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  • ChefTomato privacy policy

Chef Tomato Privacy Policy

 

CHEF TOMATO PRIVACY POLICY

Last updated December 27, 2023

This privacy notice for TREOPLAY ("we," "us," or "our"), describes how and why we

might collect, store, use, and/or share ("process") your information when you use our

services ("Services"), such as when you:

  • Visit our website at http://www.cheftomato.com, or any website of ours that links to this privacy notice
  • Download and use our mobile application (Chef Tomato), or any other application of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your

privacy rights and choices. If you do not agree with our policies and practices, please

do not use our Services. If you still have any questions or concerns, please contact

us at johnray@treoplay.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find

out more details about any of these topics by clicking the link following each

key point or by using our table of contents below to find the section you are

looking for.

What personal information do we process? When you visit, use, or navigate our

Services, we may process personal information depending on how you interact with

us and the Services, the choices you make, and the products and features you use.

Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We may process sensitive

personal information when necessary with your consent or as otherwise permitted by

applicable law. Learn more about sensitive information we process.

Do we receive any information from third parties? We may receive information

from public databases, marketing partners, social media platforms, and other outside

sources. Learn more about information collected from other sources.

How do we process your information? We process your information to provide,

improve, and administer our Services, communicate with you, for security and fraud

prevention, and to comply with law. We may also process your information for other

purposes with your consent. We process your information only when we have a valid

legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information?

We may share information in specific situations and with specific third parties. Learn

more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical

processes and procedures in place to protect your personal information. However, no

electronic transmission over the internet or information storage technology can be

guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,

cybercriminals, or other unauthorized third parties will not be able to defeat our

security and improperly collect, access, steal, or modify your information. Learn more

about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the

applicable privacy law may mean you have certain rights regarding your personal

information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request

in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the

privacy notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL

INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

9. HOW LONG DO WE KEEP YOUR INFORMATION?

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

11. WHAT ARE YOUR PRIVACY RIGHTS?

12. CONTROLS FOR DO-NOT-TRACK FEATURES

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

15. DO WE MAKE UPDATES TO THIS NOTICE?

16. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT

FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register

on the Services, express an interest in obtaining information about us or our products

and Services, when you participate in activities on the Services, or otherwise when

you contact us.

Personal Information Provided by You. The personal information that we collect

depends on the context of your interactions with us and the Services, the choices you

make, and the products and features you use. The personal information we collect

may include the following:

debit/credit card numbers

billing addresses

contact or authentication data

contact preferences

usernames

mailing addresses

email addresses

phone numbers

names

Sensitive Information. When necessary, with your consent or as otherwise

permitted by applicable law, we process the following categories of sensitive

information:

health data

Payment Data. We may collect data necessary to process your payment if you make

purchases, such as your payment instrument number, and the security code

associated with your payment instrument. All payment data is stored by __________.

You may find their privacy notice link(s) here: __________.

Social Media Login Data. We may provide you with the option to register with us

using your existing social media account details, like your Facebook, Twitter, or other

social media account. If you choose to register in this way, we will collect the

information described in the section called "HOW DO WE HANDLE YOUR SOCIAL

LOGINS?" below.

Application Data. If you use our application(s), we also may collect the following

information if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to track

location-based information from your mobile device, either continuously or

while you are using our mobile application(s), to provide certain location-based

services. If you wish to change our access or permissions, you may do so in

your device's settings.

Mobile Device Access. We may request access or permission to certain

features from your mobile device, including your mobile device's sms

messages, social media accounts, storage, contacts, camera, bluetooth,

sensors, microphone, calendar, reminders, and other features. If you wish to

change our access or permissions, you may do so in your device's settings.

Mobile Device Data. We automatically collect device information (such as your

mobile device ID, model, and manufacturer), operating system, version

information and system configuration information, device and application

identification numbers, browser type and version, hardware model Internet

service provider and/or mobile carrier, and Internet Protocol (IP) address (or

proxy server). If you are using our application(s), we may also collect

information about the phone network associated with your mobile device, your

mobile device’s operating system or platform, the type of mobile device you

use, your mobile device’s unique device ID, and information about the features

of our application(s) you accessed.

