses information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include the following:

  1. To operate, manage, and improve the Site;
  2. To perform services requested by you, such as respond to service requests and support customer needs more efficiently;
  3. To personalize user experience;
  4. To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
  5. To prevent and address fraud, breach of policies or terms, and threats of harm;
  6. We use information in the aggregate to understand how our users as a group use the services and resources provided on the Site;
  7. To conduct research, including focus groups and surveys;
  8. To improve our Site and other TriviaMaker websites, apps, marketing efforts, products and services;
  9. To run a promotion, contest, or other Site feature, including verifying your eligibility and delivering prizes in connection with your winning entries;
  10. To develop and send advertising, direct marketing, and communications about topics we think will be of interest, and about our and other entities’ products, offers, promotions, rewards, events, and services;
  11. To send periodic emails;
  12. To fulfill any other purpose at your direction; and
  13. With notice to you and your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

ANALYTICS AND ADVERTISING

We use analytics services, such as Google Analytics, to help us understand how users access and use the Site. In addition, we work with agencies, advertisers, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may use tracking technologies, such as cookies, pixels, and web beacons, in the Site, including when you use or interact with our Site, marketing communications, advertising content and/or other websites, in order to provide you with relevant advertising based on your browsing activities and interests across time and services (“Interest-based Advertising”).

We also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own Service, and the other party matching common factors between our data and their data or other datasets. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.

Vendors and other parties, as we will indicate below, may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Site and your rights and choices regarding analytics, Matched Ads and Interest-based Advertising, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

SHARING OF INFORMATION

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information include:

  • Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
  • Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section above.
  • Affiliates. We share information with our affiliates and related entities, including where they act as our service provider or for their own internal purposes.
  • Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
  • Promotions. Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern the promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
  • While you are visiting the Site, you may have the opportunity to participate in surveys or other interactive features that request information about you and your opinions and preferences. Your participation in these features is entirely voluntary. If you do choose to participate, please be aware that these features may be operated by an entity that is not controlled by TriviaMaker, and therefore the information you provide may be collected by the other entity and subject to its privacy policy.
  • Public Forums. We share information you make public through the Site, such as trivia games you submit to the Public Collections forum. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
  • Mergers or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Site or anyone else.
  • Facilitating Requests. We share information at your request or direction.
  • Consent. We share information with notice to you and your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has be aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

OTHER PARTIES

We offer parts of the Site through links to sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other entities. In addition, we integrate technologies operated or controlled by other parties into parts of the Site. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these websites or services, including their content and links, may constantly change. These websites and services have their own policies that govern their independent collection and solicitation of information from you. Browsing and interacting with any other website, including websites which have a link to the Site, is subject to that website’s own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the United States or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Some examples include:

  • Links. The Site includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
  • Liking, Sharing, and Logging-In. We may embed a pixel or SDK (e.g., Facebook SDK) on our Site that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
  • Brand Pages and Chatbots. We may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Site on social media (e.g., by using a hashtag associate with TriviaMaker in a tweet or post), we may use your reference on or in connection with our Site.

YOUR RIGHTS AND CHOICES

  1. How to Opt Out Of Email Communications

You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Complaints and Contact Information” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.

  1. Push Notifications

If you use our mobile apps, we may ask if you want to receive push notifications so that we can send you updates, communications, and other messages about the Site. To opt out of getting these push notifications or other messages, you must turn off the push notification function in your device settings.

Please note that your opt-out is limited to the email address and device used and will not affect subsequent subscriptions.

  1. Tracking Technology Choices

Cookies and Pixels. Most browsers accept cookies by default. You can set up your browser to either let you know when you receive a cookie, to decline cookies, or to deny cookie access to your computer. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.

Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor “Do Not Track” signals or alter our information collection and usage practices when we detect such a signal from your browser. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.

App and Location Technologies. You can stop all collection of information via our app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.

Please be aware that if you disable or remove tracking technologies some parts of the Site may not function correctly.

  1. Analytics and Interest-Based Advertising

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt Out of Interest-Based Ads” (for Android devices).

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt-out options or programs.

