PrizePool, Inc., a Delaware corporation (“we”, “us”, “our”), works hard to build and maintain a relationship of trust with you. This Privacy Policy (the “Privacy Policy”) governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) and mobile application (collectively, “Sites”), such as www.getprizepool.com, and any services, transactions, or other engagements you might have with us (collectively, “Services”).

This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.

Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Sites and/or Services. If you do not agree with our Terms of Use or this Privacy Policy, you must refrain from using our Sites/Services. By accessing or using our Sites or Services, you agree to our use of your information consistent with our Terms of Use and this Privacy Policy.

a. Privacy Policy Changes

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on the Sites and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Sites or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change being used in a materially new way, we will provide you notice before using your Personal Information in the new way.

b. Conflict Between this Policy and Laws and Regulations

When federal, state, or local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. The specific requirements of this Privacy Policy apply unless disallowed by applicable laws or regulations.

a. Personal Information

We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

The specific Personal Information we collect about you may vary based on how you use the Sites and/or Services and your relationship with us.

b. Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business or a business contact.

c. Usage Data and Sites Activity

We automatically collect information in connection with the actions you take on the Sites (“Usage Data”). For example, each time you visit our website, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Sites, and the duration of your visits to the Sites. When you use our mobile application, we gather information about data and time of your use, duration of use, your device type and operating system. If this information is reasonably capable of being associated with you, we treat it as Personal Information. If this information is not reasonably capable of being individually associated with you, we treat it as Usage Data.

d. Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

a. Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us (online or offline), register to use the Sites, enter a depository account relationship with our partner bank, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Sites or Services or we may not be able to fulfill your requested interaction.

b. Third-Party Data Sources

We may collect Personal Information from third-party data sources such as data brokers, marketing/advertising agencies, identity verification services, financial institutions, and government agencies.

c. Cookies and Other Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to improve the experience of the site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Website. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Instructions for how to manage cookies in popular browsers are available at: Chrome, Firefox, Internet Explorer, Safari (Mac), Safari (iOS), and Opera. However, certain features of the Sites may not work if you delete or disable cookies.
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We use the following types of cookies:

We employ software technology that enables us to track certain aspects of a user’s visit to the Sites. This technology helps us better manage content on the Sites by informing us what content is effective, how consumers engage with the Sites, and how consumers arrive at and/or depart from the Sites. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether a user has viewed a web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.

If you arrive at the Sites by “clicking through” from another website, then certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Sites, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached the Sites to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

d. Interest-Based Advertising

We may work with third-party advertisers, search providers, and ad networks (“Advertisers”) to learn more about you and show you our ads or other of our content that we believe would be relevant to you. Advertisers may collect and use information about your use of the Sites or Services as well as other websites and services. These companies may use cookies and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Sites, on third-party websites, or on social media properties. If you do not want to receive interest-based advertising, please visit the Digital Advertising Alliance (“DAA”) Consumer Choice Page. The DAA website allows you to opt-out of one or more interest-based advertising networks. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Deleting browser cookies can remove your opt-out preferences; however, the DAA offers browser extensions that help preserve the opt-out preferences you set on the DAA's Consumer Choice Page. Please note that opt-outs only apply to interest-based advertising. You may still receive other types of online advertising.

e. Information from Advertisements

If you arrive at the Sites via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).

a. Generally

We use Personal Information for internal purposes, such as to:

b. Banking Partner

As part of the Services, you may enter a depository account relationship with Evolve Bank & Trust, an Arkansas state bank (“Evolve”). We will share your Personal Information with Evolve if you seek to enter into a relationship with Evolve, for so long as you maintain a relationship with Evolve, and for a period of time thereafter to fulfill our contractual obligations to Evolve. We will also receive Personal Information about you from Evolve. Personal Information transferred to Evolve is subject to Evolve’s Privacy Policy.

c. Testimonials and Sweepstakes Winners’ Stories

If you provide a testimonial or story, we may post it publicly on the Sites or in other advertising material. By providing a testimonial or story, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications, without any compensation to you. Unless prohibited by applicable law, we may also use your likeness and story as a sweepstakes winner on the Sites or in other advertising material.

d. Service Providers

We may establish a relationship with other businesses to provide services to us which may include corporate affiliates (“Service Providers”), including for:

We only provide our Service Providers with the Personal Information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.

We may share the following types of Personal Information with one or more Service Providers: unique identifiers; contact information; characteristics of protected classifications; commercial information; financial information; audio/visual information; Internet and network information; inferences drawn from the foregoing categories of Personal Information.

You may also be asked to provide Personal Information directly to a Service Provider. For example, in order to connect your external bank account to our systems, we use a Service Provider called Plaid. If you provide your Personal Information to Plaid, it will be governed by Plaid’s End User Privacy Policy except to the extent it is shared with us, in which case it will be governed by this Privacy Policy.

e. Third-Party Selling

We do not sell your Personal Information to third-party companies.

a. Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Sites or Services, you do so at your own risk.

b. Other Websites

Please be aware that third-party websites accessible through the Sites or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.

c. Compliance with Laws and Law Enforcement

We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

d. Other Transfers

We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.

e. How Long We Retain Your Data

We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, and/or accounting obligations.

f. Children’s Privacy

The Sites and Services are not intended for children under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.

If you are a resident of California, you may have additional rights to access and control your Personal Information under the California Consumer Privacy Act (CCPA). Exemptions may apply.

a. Right to Know

You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose(s) for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; (v) the categories of Third Parties to whom we sold your Personal Information; and (vi) our business or commercial purposes for selling Personal Information. We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver’s license numbers. We will not provide specific pieces of Personal Information unless you expressly request them.

b. Right to Deletion

You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.

c. Submitting a CCPA Request

You may submit Right to Know or Deletion requests by or sending an email to privacy@getprizepool.com or writing to us at our mailing address below. In your correspondence, please include at least your name, mailing address, email address, and a description of your request.
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After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process Right to Know or Deletion requests without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.
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We will process verified Right to Know and Deletion requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. If you request specific Personal Information and that information creates a high risk of potential harm from disclosure to an unauthorized person, we will withhold that information and replace it with a category identifier. For example, if we withhold a social security number, we will inform you that we have a social security number on file. If you have an online account with us, we will provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery. We will retain a copy of your deletion request for at least two years as required by law.

d. Authorized Agent

If you are an authorized agent submitting a request on behalf of a California resident, you must provide a copy of a lawful power of attorney or a written signed authorization from the consumer along with proof your identity. You may provide this documentation via email to privacy@getprizepool.com after submitting the request. We may contact you and the consumer on whose behalf you claim to act to verify your identity, the consumer’s identity, and your authorization to act on the consumer’s behalf.

e. Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

f. California “Do Not Track” Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. Currently, our Sites and Services do not respond to “do not track” signals.

If you have any questions about our Sites, Services, or this Privacy Policy, please email us at privacy@getprizepool.com, or send us a letter to the following address:
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PrizePool, Inc.
ATTN: Privacy
3790 El Camino Real #9039
Palo Alto, CA 94306

Effective Date: July 15, 2020

Last Major Update: July 15, 2020