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Privacy Notice
Privacy Notice

Blitz Studios, Inc.

Sleeper HQ avatar
Written by Sleeper HQ
Updated over 5 months ago

Last Updated: July 19, 2024

Blitz Studios, Inc., and as applicable, its subsidiaries and affiliates (collectively, “Sleeper,” “we,” “our,” or “us”) own and operate the Sleeper mobile application and website, located at www.sleeper.app and www.sleeper.com, through which we offer free-to-play games, paid-entry contests of skill, and other games, tools, and fantasy sports-related products and services (collectively, the “Services”). Before accessing or using the Services, please read this Privacy Notice (the “Privacy Notice” or “Notice”).

This Privacy Notice shall be supplemental to, and hereby incorporate by reference, our General Terms of Use (the “GTOU”). This Notice and the GTOU, together with any additional terms, addendums, or documents that may be referenced herein (including, but not limited to, Sleeper’s Paid-Entry Contest Terms of Use), form an agreement between you and us in connection with the Services. Any capitalized terms not defined herein shall be given the meaning ascribed to them in the GTOU and/or Paid-Entry Contest Terms of Use. IF YOU DO NOT AGREE TO THIS PRIVACY NOTICE, THEN YOU MUST NOT ACCESS OR OTHERWISE USE THE SERVICES.

This Privacy Notice sets forth our practices for handling the information that we collect from or about you. It applies to any and all Services offered by Sleeper wherein this Notice is linked or otherwise referenced. By accessing the Services, you are consenting to the information collection and use practices described herein.

1. Collection of Information. We collect several types of information from and about users of our Services. This information is provided to us either directly by you or through your use of our Services.

Information You Provide to Us:

We collect the following categories of information when you use the Services:

  • Sign-in information, including e-mail address, name, authentication information, telephone/mobile phone numbers, and/or any passwords you create;

  • Profile information, including your interests, preferences, feedback, photograph, and/or avatar;

  • Age-range, and should you identity as under 18 (or as applicable, 16), your birthdate;

  • Identification and other verification information, should you seek to register for our paid-entry contests of skill – this information may include copies and information from identification documents (such as your driver’s license or passport), tax-related information, and any other information we may need to verify your identity and/or comply with applicable laws and regulations, and other sensitive personal information such as your social security number;

  • Services engagement information, including discussion topics you create or comment on, league information, information we collect from you when you connect to our Services to third-party platforms, websites, and/or social network services or use other social or player-to-player functionality, and/or information collected when you invite your friends to use the Services;

  • Photo, chat, and messages information, including photos, animated images, and direct or private messages sent to other users, as well as group messages sent to members of a particular group or league using our league-specific chat feature;

  • Commercial information, including records of products or services purchased or obtained, as well as other purchasing or consuming histories. By way of example only: a) if you use our paid entry contests of skill, we collect information about the contest entry fees you have paid, prize history, and/or withdrawal information; and b) where applicable, we collect information about your purchase of virtual currencies and virtual items within relevant portions of the Services;

  • Address book / contact information, in accordance with your device permissions;

  • Correspondence you send to us and other information, including information that you provide us with when you fill in forms or answer questions or surveys when using any of our Services, contact us through our customer service channels, respond to messages and communications that we send you, and/or interact with us on our social media channels;

  • Payment information, from you or on behalf of our payment service providers, including billing PayPal, and/or Venmo information; our payment service providers will provide us with information about your purchases to that we know if a purchase has been successful; when you purchase items via our mobile applications (such as those you can purchase in the App Store, on Facebook, and/or on GooglePlay), we do not receive any payment information from you;

  • Device error information, including information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and/or any communications or content provided at the time the error occurred; and/or

  • Any other information you provide to use directly or indirectly through using or otherwise accessing the Services.