CHILDREN’S PRIVACY

The Site is intended for general audiences and is not directed at children under 18 years old. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If  you are a parent or guardian and believe we have collected personal information in violation of COPPA, or if we learn we have collected or received personal information from a child under 18, we will remove that personal information in accordance with COPPA. If you believe we have any personal information from or about your child under 18, please contact us at info@redwoodpromedia.com. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

If you are a California resident under 18 years old and registered to use the Site, you can ask us to remove any content or information you have posted on the Site. To make a request, email us at the email address set out in the “Complaints and Contact Information” section with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with out legal obligations, resolve disputes, and enforce our agreements.

DATA SECURITY

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

INTERNATIONAL TRANSFER

We are based in the United States and the information we collect is governed by United States law. If you are accessing the Site from outside the United States , please be aware that information collected through the Site may be transferred to, processed, stored, and used in the United States and other jurisdictions. Data protection laws in the United States and other jurisdictions may be different from those of your country of residence. Your use of the Site or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the United States and other jurisdictions as set out in this Privacy Policy.

ANTI-SPAM POLICY

If you subscribe to electronic newsletters or other communications from us or our website, you will have an option to unsubscribe immediately.

We fully endorse and comply with the requirements of Canada’s anti-spam legislation (CASL) and CAN-SPAM Act of 2003 (Controlling the Assault of Non-Solicited Pornography and Marketing Act), and all other applicable unsolicited commercial e-mail laws.

For more information on your rights and choices regarding promotional emails please see the “Your Rights and Choices” section above.

COMPLAINTS & CONTACT INFORMATION

If you have any questions about this Privacy Policy, please contact us at:

Redwood Pro Media LLC

P.O. Box 912

Crescent City, CA 95531

info@redwoodpromedia.com

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at support@triviamaker.com

OUR NOTICE TO NEVADA RESIDENTS

Under Nevada law, Nevada residents may opt out of the sale of certain “covered information” collected by operators of websites or online services or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please email us at info@redwoodpromedia.com and provide your name and whether you would like to opt out.

OUR NOTICE TO CALIFORNIS RESIDENTS

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.

  1. Notice of Collection.

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

  • Identifiers, including name, postal address, email address, and online identifiers (such as IP address).
  • Customer records, including credit or debit card information.
  • Commercial or transactions information, including records of products or services purchased, obtained, or considered.
  • Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
  • Geolocation data.
  • Inferences drawn from the above information about your predicted characteristics and preferences.

For further details on information we collect, including the sources from which we receive information, review the “Information TriviaMaker Collects” section above. We collect and use these categories of personal information for the business purposes described in the “Purpose for Using Your Information” section above, including to manage our Site.

Under the CCPA, “sell” is defined broadly, and some of our data sharing practices may be considered a “sale.”

We do not generally sell information as the term “sell” is traditionally understood.

To the extent “sale” under the CCPA is interpreted to include the activities set out in this Privacy Policy, such as those disclosed in the “Analytics and Advertising” section above, we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, geolocation data, and inferences drawn. Please review the “Sharing of Information” section above for further details about the categories of parties with whom we share information.

  1. Right to Know and Delete.

You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose or sold;
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.

In addition, you have the right to delete the personal information we have collected from you.

To exercise any of these rights, please submit a request through our Online Form or email us at support@triviamaker.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

  1. Right to Opt-Out.

To the extent TriviaMaker sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by  emailing us at support@triviamaker.com.

  1. Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

  1. Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

 

  1. Shine the Light.

 

If you are a California resident, you may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Complaints and Contact Information” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

 

OUR NOTICE TO DATA SUBJECTS IN EUROPE

  1. Roles

Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). TriviaMaker acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.

  1. Lawful Basis for Processing

Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.

  1. Your Data Subject Rights

Your principal rights under data protection laws in Europe are:

(a)        The right to access;

(b)        The right to rectification;

(c)        The right to erasure;

(d)        The right to restrict processing;

(e)        The right to object to processing;

(f)         The right to data portability;

(g)        The right to complain to a supervisory authority; and

(h)        The right to withdraw consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, please contact us as set out in the “Complaints and Contact Information” section above and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.

Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, you may contact us at support@triviamaker.com. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.