Push Notifications. We may request to send you push notifications regarding

your account or certain features of the application(s). If you wish to opt out

from receiving these types of communications, you may turn them off in your

device's settings.

This information is primarily needed to maintain the security and operation of our

application(s), for troubleshooting, and for our internal analytics and reporting

purposes.

All personal information that you provide to us must be true, complete, and accurate,

and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or

browser and device characteristics — is collected automatically when you visit our

Services.

We automatically collect certain information when you visit, use, or navigate the

Services. This information does not reveal your specific identity (like your name or

contact information) but may include device and usage information, such as your IP

address, browser and device characteristics, operating system, language

preferences, referring URLs, device name, country, location, information about how

and when you use our Services, and other technical information. This information is

primarily needed to maintain the security and operation of our Services, and for our

internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar

Technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic,

usage, and performance information our servers automatically collect when

you access or use our Services and which we record in log files. Depending on

how you interact with us, this log data may include your IP address, device

information, browser type, and settings and information about your activity in

the Services (such as the date/time stamps associated with your usage, pages

and files viewed, searches, and other actions you take such as which features

you use), device event information (such as system activity, error reports

(sometimes called "crash dumps"), and hardware settings).

Device Data. We collect device data such as information about your computer,

phone, tablet, or other device you use to access the Services. Depending on

the device used, this device data may include information such as your IP

address (or proxy server), device and application identification numbers,

location, browser type, hardware model, Internet service provider and/or

mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your

device's location, which can be either precise or imprecise. How much

information we collect depends on the type and settings of the device you use

to access the Services. For example, we may use GPS and other technologies

to collect geolocation data that tells us your current location (based on your IP

address). You can opt out of allowing us to collect this information either by

refusing access to the information or by disabling your Location setting on your

device. However, if you choose to opt out, you may not be able to use certain

aspects of the Services.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners,

social media platforms, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to

you and update our records, we may obtain information about you from other

sources, such as public databases, joint marketing partners, affiliate programs, data

providers, social media platforms, and from other third parties. This information

includes mailing addresses, job titles, email addresses, phone numbers, intent data

(or user behavior data), Internet Protocol (IP) addresses, social media profiles, social

media URLs, and custom profiles, for purposes of targeted advertising and event

promotion. If you interact with us on a social media platform using your social media

account (e.g., Facebook or Twitter), we receive personal information about you such

as your name, email address, and gender. Any personal information that we collect

from your social media account depends on your social media account's privacy

settings.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our

Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on

how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage

user accounts. We may process your information so you can create and log

in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process

your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your

information to respond to your inquiries and solve any potential issues you

might have with the requested service.

To send administrative information to you. We may process your

information to send you details about our products and services, changes to

our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill

and manage your orders, payments, returns, and exchanges made through the

Services.

To enable user-to-user communications. We may process your information

if you choose to use any of our offerings that allow for communication with

another user.

To request feedback. We may process your information when necessary to

request feedback and to contact you about your use of our Services.

To send you marketing and promotional communications. We may

process the personal information you send to us for our marketing purposes, if

this is in accordance with your marketing preferences. You can opt out of our

marketing emails at any time. For more information, see "WHAT ARE YOUR

PRIVACY RIGHTS?" below.

To deliver targeted advertising to you. We may process your information to

develop and display personalized content and advertising tailored to your

interests, location, and more.

To protect our Services. We may process your information as part of our

efforts to keep our Services safe and secure, including fraud monitoring and

prevention.

To identify usage trends. We may process information about how you use

our Services to better understand how they are being used so we can improve

them.

To determine the effectiveness of our marketing and promotional

campaigns. We may process your information to better understand how to

provide marketing and promotional campaigns that are most relevant to you.

To save or protect an individual's vital interest. We may process your

information when necessary to save or protect an individual’s vital interest,

such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS

YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary

and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like

with your consent, to comply with laws, to provide you with services to enter into or

fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate

business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain

the valid legal bases we rely on in order to process your personal information. As

such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission

(i.e., consent) to use your personal information for a specific purpose. You can

withdraw your consent at any time. Learn more about withdrawing your

consent.