We may automatically collect internet, electronic activity, and other information automatically from the devices and browsers that you use, including:

  • Your device type; internet protocol (IP) address;

  • Device and advertising identifiers;

  • Default device language;

  • Application usage information;

  • Browser type and version;

  • Operating system and platform;

  • Internet service provider;

  • Date and time of your visit;

  • Information about the links you click, pages you view, and advertising you interact with within the Services and other information about how you use and interact with the Services (by way of example only, this could include details about how and when you play our games or visit our website);

  • The technology on the devices you use to access the Services;

  • Standard server log information;

  • Probabilistic identifiers, other unique personal, and/or on-line identifiers;

  • Time zone setting and location;

  • Browsers plug-in types and versions;

  • Pages that you visit before and after using the Services, browsing history, and search history; and/or

  • Inferences used to create a profile about preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may also collect information about you from other affiliated or third-party companies (including but not limited to publishing partners, platforms, advertising platforms and partners, and/or data aggregators), which may include attributes about you and your interests, as well as other services you use, demographic data, and general location information.

In addition, we also receive information about you from other sources, including but not limited to, other users of our Services, and third-party services and organizations. By way of example only, if you access any social media or similar service through the Services (Facebook, Instagram, Tik Tok, X, etc.) to login or to share information with others, we may collect your user ID and username associated with that social media account, as well as any information you make public using that social media account. We may also collect information you have authorized the social media service to share with us (such as your user ID, public profile information, email address, birthday, friends lists, and pages you have “liked”).

We will use the information as described herein subject to any limitation this Notice sets forth, as well as any applicable law. Information collected from third-parties referenced herein may also be subject to their own privacy policies and other rules/regulations.

2. Use of Information and Purpose of Data Processing. We use and otherwise process each of the categories of information identified above for various business purposes, including but not limited to:

  • Administering and providing products and services that you request, including allowing you to participate in games and other features of our Services, engaging with other users through our social features, managing your account, and processing your payments, deposits, withdrawals, and/or other account activity;

  • Communicating with you, including making suggestions and recommendations to you, sending you promotional materials from us or on a third-party’s behalf, and notifying you about changes to this Notice and/or relevant terms;

  • We may use your information to send you direct marketing and promotional materials relating to our Services and/or other products (including by e-mail) on our or a third-party’s behalf;

  • Verifying your identity and information, such as when you register to play paid entry contests of skill or where otherwise appropriate;

  • Improving our Services and to ensure that content is presented in the most relevant and effective manner for you and your device, including troubleshooting, data analytics, testing, research, and statistical and survey purposes; we may also use personal information to create aggregate or de-identified information that is no longer subject to this Notice;

  • Providing you relevant advertising, including advertising that you see while using the Services;

  • Keeping our Services, businesses, and users safe and secure, complying with applicable laws and regulations, and protecting or exercising our legal rights, including defending against legal claims; by way of example only, this includes use of your information to detect, prevent, and investigate fraud and other illegal activity and violations of this Notice and/or or other guidelines/rules; we may monitor chat, direct messaging, and other messages sent through the Services for these purposes;

  • As described to you when collecting your information; and/or

  • For any other lawful purpose.

3. Disclosure of Information. We are committed to maintaining your trust, and we want you to understand when and with whom we may share information we collect, which may include but not be limited to:

  • Authorized third-party vendors and service providers. We share your information with third-party vendors and service providers who provide services to us for a variety of business purposes, such as identity verification, payment processing, customer service, e-mail deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, and processing or fulfilling orders and transactions. These third-parties collect, use, and access your data to perform their functions, and we may allow them to use information about you for their own purposes in accordance with applicable law;

  • Chat, testimonial, and other social features. Your information may be shared with other users and made public if you use certain functionalities of our Services. By way of example only, the Services may include social features that enable you to interact with other users. These features may enable other users to your username, avatar, scoring, and/or other gameplay-related information. Depending on your settings, other information in your profile may be shared with other users. In addition, other users may be able to see anything that you post to any public discussion topic, channel, chat, and/or other open areas in our Services (the “Public Areas”). We may publish the information you submit to us alongside your name, username, and/or location on our website(s), scores, social media channels, for promotional purposes. You should use caution in disclosing information while utilizing using the Public Areas and we are not responsible for the information you choose to submit therein;

  • Corporate affiliates. We may share your information with our corporate affiliates;

  • Business transfers. We may share your information in connection with a corporate transaction, such as sales, mergers, consolidations, an initial public offering, and/or in the unlikely event of a bankruptcy;

  • Legal purposes. We may disclose your information to respond to subpoenas, court orders, the general legal process, law enforcement requests, claims, and/or government/regulatory authority inquiries (including those made by the Internal Revenue Service and other appropriate taxing authorities), and to protect and defend the rights, interests, safety, and security of Sleeper, our affiliates, users, and/or the public; and/or

  • With your consent and/or direction. We may share your information for any other purpose disclosed to you at the time we collect and/or share the information, pursuant to your consent or direction. By way of example only, we may provide your personal information to payment processors in order to process payment instruction.

