VENN Privacy Policy

Effective Date: September 17, 2019

 

PREAMBLE

Gaming 247, Inc. (“Company” or “we” or “us” or “our”) owns and operates a website, https://www.venn.tv/,  that was developed to provide the premium home for gaming, esports and pop culture entertainment and related content services (the “Platform”).  Your privacy is very important to us, and in order to best protect your information, we have adopted this privacy policy (“Privacy Policy”), which describes the types of information we collect from users (registered or unregistered) who use the Platform (each, a “User”, “you” or “your”), how such information is used, processed and in certain cases disclosed by us, and your rights and choices regarding the information you provide to us.  Please read this Privacy Policy carefully prior to your use of the Platform.  If you do not agree to abide by this Privacy Policy, please do not use our Platform.

The policy does not apply to information collected by: (a) us offline; or (b) any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Platform.

By accessing and using the Platform, you are deemed to have read, accepted, executed and be bound by this Privacy Policy, including, without limitation, the information collection, use and disclosure practices described herein. This Privacy Policy is governed by the Platform Terms of Service available at https://www.venn.tv/terms-of-service, which includes all disclaimers of warranties and limitations of liabilities.  Capitalized terms that are used but not defined in this Privacy Policy have the respective meanings assigned to such terms in the Terms of Service.

  1. Information We Collect and Receive

In order for us to (i) provide you with the services and functionalities offered via the Platform, (ii) engage in troubleshooting activities, and (iii) improve upon the Platform’s performance, safety and security, we may collect and process some or all of the following types of information about you through the means discussed below.  Please note that we may need certain types of information so that we can provide certain services offered on the Platform to you.  If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use certain services on the Platform.

  • User-provided Personal Information. Information that could be directly associated with you, or used to contact or identify you, without the aid of additional information, including, without limitation, information you provide us when you opt-in for a newsletter offering and/or create an account (“Account”) such as your name, address, email address, telephone number, and username/password (“Personal Information”).

  • Usage Information Automatically Collected. Information that is not Personal Information, but that relates to your usage of the Platform or that is necessary for the proper functioning or improvement of the Platform, including: (i) times and dates and the extent of your usage of the Platform; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Platform; (iii) device keyboard settings; (iv) content you view, follow, and otherwise interact with; (v) usage history such as areas and pages within the Platform that you access or use and/or which buttons in the Platform you click on; (vi) search terms you type in on the Platform; (vii) the URL or advertisement that may have referred you to the Platform; (viii) the search terms you entered into a search engine or app store that may have led you to the Platform; (ix) the mobile platform or service provider you use, and (x) other device and Platform access information such as your browser type, operating system, IP address, referring/exit pages, and other unique device identifiers, as well as your push notification token (collectively, “Usage Information”).

  • Third Party Information. Information about you that we may receive from third parties. For example, we may supplement certain information that we collect from you with outside records, or third parties may provide us with information about you in connection with a co-marketing agreement. We use this information to supplement the information we collect about you in order to provide more relevant, safer experiences for you with the Platform and improve the Platform, analytics, and advertising. If we combine or associate information from other sources with information that we collect through the Platform, we will treat the combined information in accordance with this Privacy Policy.

While certain types of information described above, such as Usage Information and Third-Party Information, are generally non-identifying on a standalone basis, we may in certain instances combine this information with other information collected on the Platform, as described above.  If we ever combine non-identifying information with Personal Information or other information that enables you to be identified, we will treat such combined information as Personal Information.  We do not currently use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

  1. European Union Users

European Union data protection law requires a “lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas.  Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (“GDPR”), which are summarized below.

  • Consent: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your email address when you create your Account or opt-in to a newsletter offering.

  • Contract: We may need your Personal Information to comply with our contractual obligation to deliver the Platform, such as fulfilling any future subscription based, or other transactional, services.

  • Legal Obligations: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Platforms.

  • Legitimate Interests: This is a technical term that means we have a good and fair reason to use your Personal Information and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. For example, we (i) use identity, device, and location information to prevent abuse of the Platform by Users and to keep the Platform secure, (ii) may also send you promotional communications about our Platform and services subject to your right to opt-out, and (iii) analyze how Users interact with our Platform or other Users (although we are not obligated to do so) so we can understand better what elements do or do not work well, what services/functionalities may be necessary or desirable to provide you with the best User experience on the Platform, and to ensure the safety and security of the Platform, which allows us to improve and develop the quality of the online experience we offer all our Users.