Performance of a Contract. We may process your personal information when

we believe it is necessary to fulfill our contractual obligations to you, including

providing our Services or at your request prior to entering into a contract with

you.

Legitimate Interests. We may process your information when we believe it is

reasonably necessary to achieve our legitimate business interests and those

interests do not outweigh your interests and fundamental rights and freedoms.

For example, we may process your personal information for some of the

purposes described in order to:

Send users information about special offers and discounts on our

products and services

Develop and display personalized and relevant advertising content for

our users

Analyze how our Services are used so we can improve them to engage

and retain users

Support our marketing activities

Diagnose problems and/or prevent fraudulent activities

Understand how our users use our products and services so we can

improve user experience

Legal Obligations. We may process your information where we believe it is

necessary for compliance with our legal obligations, such as to cooperate with

a law enforcement body or regulatory agency, exercise or defend our legal

rights, or disclose your information as evidence in litigation in which we are

involved.

Vital Interests. We may process your information where we believe it is

necessary to protect your vital interests or the vital interests of a third party,

such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e.,

express consent) to use your personal information for a specific purpose, or in

situations where your permission can be inferred (i.e., implied consent). You

can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to

process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be

obtained in a timely way

For investigations and fraud detection and prevention

For business transactions provided certain conditions are met

If it is contained in a witness statement and the collection is necessary to

assess, process, or settle an insurance claim

For identifying injured, ill, or deceased persons and communicating with next

of kin

If we have reasonable grounds to believe an individual has been, is, or may be

victim of financial abuse

If it is reasonable to expect collection and use with consent would compromise

the availability or the accuracy of the information and the collection is

reasonable for purposes related to investigating a breach of an agreement or a

contravention of the laws of Canada or a province

If disclosure is required to comply with a subpoena, warrant, court order, or

rules of the court relating to the production of records

If it was produced by an individual in the course of their employment, business,

or profession and the collection is consistent with the purposes for which the

information was produced

If the collection is solely for journalistic, artistic, or literary purposes

If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section

and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection

with, or during negotiations of, any merger, sale of company assets, financing,

or acquisition of all or a portion of our business to another company.

When we use Google Maps Platform APIs. We may share your information

with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).

Affiliates. We may share your information with our affiliates, in which case we

will require those affiliates to honor this privacy notice. Affiliates include our

parent company and any subsidiaries, joint venture partners, or other

companies that we control or that are under common control with us.

Business Partners. We may share your information with our business

partners to offer you certain products, services, or promotions.

Other Users. When you share personal information (for example, by posting

comments, contributions, or other content to the Services) or otherwise interact

with public areas of the Services, such personal information may be viewed by

all users and may be publicly made available outside the Services in

perpetuity. If you interact with other users of our Services and register for our

Services through a social network (such as Facebook), your contacts on the

social network will see your name, profile photo, and descriptions of your

activity. Similarly, other users will be able to view descriptions of your activity,

communicate with you within our Services, and view your profile.

Offer Wall. Our application(s) may display a third-party hosted "offer wall."

Such an offer wall allows third-party advertisers to offer virtual currency, gifts,

or other items to users in return for the acceptance and completion of an

advertisement offer. Such an offer wall may appear in our application(s) and be

displayed to you based on certain data, such as your geographic area or

demographic information. When you click on an offer wall, you will be brought

to an external website belonging to other persons and will leave our

application(s). A unique identifier, such as your user ID, will be shared with the

offer wall provider in order to prevent fraud and properly credit your account

with the relevant reward.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

In Short: We are not responsible for the safety of any information that you share with

third parties that we may link to or who advertise on our Services, but are not

affiliated with, our Services.

The Services, including our offer wall, may link to third-party websites, online

services, or mobile applications and/or contain advertisements from third parties that

are not affiliated with us and which may link to other websites, services, or

applications. Accordingly, we do not make any guarantee regarding any such third

parties, and we will not be liable for any loss or damage caused by the use of such

third-party websites, services, or applications. The inclusion of a link towards a third￾party website, service, or application does not imply an endorsement by us. We

cannot guarantee the safety and privacy of data you provide to any third parties. Any

data collected by third parties is not covered by this privacy notice. We are not

responsible for the content or privacy and security practices and policies of any third

parties, including other websites, services, or applications that may be linked to or

from the Services. You should review the policies of such third parties and contact

them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store

your information.

