PRIVACY

This Privacy Policy describes and outlines the policies and procedures of Suprize Inc. (“Suprize," “we," "our" or "us") and the types of personal information and other data that we will collect from you in connection with your use of our mobile application (the "App"), and how we will use and when we might disclose such information and data to third parties. Your installation and/or use of the App and/or submission of information to us constitute your consent to this Privacy Policy.

What Does This Privacy Policy Cover?
This Privacy Policy covers and refers to two types of information:

1. “Personal Information”
Information about an identifiable individual and includes the type of information that specifically identifies you personally and/or can be used alone to contact you online or offline, such as your full name, user name, physical address, email address, phone number, photograph, social security number (only if you become a winner) and precise geolocation information. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners; and

2. “Other Information”
which is information that may not identify you and cannot be used to contact you personally, including information about you such as your date of birth, ZIP code, non-precise geolocation information (e.g., your city), and gender, as well as information about your mobile device, such as your unique device ID, Internet Protocol (IP) address, or other persistent identifiers, and their hardware/software/firmware. Other Information also includes “Usage Data,” which includes data relating to usage of your device, such as the actions you take within and outside of the App, the browser and/or device you use, the date and time of your use of the App, particular preferences you have chosen, and the apps you used before and after using our App.

Depending on your jurisdiction of residence, Other Information may also be Personal Information. If you are located in such a jurisdiction, to the extent your Other Information is Personal Information, it will be collected, used and disclosed as Personal Information according to this Privacy Policy. Together, Personal Information and Other Information may collectively be referred to as “Information.”

What Information Do We Collect?
The information we collect enables us to improve, customize, personalize and operate the services. We collect the following types of information from our users:
· If you choose to open an account with us, participate in our contests, request support, sign up to receive notifications, or in any other way take steps that require the submission of Information, we will collect all information you submit, which may include your name, email address, phone number, date of birth, zip code and/or gender.
· If you partake in any contests or games, you may be required to submit additional Personal Information such as your name, street address, city, state and zip code, email address, phone number and date of birth.
· If you choose to submit your Information to us for any other reason in any other form (e.g., customer service requests, inquiry submissions, etc.), we will collect such Information and use it for the purposes for which you submitted it and to improve the App and our services.
· User profile information including your first name, first initial of your last name, username and other information you may enter or submit at sign up and/or in the winner publicity release agreement may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses or phone numbers to other users.
· We may communicate with you via push notification, email, SMS, MMS or other text message (“Message”) (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email, read a Message or receive a push notification. We use this information to improve our Services, including without limitation our customer service. · We may access your device’s phonebook or contact list to gather Information such as your friend’s contact information in order to facilitate inviting your friends to join our App, but only if you have first given us your express consent.

· You may be able to access posting and sharing tools on the Services that allow you to post or share information to your social networks outside of the Services (“Share”). By using these tools, you acknowledge that some account information from your account on the applicable Third Party Service may be transmitted into your Account with us, and that such information is covered by this Privacy Policy. Furthermore, if a tool, such as the Share tool, is operated by a Third Party Service, the Third Party Service that operates the tool may collect information about your browser or online activity, which would be subject to the Third Party Service’s privacy policy. When you use these tools, some of your information from the Services may be shared with the Third Party Service and others. Therefore, we encourage you to read the privacy policies and other policies of any Third Party Services, including without limitation any applicable social networks, you use in connection with the Services

· We may collect Information about your location, but only if you have first given us your express consent. With your consent, we may also collect Information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.
· We, or third party analytics services on our behalf, may collect Information such as device IDs, IP addresses and other persistent identifiers whenever you use our App.
· A special note about cookies: When you use the App, we may also use “cookies,” “web beacons” or similar tracking technologies, which are tiny files that identify your computer or mobile device that collect and store Usage Data relating to such computer or mobile device. Should you choose to submit other Information to us, we may link that Usage Data to your other Information. You may be able to disable cookies and other tracking technology; however, some of our App will not function properly if you do so and you may lose access to the parts of the App you wish to use.

Use of the Personal Information That We Collect
We will use your Personal Information to:
· Provide you with the services or functionality you have requested, including facilitating posts, messaging and chats, contacting your friends, registering you for a contest or game, and processing any prizes or awards you’ve won;

· Respond to any inquiries you have made through our customer service features;

· We may also contact you to generally promote our App or alert you to special offers or features. We will provide you with the opportunity to opt out of receiving such communications in the future. You may also opt out of receiving such communications at any time in accordance with the instructions provided in this Privacy Policy. Please note that if you have chosen to opt-out of receiving promotional emails, you will still receive emails alerting you if you have won a contest, or other personal communications regarding your win and/or prize.

Use of the Other Information That We Collect
Other Information may be used by us for administrative, analytical, research, optimization, security and other purposes. Specifically, we may use your Other Information (including Usage Data collected through tracking technologies) to:
· Track your use of our App to help us learn more about your preferences and tendencies so that we can personalize your experience, provide you with notifications that are tailored to you, and otherwise enhance your experience;

· Determine which features, products and services users enjoy the most so we can enhance and improve our App;

· Evaluate the success of certain features;

· Protect against crime or fraud, or to address other security concerns.

Disclosure of the Information That We Collect
· We will not sell, rent or transfer your Personal Information to third parties for marketing purposes without your prior consent. Specifically, we will not disclose your Personal Information to third parties for their direct marketing purposes unless you first “opt in” or affirmatively agree to the disclosure.