  1. Use of Information

We may use the information we collect about/from you to:

  • Identify you and potentially improve and/or customize the Platform

  • Send you administrative notices or Account notifications

  • Send you requested service and other Platform information

  • Address inquiries and respond to customer service requests, questions and comments

  • Administer your Account and manage your Account profile information

  • Send you newsletters and mail (including email)

  • Send you more relevant marketing communications and general Platform information/updates

  • Create a more personalized User experience and customize certain content you see on the Platform

  • Identify trends, conduct data analysis and determine the effectiveness of our marketing and promotions and other service offerings

  • Improve your User experience and increase the efficiency and effectiveness of the Platform service and functionality offerings

  • Maintain security

  • Enforce our Terms of Service and applicable law

  • Analyze Platform usage and other trend data

  • Solicit feedback, reviews, and other information regarding your experience with the Platform, including, without limitation, with respect to certain features and functionalities that you would like to see on the Platform, or that we have recently rolled out onto the Platform

  • Test new features, service offerings and functionalities on the Platform

  • Other purposes that we believe are necessary to protect our rights and the rights of others, or as otherwise described to you at the time of collection

We may also use certain collected information on an aggregated and/or anonymized basis in order to conduct market research, engage in project planning, for troubleshooting purposes, to help detect and protect against error, fraud or other criminal activity.

We may also ask for your consent to process your Personal Information for a specific purpose that we communicate to you.  When you consent to our processing your Personal Information for a specified purpose, you may withdraw your consent at any time and we will stop processing of your data for that purpose.

  1. Email Notifications and Opt-Out

We maintain a strict “no-spam” policy.  Unless you specifically opt-out as provided herein, by accepting the Terms of Service and this Privacy Policy, you expressly agree that we may use your information to contact you by email in order to deliver you information that is relevant to your use of the Platform such as administrative notices, service enhancements or “newsletters”, or that, in some cases, is targeted to your interests, such as service/functionalities offerings that we believe you may be interested in learning more about.  You may choose to stop receiving these email communications from us by following the unsubscribe instructions at the bottom of any email from us.

  1. Sharing Your Information

Information We May Share with Third Parties

We may share aggregated usage information and may otherwise disclose non-Personal Information that we collect to third parties.  However, absent your prior consent, we will share your Personal Information with third parties only in the ways that are described in this Privacy Policy, including as set forth below, and we do not otherwise sell your Personal Information to third parties.

  • We may use third parties to outsource one or more aspects of our business and/or Platform operations (such as customer service functions, data processing, web analytics, maintenance, online advertising, and security execution and clearing services), in which case, we may provide your Personal Information to such third parties in connection with the performance of such activities. Such third parties will only use your Personal Information to the extent necessary to perform their functions and will be contractually bound to process your Personal Information only on our behalf and in compliance with our requests.

  • We also work with (or may in the future work with) network advertisers, ad agencies, analytics service providers, and other vendors to provide them with information regarding traffic on the Platform, including pages viewed, content interacted with, and actions taken by Users when visiting the Platform; to serve advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Platform and the effectiveness of our advertisements and other marketing campaigns. Our service providers may collect certain information about your visits to, and activity on, the Platform as well as other websites or services, they may set and access their own tracking technologies on your device (including Cookies and Web Beacons), and they may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Platform or other online websites and services. We may also share certain non-Personal Information with these parties, in connection with the services they provide to us.

  • In the event that we undergo re-organization, are sold to or merged with a third party, or sell all or substantially all of our assets, any Personal Information we hold about you may be transferred to that re-organized entity or third party in compliance with applicable law.

  • In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Information is treated, transferred, or used.

  • We will also share your information with any member, subsidiary, parent or affiliate of our corporate group, only for the purposes set out above, to assist in the improvement and optimization of the Platform, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes.