We may use cookies and similar tracking technologies (like web beacons and pixels)

to access or store information. Specific information about how we use such

technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media

account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social

media account details (like your Facebook or Twitter logins). Where you choose to do

this, we will receive certain profile information about you from your social media

provider. The profile information we receive may vary depending on the social media

provider concerned, but will often include your name, email address, friends list, and

profile picture, as well as other information you choose to make public on such a

social media platform.

We will use the information we receive only for the purposes that are described in this

privacy notice or that are otherwise made clear to you on the relevant Services.

Please note that we do not control, and are not responsible for, other uses of your

personal information by your third-party social media provider. We recommend that

you review their privacy notice to understand how they collect, use, and share your

personal information, and how you can set your privacy preferences on their sites

and apps.

8. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other

than your own.

Our servers are located in the United States. If you are accessing our Services from

outside the United States, please be aware that your information may be transferred

to, stored, and processed by us in our facilities and by those third parties with whom

we may share your personal information (see "WHEN AND WITH WHOM DO WE

SHARE YOUR PERSONAL INFORMATION?" above), in the United States, and

other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or

Switzerland, then these countries may not necessarily have data protection laws or

other similar laws as comprehensive as those in your country. However, we will take

all necessary measures to protect your personal information in accordance with this

privacy notice and applicable law.

European Commission's Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by

using the European Commission's Standard Contractual Clauses for transfers of

personal information between our group companies and between us and our third-

party providers. These clauses require all recipients to protect all personal

information that they process originating from the EEA or UK in accordance with

European data protection laws and regulations. Our Standard Contractual Clauses

can be provided upon request. We have implemented similar appropriate safeguards

with our third-party service providers and partners and further details can be provided

upon request.

9. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes

outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the

purposes set out in this privacy notice, unless a longer retention period is required or

permitted by law (such as tax, accounting, or other legal requirements). No purpose

in this notice will require us keeping your personal information for longer than the

period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal

information, we will either delete or anonymize such information, or, if this is not

possible (for example, because your personal information has been stored in backup

archives), then we will securely store your personal information and isolate it from

any further processing until deletion is possible.

10. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of

organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational

security measures designed to protect the security of any personal information we

process. However, despite our safeguards and efforts to secure your information, no

electronic transmission over the Internet or information storage technology can be

guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,

cybercriminals, or other unauthorized third parties will not be able to defeat our

security and improperly collect, access, steal, or modify your information. Although

we will do our best to protect your personal information, transmission of personal

information to and from our Services is at your own risk. You should only access the

Services within a secure environment.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United

Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater

access to and control over your personal information. You may review, change, or

terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain

rights under applicable data protection laws. These may include the right (i) to

request access and obtain a copy of your personal information, (ii) to request

rectification or erasure; (iii) to restrict the processing of your personal information; (iv)

if applicable, to data portability; and (v) not to be subject to automated decision￾making. In certain circumstances, you may also have the right to object to the

processing of your personal information. You can make such a request by contacting

us by using the contact details provided in the section "HOW CAN YOU CONTACT

US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data

protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing

your personal information, you also have the right to complain to your Member State

data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and

Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your

personal information, which may be express and/or implied consent depending on

the applicable law, you have the right to withdraw your consent at any time. You can

withdraw your consent at any time by contacting us by using the contact details

provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before

its withdrawal nor, when applicable law allows, will it affect the processing of your

personal information conducted in reliance on lawful processing grounds other than

consent.