In the preceding 12 months, we have disclosed your information for the following business purposes. The table below describes the categories of information in the left column, examples of data types within the applicable categories in the middle column and the right column states the categories of recipients that receive such information as part of disclosures business purposes.

Category of Personal Data

Examples of Personal Data types within the category

Categories of recipients

Identifiers and Contact Information

Contact information, Username, Unique IDs & Account Details, Financial Account Information, Government-issued IDs

· Software and other business vendors,

· Marketing Vendors,

· Affiliates and related entities.

Personal Records

Contact information, Unique IDs & Account Details, Financial Account Information, Government-issued IDs

· Business Vendors,

· Marketing Vendors,

· Affiliates and related entities.

Customer Account Details/Commercial Information

General demographics & Psychographics, Transaction and Commercial Information, Online and Technical Information

· Business Vendors,

· Marketing Vendors,

· Affiliates and related entities.

Internet Usage Information

Transaction and Commercial Information, Online and Technical Information

· Business Vendors,

· Marketing Vendors,

· Affiliates and related entities.

Location Data

Imprecise Location Data

· Business Vendors,

· Marketing Vendors,

· Affiliates and related entities.

Professional or employment related information

General Demographics & Psychographics, Contact information, Government-issued IDs.

· Business Vendors,

· Marketing Vendors,

· Affiliates and related entities.

Inferences drawn from other information received.

General Demographics & Psychographics, Inferred Information.

· Business Vendors,

· Marketing Vendors,

· Affiliates and related entities.

Sensitive personal information

*This information is collected only from users who participate in Sleeper's paid-entry contests of skill and is primarily used to fulfill our legal and compliance obligations.

Credit or debit card numbers, financial account numbers, government-issued identification numbers (such as driver's license, social security number, etc.), and precise geolocation.

· Business Vendors,

· Marketing Vendors,

· Affiliates and related entities.

4. Advertising, Cookies, and Similar Technologies. When you use the Services we, along with our third-party advertising partners (including but not limited to ad exchanges, ad networks, and/or ad servers) use cookies, pixel tags, local storage, mobile advertising IDs, and other similar technologies (collectively, “Cookies”) to collect information from your browser and/or device.

We use various service providers to help analyze how people use our Services. These service providers use cookies and similar technologies to collect information pertaining to how people use our website and mobile application and elsewhere based on your on-line activities over time and across different sites, services, and devices, as well as for other lawful purposes. We use the information we get from these service providers to improve and optimize our website, mobile application, and Services.

One of the service providers we use is Google Analytics, which helps us understand how you use our Services. Google Analytics collects data about your traffic via Google advertising Cookies and anonymous identifiers, as well as data collected through standard Google Analytics implementation.

Our use of Cookies is detailed below.

You may revoke your consent to the use of web analysis at any time, either by downloading and installing the provided Google Browser Plugin or by following your internet browser’s instructions to enable, disable, or clear Cookies.

By using the Services, you consent to our use of Cookies and other similar technologies. The following non-exhaustive list notes some of the types of Cookies that are used on our Services:

  • Essential Cookies – These enable you to use our Services and are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. Without them, certain parts of the Services cannot be provided. These also help keep our Services safe and secure;

  • Preference Cookies – These store information such as your preferred country and language selection, login data, and website preferences. Without them, our Services may not be able to remember certain choices you have previously made (such as a saved country or language preference) or personalize your browsing experience by providing you with relevant information. These can also be used to recognize your device so that you do not have to provide the same information more than once;

  • Performance Cookies – These collect information about how you use our Services such as which pages or parts of them you visit regularly. These are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages; and

  • Content/Advertising Cookies – These gather information about your use of the Services so we may improve your experience and provide you with more relevant content and advertising on our Services and elsewhere on-line and across your devices. They are also used to gather feedback on customer satisfaction through surveys. They remember that you’ve visited our Services and help us understand usage of our Services. Some of them are from third-parties that collect information about your use of the Services in order to provide advertising (on our Services and elsewhere) based on your on-line activities. We do not control the privacy practices of these third-parties, and said practices are not covered by this Notice, you should review their terms prior to any disclosure.

