SUPPLEMENTAL PRIVACY NOTICE FOR US RESIDENTS

Live Tech Games

Last updated: 8th February 2023.

This US Supplemental Privacy Notice (“Supplemental Notice”) applies only to information collected about consumers located in the United States. It provides information required under the following laws, (collectively, “US State Privacy Laws”):

• California Consumer Privacy Act of 2018 and California Privacy Rights Act of 2020 (collectively, the “CPRA”);
• Colorado Privacy Act of 2021 (the “CPA”);
• Connecticut Data Privacy Act (“CTDPA”);
• Utah Consumer Privacy Act of 2022 (the “UCPA”); and
• Virginia Consumer Data Protection Act of 2021 (the “VCDPA”).

This Supplemental Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Supplemental Notice is parallel in scope to our general Privacy Policy and should be read in conjunction with our Privacy Policy.

Some portions of this Supplemental Notice apply only to consumers of particular states. In those instances, we have indicated that such language applies only to those consumers. To the extent other terms used in this Supplemental Notice are defined terms under the applicable US State Privacy Law, they shall have the meanings afforded to them in those statutes, whether or not capitalized herein. As there are some variations between such definitions in each of the state statutes, the definitions applicable to you are those provided in the statute for the state in which you are a consumer. For example, if you are a Virginia consumer, terms used in this Supplemental Notice that are defined terms in the VCDPA shall have the meanings afforded to them in the VCDPA as this Supplemental Notice applies to you.

Like our Privacy Policy, this Supplemental Notice only applies to personal information that we collect through our website at https://livetechgames.com/ (“Website”), our applications (“Apps“) and when you play one of our games (“Games“). Where we provide links to websites of other organisations, this Privacy Notice does not cover how that organisation processes personal information. We encourage you to read the privacy notices on the other websites you visit.

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1. Collection of Personal Information

We may collect and have collected within the last 12 months the following categories of personal information:

1. 1. • Identifiers, such as your name, telephone number, postal address, email address, user account name, and IP address;
      • Contact and financial information, including personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your contact information and profile picture;
      • Characteristics of protected classifications under state or federal law, such as your gender;
      • Commercial information, such as transaction information and purchase history;
      • Internet or network activity information, such as your browsing history and interactions with our Website, Apps and Games;
      • Geolocation data, such as your approximate location based on your IP address;
      • Audio, electronic, visual, and similar information, such as call and video recordings;
      • Professional or employment-related information, such as your title or industry; 
      • Inferences drawn from any of the above personal information to create a summary about you, for example of your preferences and characteristics; and
      • Sensitive personal information as defined in the CPRA, such as your account log-in in combination with the password or credentials to access the account (if you have an account with us).

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1. 1. 2. Sources of Personal Information

We may obtain the categories of personal information listed above from the following categories of sources:

1. 1. • Directly from you – for example, from forms you complete on our Website, when you create an account with us, purchase goods or services whilst playing our Games or when you contact us;
      • Indirectly from you – for example, from your device when you access our Website or from observing your actions on our Website; 
      • From third parties that assist us in providing relevant services for our Website;
      • From joint marketing partners that share the information with us; and
      • From public sources (such as data in the public domain).

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1. 1. 3. Purposes for Processing Personal Information

We collect and process personal information described in this Supplemental Notice:

1. 1. • To operate, manage, and maintain our business;
      • To respond to your inquiries and to fulfill your requests;
      • To prevent fraud or crime, and for risk and technical security monitoring purposes;
      • To facilitate the development of new products and services;
      • To enhance, improve or modify our Website or products and services; 
      • To provide you with access to the Apps, their content and functionalities, including to register you as a new user, set up your account, and provide you with access to your account;
      • To process and fulfil any in-App purchases or other purchases you make from us, including to manage payments, fees and charges, send you purchase confirmations and invoices and collect and recover money owed to us;
      • To manage our relationship with you, which will include: 
        • Notifying you about changes to our terms or privacy policy;
        • Asking you to leave a review or take a survey;
        • Sending you technical notices, updates, security alerts, and support and administrative messages;
        • Responding to your comments, questions, and requests and providing customer service;
      • To understand feedback about our Website, our Apps and our services, and to help quickly and easily provide more information on the use of those services;
      • To enable you to partake in a  competition or complete a survey;
      • To fulfil the payment of cash prizes where you win any of our competitions;
      • To administer and protect our business and our Website and Apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
      • To personalize your experience of our Website and/or Apps in accordance with your interests and preferences;
      • To deliver relevant advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
      • To monitor performance and overall usage of our Website and Apps and user retention rates, track how users are engaging with our services, identify how and how frequently features are utilized, identify problem areas and inform design development for future updates;
      • To share your contribution to our blog (published on our Website);
      • To send you advertising or promotional materials, including information about new Games, products, contests, features and enhancements, special offers and other events of interest from Live Tech Games and our select partners;
      • For collecting information through the device-based settings which you have enabled (e.g. access to your GPS location, camera or photos); and
      • To comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.

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1. 1. 4. Retention of Personal Information

We retain the personal information we collect from you where we have an ongoing business need to do so. We will store and use your personal data for as long you have an account with us and for as long we consider it to be required to fulfil the purposes set out in this Supplemental Notice. This means that we will use different categories of data for different periods. We will for example use contact and sign in details, gaming history and data related to your device for as long you use our Apps and play our Games, and as long as we need to provide you with your account. 

In certain circumstance, we will need to keep your information for legal reasons after your account has been deleted. The specific retention periods depend on the nature of the information and why it is collected and processed and the nature of the legal requirement. We keep your information when we have a legal obligation to do so (for example bookkeeping and financial reporting); to deal with and resolve requests and complaints (for example, if there was an ongoing complaint with respect to a service provided to you but you had deleted your account), to protect individuals’ rights (for example we will retain information about a data subject access request for one year after the request in case there is a subsequent complaint and the information is needed to demonstrate how the request was handled); and for litigation or regulatory matters (for example we would retain your information if there was an ongoing legal claim and the information was relevant to the claim. This information would be retained until the matter had been concluded.). 

When we have no ongoing legitimate business need or legal reason to process your personal information, we will either delete or anonymise it 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.

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1. 1. 5. Categories of Entities to Whom We Disclose Personal Information

We share your personal information with the following categories of recipients:

1. 1. • Third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website and Apps), or who otherwise process personal information for purposes that are described in this Supplemental Notice. We work with the following types of third-party service providers: 
        • Core Infrastructure including hosting services such as Microsoft Azure who process all of our hosted data;
        • Payment service providers such as PayPal who process Contact Data and who assist us with fulfilment of cash prizes; 
        • Customer relationship management services such as Help Shift and Braze who process Identity Data, Contact Data and Technical data who assist us with customer support;
        • Marketing companies and advertising partners who process Technical Data such as your IP address and other advertising identifiers and who assist us with our marketing and advertising activities.
   2. • Commercial partners for business, commercial and advertising reasons, who in certain contexts, independently decide how to process data. We may share information such as your email address with commercial partners, which may be used for their own data matching and analytics purposes (such as to see whether a user of our Apps is also a user of their products and services). We may also share information about your in-App activity including how many live tournaments you have entered playing our Games and other types of session data. Where we provide you with in-App advertising content (including in-App links) on behalf of our partners, we may share information such as whether you have clicked on or otherwise interacted with any advertising content, banners or links. Please note that the results of any data matching and analytics carried out will only be shared by commercial partners with their own commercial partners where relevant data protection contractual clauses are in place. 
   3. • Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
      • An actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice.
      • Any other person with your consent to the disclosure.