  • In addition to the foregoing, we also reserve the right, and you hereby authorize us, to share or disclose (including, without limitation, to law enforcement agencies, public authorities, governmental departments, or other similar organizations) information we collect, including your Personal Information, and any other information, records or electronic communications of any kind, when we determine (in our sole discretion), that the disclosure of such information is necessary to identify, contact, or bring legal action against you if:

    • you are or may be violating the Terms of Service or this Privacy Policy, or if otherwise necessary to enforce our Terms of Service or other policies governing the Platform;

    • you are interfering with our or any third party’s rights or property;

    • you are violating any applicable law, rule or regulation;

    • necessary or required by any applicable law, rule or regulation, including a subpoena or similar legal process or request/order;

    • necessary or required for purposes of public importance, to protect our rights, protect your safety or the safety of others, investigate security, technical issues or fraud, or respond to a government request; and/or

    • requested by governmental authorities in the event of any investigation, act of terrorism or instance of local, regional or national emergency;

    • necessary to support any audit, or to comply with similar corporate governance functions; or consented to by you.

  1. Storage of Information

We make no representation or warranty with respect to any duty to permanently store any information you may provide or that we otherwise collect about you.  We strive to keep our processing activities with respect to your Personal Information as limited as possible.  In the absence of specific retention periods set out in this Privacy Policy, we will retain the information we collect from or about you only as long as necessary to provide you with the Platform or our services, which includes for the duration of, but could extend beyond, your active participation on the Platform, or as otherwise set forth in this Privacy Policy, and to the extent set out in this Privacy Policy and as necessary to comply with our legal and/or statutory obligations, resolve disputes, enforce our agreements, and protect our legal rights. Additionally, we may retain indefinitely any aggregated, anonymized, or pseudonymized information which we may collect and maintain, and may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format.  By using the Platform and providing us with information (including Personal Information), you waive any claims that may arise under your own or any other local or national laws, rules or regulations or international treaties. We may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format.  This Privacy Policy applies to your information for as long as your information is in our possession, even if you terminate or discontinue your use of the Platform.

  1. Cookies and Other Tracking Technologies

We may use cookies, for example, to keep track of your preferences and Account profile information, or to engage in certain retargeting activities that we feel will better enhance your User experience and the efficiency and effectiveness of the Platform and certain services and functionalities offered thereon.  Cookies are also used to collect general usage and volume statistical information that does not include Personal Information.  We may also use another company or third-party service to place cookies on your computer to collect non-personally identifiable information to compile aggregated statistics for us about Users of the Platform.  For information about what cookies are, how they work, how we use them, and how to remove them, please read the remainder of this section below.

What is a Cookie?

Cookies are small pieces of information that are stored as text files by your Internet browser on your computer's hard drive.  Most Internet browsers are initially set to accept cookies.  You can set your browser to refuse cookies from websites or to remove cookies from your hard drive, but if you do so, you may not be able to access or use portions of the Platform, or certain offerings on the Platform may not function as intended or as well.  Also, some browsers have “do not track” features that allow you to tell a website not to track you.  These features are not all uniform.  If you block cookies, certain features on the Platform may not work. If you block or reject cookies, not all of the tracking described herein will stop.  Please note that certain options you select are browser- and device-specific.

What Cookies do we use?

A more detailed list of the cookies we currently, or in the future may, use and how we use, or may use, them are as follows:

  • Security: We secure the Platform with cookies that facilitate security features and allow us to detect activity that might violate our rules and Terms of Service, such as unauthorized access or activity.

  • Localization: We use some cookies to help us provide localized experiences, such as displaying the Platform in the local language.

  • Platform Features and Services: We use certain cookies to provide greater functionality to the Platform and help us deliver our products and services.

  • Performance: We use performance cookies to help us route traffic between servers and understand how the Platform is performing so we can provide users with the best experience possible.

  • Analytics and Research: We use certain cookies and other technologies also help us to understand, improve, and research features and content on the Platform.

  • Marketing and Online Behavioral Advertising: We may use cookies to help us deliver targeted advertisements through web browsers and on social media platforms based on your activity on the Platform and to track the performance of those ads. In some cases, our partners may also use cookies to provide us with information about your interactions with their services, as applicable. Those third-party cookies would be subject to such third-party service’s privacy policies. The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes. Visit {http://optout.aboutads.info/} to opt-out of having your online behavior collected for advertising purposes.

  1. Web Beacons

Our Platform may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the Platform is used.

