This Privacy Policy describes how Elo Entertainment Inc. (the "Company") collects, uses, and discloses information, and what choices you have with respect to that information.

This document was last updated on January 15th, 2024.

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Application of this Privacy Policy

This Privacy Policy applies to all websites, Internet properties, applications, and accounts operated by the Company. This includes all websites, applications, accounts, and services owned or operated by the Company (collectively, the "Services").

This Privacy Policy applies to all Users of the Services, where “User” is defined as anyone who accesses the Website, regardless of subscription status or lack thereof.

Please refer to our Terms of Use (the "Terms") for additional information regarding your use of the Website and the Services provided by the Company.

By accessing the Website or using the Services, you acknowledge that you have read, understand, and accept this Privacy Policy and the Terms. For Users who access the Website without signing in, we reserve the right to collect and process Service Usage Data that may be used for legitimate interests of the Company. For Users who create an account with the Company, including paying subscribers, you may consent to the collection and processing of your data by agreeing to the Customer Agreement presented during the sign up process.

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Information we collect and receive

We collect data in three different categories:

• Website Information. We collect certain categories of information from all users of our website.

  • Service usage data. With the help of third parties like Google Analytics and Quantcast we automatically collect visitor usage data. This may include your IP address, location, device and browser type, demographic information, or similar information, as well as a record of the pages or screens you visit. This data is anonymized and not connected to your specific account.
  • Service logs. As with most websites and applications, our services automatically collect information when you access the Service. This log data may include your IP address, the address or location of the requested web page, your browser type and settings, the date and time of the event, and data from your user session (such as your session identifier).
  • Email communications. For users who choose to send us email (such as for customer service, media or business development inquiries, or other purposes), we retain a record of the conversation including your email address and messages.
  • Chat and social media messages. For users who interact with us on social media or chat services (like Twitter or Discord, respectively), we may retain a record of those communications including your service identity and messages.

• User information. For visitors who use our Services, we may collect the following information. None of this information is collected automatically, you must choose to provide it.

  • Email addresses. Users may choose to provide their email address, which we store on our servers.
  • Third party accounts. Users may choose to link third party accounts like Steam, Battle.net, Twitch, Discord, Twitter, etc. In this case, we store the identities and related metadata for those third party accounts.
  • User submitted content. Users may choose to submit original content like forum threads, comments, profile customizations, and other user created or submitted content. We collect and store this information on our servers.

• Customer information. For Users who pay the Company for services (the "Customer"), we may collect the following information. None of this information is collected automatically, you must choose to provide it.

  • Email addresses. Customers are required to provide their email address, which we store on our servers.
  • Payment data. Customers must provide their name, payment method and related payment details. Additionally, we may receive your IP address, transaction identifiers and metadata as part of completing your purchase. We use PayPal and Stripe to process payments and never process or store your credit card or bank information on our servers.

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How we use information

We use the information collected for the following purposes:

• To provide, update, maintain, and operate the Services. We use User, Customer, and Website Information to provide customized features for you on the Services. We may use Website Information to improve website performance and resolve problems with the Services.
• To develop and provide additional features on the Services. We use User, Customer and Website Information to aide in making decisions about the future of the Services, such as making improvements or creating new features. For example, we may aggregate and anonymize User Information and/or Customer Information to determine the number of visitors who have linked their Twitch account and whether further information about the benefits of such linking would be helpful.
• To communicate with you by responding to your requests, comments and questions. We use User, Customer, and Website Information to aide in the resolution of support tickets for purposes of customer service or business development.
• To send emails and other communications. We use User and Customer Information to send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services or important Services-related notices. These communications are considered part of the Services and you may not opt out of them without discontinuing use of the Services. In addition, we sometimes send emails about new product features, promotional communications or other news about the Services. These are marketing messages and you can control whether you receive them.
• For billing, account management and other administrative matters. We use User and Customer Information to contact you for billing, account management and similar reasons.
• For business development purposes. We use Website Information to aide in the growth of the business of the Company.
• To investigate and help prevent security issues, fraud, or other illegal activity.
• For other purposes as required by applicable law, legal process or regulation, including, but not limited to, in the event that any of the personal information you provided to us is exposed to unauthorized third-parties. In the event of such unauthorized exposure, we expressly reserve the right to provide notice to you electronically via any email address you have provided directly to us if permitted to do so by law.
• To investigate or defend against third-party claims against the Company.
• To respond to a request by you, or a person authorized by you, to disclose or delete any collected information.
• For any other purpose after receiving your express consent.