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1. 1. 6. Disclosure of Personal Information

We may disclose the following categories of personal information to the third parties described above:

1. 1. • Identifiers, such as your name, telephone number, postal address, email address, user account name, and IP address;
      • Contact and financial information, including personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e), such as your contact information and profile picture;
      • Characteristics of protected classifications under state or federal law, such as your gender;
      • Commercial information, such as transaction information and purchase history;
      • Internet or network activity information, such as your browsing history and interactions with our Website, Apps and Games;
      • Geolocation data, such as your approximate location based on your IP address;
      • Audio, electronic, visual, and similar information, such as call and video recordings;
      • Professional or employment-related information, such as your title or industry; 
      • Inferences drawn from any of the above personal information to create a summary about you, for example of your preferences and characteristics; and
      • Sensitive personal information as defined in the CPRA, such as your account log-in in combination with the password or credentials to access the account (if you have an account with us).

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1. 1. 7. Selling and Sharing of Personal Information

Disclosure for California Consumers: Unless specifically stated, we have not “sold” or “shared” personal information about California consumers to third parties for their own use within the meaning of the CCPA or the CPRA in the preceding 12 months. Relatedly, we do not have actual knowledge that we sell or share personal information of California consumers under 16 years of age. 

For purposes of the CPRA, a “sale” is the disclosure of personal information to a third party for monetary or other valuable consideration, and a “share” is the disclosure of personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. However, we may share your personal information with our affiliates and trusted partners in arrangements that may meet the broad definition of “sale” or “share” under California law. In these arrangements, use of the information we share is limited by policies, contracts, or similar restrictions.

Disclosure for Colorado, Virginia, Utah, and Connecticut Consumers: Unless specifically stated, we do not “sell” or “share” personal information to third parties for their own use.  However, we may share or process one or more of the above categories of personal information with our affiliates and trusted partners in arrangements for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA, VCDPA, UCPA, and CTDPA. In these arrangements, use of the information we share is limited by policies, contracts or similar restrictions.

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1. 1. 8. Your data protection rights

California, Colorado, Virginia, Utah, and Connecticut consumers have certain rights with respect to the collection and use of their Personal Information. Those rights vary by state. As required by the CPRA, we provide detailed information below regarding the data subject rights available to California consumers. Colorado, Virginia, Utah, and Connecticut consumers have similar rights and can find more detail by referencing the applicable US State Privacy Laws.

1. 1. • Right to receive information on our privacy practices: You have the right to receive the following information at or before the point of collection:
        • The categories of personal information to be collected;
        • The purposes for which the categories of personal information are collected or used;
        • Whether or not that personal information is sold or shared;
        • If the business collects sensitive personal information, the categories of sensitive personal information to be collected, the purposes for which it is collected or used, and whether that information is sold or shared; and
        • The length of time the business intends to retain each category of personal information, or if that is not possible, the criteria used to determine that period.

We have provided such information in this Supplemental Notice, and you may request further information about our privacy practices by using the contact details provided under the “How to contact us” heading below.

1. 1. • Right to know: You may request that we provide you with the following information about how we have handled your personal information in the 12 months preceding your request:
        • The categories of personal information we collected about you;
        • The categories of sources from which we collected such personal information;
        • The business or commercial purpose for collecting personal information about you;
        • The categories of personal information about you that we shared or disclosed and the categories of third parties with whom we shared or disclosed such personal information; and
        • The specific pieces of personal information we have collected about you.
      • Right to correction: You may request that we correct any inaccurate personal information we maintain about you.
      • Right to deletion: You may request that we delete any personal information about you that we collected from you.
      • Right to receive information about onward disclosures: You may request that we disclose to you:
        • The categories of personal information that we have collected about you;
        • The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared; and
        • The categories of personal information we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
      • Right to non-discrimination: You have the right not to be discriminated against for exercising your data subject rights. We will not discriminate against you for exercising your data subject rights.
      • Right to restrict or limit the use of sensitive personal information: You have the right to restrict the use and disclosure of sensitive personal information to certain purposes related to the offering of goods or services as listed in the CPRA. As described in the Section “Selling and Sharing of Personal Information” above, we do not “sell” or “share” personal information.
      • Right to opt-out of sharing, disclosure, or sale of personal information: You have the right to direct us to not share, disclose, or sell your personal information.  As described in the Section “Selling and Sharing of Personal Information” above, we do not “sell” or “share” personal information.

