Privacy Policy

TREZURE INC PRIVACY POLICY

Trezure INC., and as applicable, its subsidiaries and affiliates (collectively, “Trezure,” “we,” “our,” or “us”) own and operate the Trezure mobile application and website, located at www.playtrezure.com., through which we offer free-to-play games, paid contests of skill, and other fantasy sports-related products and services (collectively, the “Services”). Before accessing or using the Services, please read this Privacy Policy (the “Privacy Policy” or “Policy”) (as well as our Terms of Use).

By creating an account or otherwise accessing and using the Services, you agree to be bound by this Privacy Policy, our Terms of Use, and all applicable contest rules that may be published on the Services by Trezure, which form a legal agreement between you and us. If you do not agree to this Privacy Policy, then you may not access or otherwise use the Services.

This Privacy Policy sets forth our practices for handling the information that we collect from or about you. It applies to any and all Services offered by Trezure. By accessing the Services, you are consenting to the information collection and use practices described herein.

This Policy may be updated, from time to time, in Trezure's sole discretion. You will be notified of such updates inside our app, and asked to agree to the Policy before proceeding.

1. Collection of Information. We collect the following categories of information when you use the Services, which shall include but not be limited to:

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

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

· 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;

· 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 or PayPal 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;

· Information we collect automatically – We may 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; and

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

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 to login or to share information with others, we may collect such information.

We will use the information as described herein subject to any limitation this Policy 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 Policy and/or relevant terms;

· 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 disidentified information that is no longer subject to this Policy;

· 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 Policy and/or or other guidelines/rules; we may monitor chat, direct messaging, and other messages sent through the Services for these purposes; and

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 Trezure, our affiliates, users, and/or the public; and

· 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.

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. This is done in order to provide analytics and advertising on our Services and elsewhere based on your on-line activities over time and across different sites, services, and devices, as well as for other lawful purposes. By using the Services, you consent to our use of Cookies and other similar technologies. The following non-exhaustive list notes some 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;