We use third parties to gather information about how you and others use the Platform.  For example, we will know how many Users access a specific page and which piece of content they clicked on.  We use this aggregated information to understand and optimize how the Platform is used.

  1. Link to Third Party Websites

The Platform may include links to other websites, mobile applications or services (“Third Party Sites”), whose privacy practices may differ from those set forth herein.  Such links are not an endorsement by Company of those Third Party Sites and/or the products or services they offer.  If you visit Third Party Sites or submit Information to any of those Third Party Sites, your visit and Information is governed by their privacy statements.  We encourage you to carefully read the privacy statement of any Third Party Site you visit, as it may differ substantially from that of this privacy statement.  Company makes no representations or warranties with respect to, nor is Company responsible for the privacy policies of, any Third Party Sites. If you decide to click on any such links or access any Third Party Sites appearing on the Platform, you do so at your own risk.

  1. Your Rights

In certain circumstances you have the right to access the Personal Information that we collect/hold about you and to correct, update, or request deletion your Personal Information.  Prior to the fulfillment of your request concerning your Personal Information, we will ask you to verify your identity before we can act upon your request.

You have the following rights:

  • The right to require free of charge (i) confirmation of whether we process your Personal Information and (ii) access to a copy of the Personal Information retained;

  • The right to request proper rectification, removal or restriction of your Personal Information;

  • Where processing of your Personal Information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Information concerning you in a structured, commonly used and machine-readable format or to have your Personal Information transmitted directly to another company, where technically feasible (data portability);

  • Where the processing of your Personal Information is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question;

  • The right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and

  • The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Information, as well as to lodge complaints before the competent data protection regulators.

As far as we process your Personal Information on the basis of our legitimate interests, you can object to processing at any time. You can find a detailed description of our processing activities and the legal basis in the sections above. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your Personal Information and decide whether to adjust the processing accordingly.

  1. Do Not Track Requests

Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

  1. Security

The security of your information is important to us, and we take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.  Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, for example, by encryption, we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk.

We follow generally accepted industry standards to protect your information, both during transmission and once we receive it, and to keep such Information confidential (unless it is non-confidential by nature, for example, publicly-available information) and free from any unauthorized alteration. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. While we strive to keep current our security technology and will review, refine and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete and absolute security of any Information collected, stored or used by us cannot therefore be guaranteed.  In the unlikely event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information.  If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately.

If you have any questions about security on our Platform, you can contact us at privacy@venn.tv.

  1. Children’s Privacy

IF YOU ARE UNDER 13 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE PLATFORM AT ANY TIME OR IN ANY MANNER.

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or maintain personal information (as defined by the United States Children’s Online Privacy Protection Act) from persons under 13 years-of-age. If we learn that personal information of persons under 13 has been collected on or through the Platform, we will take appropriate steps to delete this information.

If you are the parent or legal guardian of a child under 13 who has become a User, then please contact at business@venn.tv to have that child’s account terminated and personal information deleted.

  1. Updates; Notification of Privacy Policy Changes

We may update this Privacy Policy to reflect changes to our information practices from time to time in our sole discretion.  If we make any material changes to this Privacy Policy we will notify you by posting such changes on the Platform prior to the change becoming effective. We will also update the date at the top of this Privacy Policy, which reflects the effective date of such Privacy Policy, and we encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.  Once a change becomes effective, your continued use of the Platform and/or creation of an Account shall automatically constitute your acceptance of such changes.

  1. Your California Privacy Rights

Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. As explained elsewhere in this Privacy Policy, we will not sell or transfer your personal information to third party companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this statute or who have questions more generally about our Privacy Policy and our privacy commitments to our customers and Web site users should not hesitate to contact us at the address or phone number below.

  1. Contacting Us

In the event that you wish to make a complaint or request concerning your Personal Information or our privacy practices, or have questions, concerns or comments about this Privacy Policy, please contact us either by mail to Gaming 247, Inc., 368 9th Ave, 6th Floor, New York, NY 10001; Attn: Privacy Policy, or email to business@venn.tv and we will endeavor to deal with your request as soon as possible.  This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute process set forth in the Terms of Service.


VENN is a Trademark of Gaming 247, Inc.  All rights reserved.