You may exercise the data subject rights applicable to you under the applicable US State Privacy Law by using the contact details provided under the “How to contact us” heading below. While we will make reasonable efforts to accommodate your request, we reserve the right to impose certain restrictions or requirements on your request, if allowed by or required by applicable law. Consumers in some states may also authorize an agent to make data subject requests on their behalf.

We may ask you to provide information that will enable us to verify your identity in order to comply with your data subject request. In particular, when a California or Connecticut consumer authorizes an agent to make a request on their behalf, we may require the agent to provide proof of signed permission from the consumer to submit the request, or we may require the consumer to verify their own identity to us or confirm with us that they provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.

We will not discriminate against you for exercising your data subject rights. For example, we will not deny goods or services to you, or charge you different prices or rates, or provide a different level of quality for products or services as a result of you exercising your data subject rights.

To appeal our decision on your data subject requests, you may contact us by using the contact details provided under the “How to contact us” heading below. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

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1. 1. 9. Children’s Privacy

The Website, Apps and Games are intended for adults and are not directed at children who are under 13 years of age. We do not knowingly collect personal information from children under the age of 13. If we obtain knowledge that it has personal information about a child under 13 in retrievable form in its files, we will delete that information from our existing files. If you believe that a person under 13 years of age has provided us with his or her personal information, please notify us so that we can take reasonable steps to remove the information from our database.

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1. 1. 10. Cookies and similar technologies

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising.  For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice and consent management platform. Your browser may have a setting that allows you to indicate a “Do Not Track” preference. Our Website does not respond to “Do Not Track” signals or other similar mechanisms.

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1. 1. 11. Other disclosures

   2. • California Residents Under Age 18. If you are a resident of California under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to the website by using the contact details provided under the “How to contact us” heading below. Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.
      • Disclosure About Direct Marketing for California Residents. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of Personal Information to other entities for their direct marketing purposes in the preceding calendar year. We do not distribute your personal information to other entities for their own direct marketing purposes. 
      • Financial Incentives for California Consumers. We may offer various types of financial incentives in exchange for your personal information, such as coupons, discounts, promotions, loyalty points, sweepstakes, contests, surveys, and other exclusive offers for California consumers who sign up to receive our marketing emails or join our loyalty program. The amount and terms of such offers will be presented to you at the time of the offer. When you participate in a financial incentive, we collect personal information from you, such as identifiers (like your email address) and commercial information (like your purchase history). Solely for purposes of California privacy law, we reasonably estimate the value of the discount, coupon, or other financial incentive that we offer to you to be equal to or greater than the value we receive from a consumer’s personal information collected in connection with the offer. We reasonably estimate the value of a consumer’s data by estimating the expenses related to the provision of each incentive program per consumer. We incur a variety of expenses for providing financial incentives, such as administrative and technical expenses associated with maintaining a loyalty program and costs associated with discounts on purchases. Participation in our financial incentives is voluntary. You may opt into a financial incentive by following the sign-up or participation instructions provided, and you have the ability to opt out by unsubscribing from our emails or closing your loyalty member account. 
      • Changes to our Supplemental Notice. We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make material changes to this Supplemental Notice, we will notify you by posting an updated Supplemental Notice on our website and listing the effective date of such updates.

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1. 1. 12. How to contact us

If you have any questions or concerns about our use of your personal information, please contact us using the following details: hello@livetechgames.com. 

The data controller of your personal information is Live Tech Games Ltd, which is registered with the UK’s Information Commissioner’s Office with registration number ZA926936.

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