Opting out of marketing and promotional communications: You can unsubscribe

from our marketing and promotional communications at any time by or by contacting

us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT

THIS NOTICE?" below. You will then be removed from the marketing lists. However,

we may still communicate with you — for example, to send you service-related

messages that are necessary for the administration and use of your account, to

respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or

terminate your account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your

account and information from our active databases. However, we may retain some

information in our files to prevent fraud, troubleshoot problems, assist with any

investigations, enforce our legal terms and/or comply with applicable legal

requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies

by default. If you prefer, you can usually choose to set your browser to remove

cookies and to reject cookies. If you choose to remove cookies or reject cookies, this

could affect certain features or services of our Services. You may also opt out of

interest-based advertising by advertisers on our Services.

If you have questions or comments about your privacy rights, you may email us at

johnray@treoplay.com.

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications

include a Do-Not-Track ("DNT") feature or setting you can activate to signal your

privacy preference not to have data about your online browsing activities monitored

and collected. At this stage no uniform technology standard for recognizing and

implementing DNT signals has been finalized. As such, we do not currently respond

to DNT browser signals or any other mechanism that automatically communicates

your choice not to be tracked online. If a standard for online tracking is adopted that

we must follow in the future, we will inform you about that practice in a revised

version of this privacy notice.

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Utah or Virginia,

you are granted specific rights regarding access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve

(12) months: NONE

A. Identifiers

Contact details, such as real name, alias,

postal address, telephone or mobile

contact number, unique personal identifier,

online identifier, Internet Protocol address,

email address, and account name

NO

B. Personal information as

defined in the California

Customer Records statute

Name, contact information, education,

employment, employment history, and

financial information

NO

C. Protected classification

characteristics under state

or federal law

Gender and date of birth 

NO

D. Commercial information

Transaction information, purchase history,

financial details, and payment information

NO

E. Biometric information Fingerprints and voiceprints 

NO

F. Internet or other similar

network activity

Browsing history, search history, online

behavior, interest data, and interactions

with our and other websites, applications,

systems, and advertisements

NO

G. Geolocation data Device location 

NO

H. Audio, electronic, visual,

thermal, olfactory, or similar

information

Images and audio, video or call recordings

created in connection with our business

activities

NO

I. Professional or

employment-related

information

Business contact details in order to

provide you our Services at a business

level or job title, work history, and

professional qualifications if you apply for

a job with us

NO

J. Education Information Student records and directory information

NO

K. Inferences drawn from

collected personal

information

Inferences drawn from any of the collected

personal information listed above to create

a profile or summary about, for example,

an individual’s preferences and

characteristics

NO

L. Sensitive personal

Information

Account login information, contents of

email or text messages, debit or credit

card numbers, drivers' licenses, health

data, passport numbers, precise

geolocation and state id card numbers

NO

We will use and retain the collected personal information as needed to provide the

Services or for:

Category B - As long as the user has an account with us

Category K - As long as the user has an account with us

Category L - As long as the user has an account with us

Category L information may be used, or disclosed to a service provider or contractor,

for additional, specified purposes. You have the right to limit the use or disclosure of

your sensitive personal information.

We may also collect other personal information outside of these categories through

instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, "HOW DO WE

PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a

written contract between us and each service provider. Learn more about how we

disclose personal information to in the section, "WHEN AND WITH WHOM DO WE

SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for

undertaking internal research for technological development and demonstration. This

is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a

business or commercial purpose in the preceding twelve (12) months. We will not sell

or share personal information in the future belonging to website visitors, users, and

other consumers.

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law

permits our users who are California residents to request and obtain from us, once a

year and free of charge, information about categories of personal information (if any)

we disclosed to third parties for direct marketing purposes and the names and

addresses of all third parties with which we shared personal information in the

immediately preceding calendar year. If you are a California resident and would like

to make such a request, please submit your request in writing to us using the contact

information provided below.