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How and to whom we share and disclose information

We may share the information we collect according to the following guidelines:

• Display on the services. We may display User Information to other users of the Services. For example, by authorizing and linking your Discord account, we may show your data from that account to other visitors.
• Data insights and matching. We may display User Information to users of the Services, including matched, analyzed or accumulated data to our paying “Plus” users.
• Third party service providers and partners. We may engage third party companies or individuals as service providers or business partners to process data to support our business. These third parties may, for example, provide virtual computing, storage, payment, help desk, bug tracking, or other related services. We may share Website Information with these third parties, and we make a conscious effort to share the minimum amount of data possible with each third party service.
• Corporate affiliates and partners. We may share Website Information with corporate affiliates, parents and/or subsidiaries. If the Company engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of the Company's assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all User and Customer Information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or anonymized data. We may disclose or use aggregated or de-identified data for any purpose. For example, we may share aggregated or de-identified account, usage, and log with prospects or partners for business or research purposes.
• Upon request. We may share or disclose User Information in accordance with the instructions of the User, and in compliance with applicable law and legal process.
• To comply with laws. If we receive a request for information, we may disclose User, Customer, or Website Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Upon receipt of a request for information, the Company reserves the right to verify the identity of the person requesting access to or deletion of the information as allowed by applicable law.
• To enforce our rights, prevent fraud, and for safety. We may use data to protect and defend the rights, property or safety of the Company or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• With consent. We may share data with third parties when we have your consent to do so.

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Data retention

We may retain User, Customer, and Website Information for as long as necessary to aide in delivery of the Services, unless a different retention period is required by any applicable law, rule or regulation. Users may control which account data we collect, and may remove existing User Information by de-authorizing third party services. In the case you are unable to remove existing account data yourself, we will anonymize or remove other account data upon request. The Company reserves the right to delete or destroy any such information at any time.

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Security

We implement commercially reasonable security measures to protect information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology. Given the nature of communications and information processing technology, the Company cannot and does not guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

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Age limitations

To the extent prohibited by applicable law, the Company does not allow use of our Services by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

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Changes to this Privacy Policy

We may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services. If you do not consent to the changes to this Privacy Policy, you should deactivate your Services account.

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Your rights

Residents of certain areas, including the European Economic Area and California, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact us for additional access and assistance by emailing support@elo.io. The Company will not retaliate or discriminate against you for exercising your rights under any such applicable law. However, this does not restrict the right of the Company to engage in financial incentive programs or otherwise alter the Services received if they are directly related to the value provided to the Company by the consumer’s data.

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Cookies

A cookie is a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site’s computers and stored on your computer’s hard drive. Our Services use cookies to record current session information. Our cookies typically exist perpetually and we provide the ability to remove your session cookie with a sign out link.

Additionally, most web browsers allow you to set controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Website though your access to some functionality and areas of our Website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

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Google Analytics

Among other technologies, the Website uses Google Analytics, a service provided by Google, Inc. Google Analytics uses cookies to analyze how our Website is used. Google Analytics has its own policy that describes how it collects and processes data, located here. By using our Website, you agree to the processing of data about you by Google in the manner and for the purposes described here and in the Google Analytics policy.

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Do-not-track disclosure

This Website does not respond to “Do Not Track Signals.”

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Links to third party websites

The Website may contain links to other third-party websites (each a “Linked Website” and together the “Linked Websites”). The Linked Websites are not under the control of the Company and the Company disclaims any and all responsibility for the contents of any Linked Website, including without limitation any link contained in a Linked Website, or any changes or updates to a Linked Website. The Company is not responsible for webcasting or any other form of transmission received from any Linked Website. The Company is providing these links, if any, to you only as a convenience, and the inclusion of any link does not necessarily imply endorsement or representations by the Company of the Website or any association with its operators. You are encouraged to review any Privacy Policy or terms of service posted on the Linked Websites.

The Company cannot and does not assume any responsibility for any actions or omissions of operators of the Linked Websites, including the manner in which they use information received either from us or independently. Nevertheless, in the event you encounter any third party associated with, or who claims association with, us who you feel is improperly collecting or using information about you, please contact support@elo.io; the Company will make reasonable efforts to address your concerns.

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Severability

If any part of this Privacy Policy is determined to be invalid or unenforceable pursuant to applicable law, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of this Privacy Policy shall continue in effect.

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Data Protection Officer

To communicate with our Data Protection Officer, please email support@elo.io.