Some mobile and web browsers transmit “do not track” signals, which send a signal to websites visited by you about your browser's do not track preference settings. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of their existence. Our website is not currently configured to alter its behavior or respond to “do not track” signals, or other mechanisms that may allow you to opt out of the collection of your information across websites.

5. Third-Party Data Collection and Advertising Practices

We engage third parties to collect information through our Services, which helps us deliver targeted advertising based on your online activities across different websites, services, and devices. Some of these partners are members of the Network Advertising Initiative ("NAI"), which provides a centralized service to opt-out of ad targeting from member companies. For more information or to opt out, visit the NAI Consumer Opt Out page.

6. U.S. State Privacy Notice

You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, rectification, erasure, and portability of your information or as applicable, more information about our practices.

This U.S. State Privacy Notice is designed to provide you with notice of our recent information practices over the prior 12 months from the “Last Updated” date of this Privacy Statement. This U.S State Privacy Notice also applies to our current data practices such that it is also meant to provide you with “notice at collection.”

For any new or substantially different processing activities that are not described in this U.S. State Privacy Notice, we will notify you as required by the applicable U.S. Privacy Laws, by updating this U.S. State Privacy Notice.

Generally, we collect, retain, use and disclose your information for business purposes, that you have consented to, and as outlined in this Notice. We do not sell your information for monetary consideration; however, we may share your information with third-party service providers in a way that may be considered a sale of your information under applicable U.S. Privacy Laws. These sales are subject to your right to opt-out.

Under certain U.S. Privacy Laws, you have specific rights regarding your information. Other jurisdictions, or countries (see additional Sections) may also provide similar rights. This section describes U.S. Privacy Law rights you may have and how to exercise those rights. For any of the following rights, we will first verify your identity prior to providing any information. We may verify your request, such as by requesting additional information from you.

  • Right to Know and Data Portability: You have the right to request that we disclose certain information to you about our collection and use of your information over the past 12 months, which includes:

    • The categories of information we collect about you;

    • The categories of sources from which we collected information;

    • Our business or commercial purpose for collecting or selling (when applicable) that information;

    • The categories of third parties with whom we share information; and/or

    • The categories of information about you that we disclosed for a business purpose, and the categories of service providers to whom disclosed that information for a business purpose.

Additionally, you may request that we provide the specific pieces of information we collect about you in a portable format.

  • Right to Delete: You have the right to request that we delete any of your information that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

    • Complete the transaction for which we collected the information, provide the services you have requested, or take actions reasonably anticipated within the context of our ongoing business relationship;

    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

    • Enable (internal only) uses that are reasonably aligned with consumer expectations based on your relationship with us;

    • Comply with a legal obligation; and/or

    • Other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify your information not subject to one of the foregoing exceptions from our records and will direct our service providers to take similar action.

  • Right to Correct: You have the right to request correction of any inaccurate information we hold about you.

  • Right to opt-out of a sale: You have the right to opt-out of our sale or our use of information for targeted advertising purposes.

  • Right to receive notice: You have the right to receive notice of our practices at or before collection of information and you have a right not to receive discriminatory treatment for exercising any of your rights described under this section. We will not discriminate against you based on your exercise of any of your rights.

Depending on your place of residence, you may be limited to the number of free requests you can make in a 12-month period. If you exceed the number of requests allotted under applicable law, we reserve the right to charge a reasonable fee to respond to your request.

Requests should be submitted in writing via email to [email protected]. If you become aware of changes or inaccuracies in your information, you should inform us of the same so that the information may be updated and/or corrected.

If you are in a jurisdiction that recognizes the ability to use an authorized agent and wish to contact us through an authorized agent, the authorized agent can submit a request on your behalf to [email protected], along with an authorized agent form.