If you are under 18 years of age, reside in California, and have a registered account

with the Services, you have the right to request removal of unwanted data that you

publicly post on the Services. To request removal of such data, please contact us

using the contact information provided below and include the email address

associated with your account and a statement that you reside in California. We will

make sure the data is not publicly displayed on the Services, but please be aware

that the data may not be completely or comprehensively removed from all our

systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer

Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a "residents" as:

(1) every individual who is in the State of California for other than a temporary or

transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the

State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and

obligations regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your

personal information, we will respect your request and delete your personal

information, subject to certain exceptions provided by law, such as (but not limited to)

the exercise by another consumer of his or her right to free speech, our compliance

requirements resulting from a legal obligation, or any processing that may be

required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;

the categories of personal information that we collect;

the purposes for which the collected personal information is used;

whether we sell or share personal information to third parties;

the categories of personal information that we sold, shared, or disclosed for a

business purpose;

the categories of third parties to whom the personal information was sold,

shared, or disclosed for a business purpose;

the business or commercial purpose for collecting, selling, or sharing personal

information; and

the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete

consumer information that is de-identified in response to a consumer request or to re￾identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

If the business collects any of the following:

social security information, drivers' licenses, state ID cards, passport numbers

account login information

credit card numbers, financial account information, or credentials allowing

access to such accounts

precise geolocation

racial or ethnic origin, religious or philosophical beliefs, union membership

the contents of email and text, unless the business is the intended recipient of

the communication

genetic data, biometric data, and health data

data concerning sexual orientation and sex life

you have the right to direct that business to limit its use of your sensitive personal

information to that use which is necessary to perform the Services.

Once a business receives your request, they are no longer allowed to use or disclose

your sensitive personal information for any other purpose unless you provide consent

for the use or disclosure of sensitive personal information for additional purposes.

Please note that sensitive personal information that is collected or processed without

the purpose of inferring characteristics about a consumer is not covered by this right,

as well as the publicly available information.

To exercise your right to limit use and disclosure of sensitive personal information,

please email johnray@treoplay.com 

Verification process

Upon receiving your request, we will need to verify your identity to determine you are

the same person about whom we have the information in our system. These

verification efforts require us to ask you to provide information so that we can match it

with information you have previously provided us. For instance, depending on the

type of request you submit, we may ask you to provide certain information so that we

can match the information you provide with the information we already have on file,

or we may contact you through a communication method (e.g., phone or email) that

you have previously provided to us. We may also use other verification methods as

the circumstances dictate.

We will only use personal information provided in your request to verify your identity

or authority to make the request. To the extent possible, we will avoid requesting

additional information from you for the purposes of verification. However, if we cannot

verify your identity from the information already maintained by us, we may request

that you provide additional information for the purposes of verifying your identity and

for security or fraud-prevention purposes. We will delete such additionally provided

information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer

relevant, or ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on

your behalf. We may deny a request from an authorized agent that does not

submit proof that they have been validly authorized to act on your behalf in

accordance with the CCPA.

You may request to opt out from future selling or sharing of your personal

information to third parties. Upon receiving an opt-out request, we will act upon

the request as soon as feasibly possible, but no later than fifteen (15) days

from the date of the request submission.

To exercise these rights, you can contact us  by email at

johnray@treoplay.com, or by referring to the contact details at the bottom of this

document. If you have a complaint about how we handle your data, we would like to

hear from you.

Colorado Residents

This section applies only to Colorado residents. Under the Colorado Privacy Act

(CPA), you have the rights listed below. However, these rights are not absolute, and

in certain cases, we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted

advertising, the sale of personal data, or profiling in furtherance of decisions

that produce legal or similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email

johnray@treoplay.comIf we decline to take action regarding your request and you wish to appeal our

decision, please email us at johnray@treoplay.com. Within forty-five (45) days of

receipt of an appeal, we will inform you in writing of any action taken or not taken in

response to the appeal, including a written explanation of the reasons for the

decisions.

Connecticut Residents

This section applies only to Connecticut residents. Under the Connecticut Data

Privacy Act (CTDPA), you have the rights listed below. However, these rights are not

absolute, and in certain cases, we may decline your request as permitted by law.

Right to be informed whether or not we are processing your personal data

Right to access your personal data

Right to correct inaccuracies in your personal data

Right to request deletion of your personal data

Right to obtain a copy of the personal data you previously shared with us

Right to opt out of the processing of your personal data if it is used for targeted

advertising, the sale of personal data, or profiling in furtherance of decisions

that produce legal or similarly significant effects ("profiling")

To submit a request to exercise these rights described above, please email

johnray@treoplay.com If we decline to take action regarding your request and 


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