If you are in a jurisdiction that recognizes your ability to appeal a decision we have made in connection with your attempt to assert a right under applicable U.S. State Privacy Laws, you may file an appeal of our decision refusing your request to exercise your rights under this Privacy Statement. Requests to change our policies or practices are not grounds for an appeal. You may request an appeal of such decision by contacting us at [email protected], please provide the state that you are writing from, accompanied with documentation that you may have regarding the matter you are appealing.

California Shine the Light Law: California residents may opt out of the sharing of personal information (as defined by California’s “Shine the Light law”), with third parties for their own direct marketing purposes. California residents may opt out and/or request for an accounting of what third-parties we have shared your personal information with. This right is in addition to and different than rights granted to California residents pursuant to the California Consumer Privacy Act (CCPA). California residents exercising their Shine the Light rights should mail requests to our address below identifying the request as a Shine the Light Request and include a statement attesting to your California residency.

7. United Kingdom and European Economic Area (the “EEA”)

If you are a user in the European Union, you are afforded additional rights under the law. You can exercise any of the following rights by directly making changes in your account or notifying us as described below.

  • Access. You can access and verify what information our Services have collected and currently contains by logging into your account and visiting your account profile page.

  • Correction or Rectification. If any of your information is incorrect, you may change or request that your information be corrected by submitting a request as described below. Where applicable, we will ensure such changes are shared with any trusted third parties.

  • Restrict Processing. When applicable, you may restrict the processing of your information through the Services by submitting a request via email as described below. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Notice, to include withdrawing your consent (resulting in deleting your account and any associated information). Where applicable, we will ensure such changes are shared with any trusted third parties.

  • Object to Processing. When applicable, you have the right to object to the processing of your information by submitting a request via email as described below. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Notice, to include withdrawing your consent (resulting in deleting your account and any associated information). Where applicable, we will ensure such changes are shared with any trusted third parties.

  • Portability. Upon request, and when possible, we can provide you copies of your information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Privacy Notice, which include withdrawing your consent (resulting in deleting your account and any associated information). Where applicable, we will ensure such changes are shared with any trusted third parties.

  • Withdraw Consent. At any time, you may withdraw your consent to our processing of your information by notifying us at [email protected]. Using the same email address associated with your account, simply type the words “WITHDRAW CONSENT” in the subject line of an email and send it to the email address below. Upon receipt of such a withdrawal of consent, we will confirm receipt, proceed to stop processing your information and erase your data (and delete your account and any associated information) in accordance with this Privacy Notice. Where applicable, we will ensure such changes are shared with any trusted third parties.

  • Erasure. If you should wish to cease use of your account and have your information deleted from our Services, please notify us at [email protected]. We will confirm receipt and erase your information (and delete your account and any associated information). Where applicable, we will ensure such changes are shared with any trusted third parties.

We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Our lawful basis for processing, including basis of legitimate interest, includes but is not limited to:

  • Providing you with the products and services that you request from us;

  • Allowing you to participate in games and other features of the Services;

  • Engaging with other users through our social features;

  • Managing your account;

  • Verifying your identity and information to access certain features;

  • Notifying you about changes to our GTOU or Privacy Notice;

  • Improving our Services and ensuring that content is presented in the most relevant and effective manner for you and for your device;

  • Administering our Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes;

  • Keeping our Services, business and users safe and secure;

  • Complying with applicable laws and regulations; and

  • Protecting or exercising our legal rights or defend against legal claims.

Where legally required, and we have no other valid legal basis to process your information, we will obtain consent (by way of example, to provide you with marketing information or share information with third-parties), which may subsequently be withdrawn at any time by contacting us. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn. Where we need to collect information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to you with the Services or portions thereof. You may lodge a complaint with a supervisory authority if you believe our processing of your information is unlawful. Please submit any such requests by sending an e-mail to [email protected].

Active monthly users (as of June 30, 2024): Under Article 24 of the Digital Services Act (the "DSA"), on-line platforms are required to publish information on the average monthly active recipients of services in the EU at least every six (6) months. This is for the purposes of determining whether an on-line platform is a very large on-line platform ("VLOP"), reaching an average of at least 45 million users per month in the EU (i.e., representing 10% of the EU population). VLOPs are subject to additional requirements due to the role they play in the dissemination of content throughout the EU. Article 24(2) and other provisions of the DSA provide guidance for on-line platforms in calculating the number of average monthly active recipients of the service, including limiting this number to recipients located in the EU, excluding visits from automated bots and scrapers, and counting only unique visits, i.e., counting multiple visits by the same user to different sites or interfaces of the same platform only once in each month. We have calculated the average monthly active recipients of our platform services in the EU based on the period from January 1, 2024 to June 30, 2024, in accordance with Recital 77 of the DSA. Our conclusion is that during this period the average number of monthly active recipients of our platform services in the EU was below the 45 million users threshold for being designated as a VLOP. We will continue to monitor the number of average monthly active recipients of our platform services in the EU and will publish updated information in accordance with Article 24(2).

Note that Blitz Studios, Inc. is the controller of personal data collected through the Services.

8. Canada (PIPEDA)

If you are a user in Canada, you are afforded specific rights regarding your information. You can make any of the following requests, and we will respond to your request as soon as possible, and in any event, no later than thirty (30) days after receipt, unless we notify you otherwise.

  • Right to Know. You have the right to request that we disclose certain information about our collection and use of your information, including:

    • The information we collected about you;

    • Where the information was obtained from; and

    • How the information is or has been used and who it has been disclosed.

  • Portability. Upon request, and when possible, we can provide you copies of your information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Notice, which include withdrawing your consent (resulting in deleting your account and any associated information). Where applicable, we will ensure such changes are shared with any trusted third-parties.

  • Correction. If any of your information is incorrect, you may change or request that your information be corrected by submitting a request as described below. Where applicable, we will ensure such changes are shared with any trusted third-parties.

  • Deletion. If you wish to cease use of your account and have your information deleted from our Services, please notify us at [email protected]. We will confirm receipt and erase your information (and delete your account and any associated information). Where applicable, we will ensure such changes are shared with any trusted third-parties.

We may refuse to provide information in the event; we cannot confirm your identity or you fail to provide information necessary for us to locate your information, for situations in which searching for and providing your information is prohibitively costly, where the information contains references to other individuals, or when information cannot be disclosed for legal, security, or commercial proprietary reasons.

9. Minors. Our Services are not intended for individuals who are defined as minors for purposes of processing personally identifiable information under applicable law. We do not knowingly collect or retain personal information from minors via our Services. If we discover that a minor has submitted personal information through any of these channels, we will promptly remove such information from our records and delete your account. If you are a parent or legal guardian and believe that your minor child has provided personal information to us, please reach out to our privacy team at [email protected], and we will ensure that the child's information is deleted.

10. International Transfers. By using our Services and providing us with information, you understand that your information is being collected and stored on, and may be transferred to, servers located outside your resident jurisdiction. We and many of our third-party vendors are based in the United States, and your information is being processed by us both here and in other jurisdictions where laws may not be equivalent to those where you reside. To the extent we disclose your information to third-party vendors, we use contractual safeguards to help ensure that such third-party vendors are bound to duties of confidentiality. Where local law permits, you are deemed to have consented to these data transfer practices through your use of the Services. If you do not consent to these data transfers practices, please do not use the Services. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) with respect to data protection issues. If you would like further information please contact us. Except as set forth herein or if we have obtained your explicit consent, we will not transfer your personal information outside of the EEA.

11. Data Retention, Security, and Integrity. Your information will be retained only for so long as reasonably necessary, for the purposes set out herein, and in accordance with applicable law. We maintain security measures to safeguard your information from loss, theft, interference, misuse, unauthorized access, disclosure, alteration, and/or destruction. However, you should understand that no data storage system or transmission of data over the internet or any other public network can be guaranteed to be 100% secure, accurate, complete, and/or current. Please note that information collected by third-parties may not have the same security protections as the information you submit to us, and we are not responsible for protecting the security of such information.

12. Changes to the Privacy Notice. We may modify this Notice from time to time, in our sole discretion. When any such updates are made, we shall revise the “Effective Date” above and post the new Notice version. We recommend that you review the Privacy Notice each time you visit and/or use the Services in order to stay informed of our ongoing practices.

13. Contact. Any questions, comments, complaints, and/or submissions referenced herein pertaining to this Privacy Notice should be e-mailed to our Data Protection Officer at [email protected] and/or mailed to 548 Market Street, PMB 95988, San Francisco, CA 94104, Attn: Blitz Studios, Inc.

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