· In order to provide certain aspects of our App, such as prize fulfillment, we may be required to share your Information, including Personal Information, with third parties with whom we have contracted to assist us in providing such App. Your Information may be maintained and processed by us or our third party service providers in the US or other jurisdictions. In addition, Information in aggregated, anonymous form may be shared with third parties who assist us with our internal operations such as administration, analytics, research, strategy and optimization. The third parties we contract with for the foregoing purposes (“App Providers”) will be authorized to use such Information only for the purposes for which the party was engaged.

· Our App may offer social sharing features such as via Instagram or other third party social networking sites. If you decide to use such features, it may allow the sharing and collection of Information both to and from such third-party social networks. You should visit the policies of such third parties for more information about their information collection practices.

· We and our Canadian, US and other service providers may disclose your Personal Information or other Information collected if required by law or court order, if the information relates to actual or threatened harmful conduct, to investigate and/or take action against illegal activity, suspected abuse or unauthorized use of the App, or to protect the property or safety of others. We may also share your Information with an organization in the case of a breach of an agreement or contravention of law, or to detect, suppress or prevent fraud.

· In connection with an actual or proposed sale or transfer of our company or any line of business (including the assets relating thereto) or other corporate reorganization or change in corporate control, customer information generally is one of the transferred business assets, and such customer information (including your Personal Information) will be transferred, shared or sold to the acquirer or transferee or potential acquirer or transferee.

Advertising
By using our App, you may be offered advertising content. We or the ad networks we use may utilize ad-serving technologies that use cookies, web beacons, tracking pixels and other technologies that are placed within the ads and allow us or our networks to collect Information. Information such as age and gender may be used to ensure that appropriate advertising is offered to you, otherwise known as interest-based advertising. Information such as advertising identifiers may be used to determine how many clicks an ad received, to measure the effectiveness of ad campaigns, to determine the proper amount of repeat views of a given ad, and/or to deliver ads that best relate to your interests.

To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please visit http://youradchoices.ca/ and find out how you can download the version of AppChoices for your device. Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection and use of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.
Depending on your device and its operating system, you may also be able to choose to prevent your device's ad identifier being used for interest-based advertising or reset your device's ad identifier by changing the settings of your device.

Your Rights and Access to Your Information
We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at legal@suprize.win. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.

If you wish to opt out of further communications from us, or if you wish to review, delete and/or revise the Personal Information we have stored about you, please contact us with your specific request at legal@suprize.win; provided, however, that we reserve the right to retain an archive of such Personal Information for a commercially reasonable time to ensure that its deletion does not affect the integrity of our data; and we further reserve the right to retain an anonymous version of such information.
You may have the ability to decline to permit cookies or other tracking technology, but in that case we cannot promise you that all features will function properly as a result.
If you use the App, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account.

Children and Minors
We do not knowingly collect or use any Personal Information from minors under the age of 13. If we collect Personal Information from someone we learn to be under 13 years of age, such Personal Information shall immediately be deleted. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at legal@suprize.win.
If you are a California resident under the age of 18, and a registered user of our App, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to legal@suprize.win and include “CA Removal Request” in the subject line. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Changes
We reserve the right to change this Privacy Policy at any time. In the event we make material changes to this Privacy Policy, such policy will be re-posted in the "Privacy" section of our App with the date such modifications were made indicated on the top of the page. Therefore, please review this Privacy Policy from time to time so that you are aware when any changes are made to this Privacy Policy. If you have any questions about the changes that were implemented, please contact us at legal@suprize.win and include “Information Regarding Updated Policy” in the subject line. In any event, your continued use of the App after such change constitutes your acceptance of any such change(s), and if you do not accept any changes, you may choose not to use the App or opt out by sending us an appropriate notice.

Security
It is entirely your choice whether or not you provide Personal Information to us. We have put in place physical, electronic, and managerial procedures to attempt to safeguard and help prevent unauthorized access, use, modification and disclosure and maintain data security, and correctly use the Personal Information collected through the App. We take, or obligate applicable third parties to take, reasonable precautions to protect our customers' Personal Information against loss, misuse, unauthorized disclosure, alteration, and destruction. However, please remember that no transmission of data over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to us or from us, and you do so at your own risk. We cannot ensure or warrant the security of any information you transmit to us by email and you do so at your own risk.
If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at legal@suprize.win.

Your California Privacy Rights
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California customer, a business may be required to provide detailed information regarding how that business has shared that customer’s personal information with third parties for direct marketing purposes. However, the foregoing does not apply to businesses like ours that either do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their personal information disclosed to third parties for their direct marketing purposes (for more detail on our policy, please see the first bullet point in the Section above entitled “Disclosure of the Information That We Collect”). California users may request further information about their rights under this law and our policy by writing to us at legal@suprize.win, using the subject line “CA Request for Information,” and requesting further information.
California Do Not Track Disclosures: because we respect your privacy, we will abide by any “do not track” technology that you may choose to utilize, although, as described above with cookies, such technology may negatively affect the functionality of the App. Third Party Links
Our App may contain links to other sites on the Web. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave the Suprize platform and to read the privacy statements of each and every Website that collects personally identifiable information. This privacy policy applies solely to information collected on the Suprize platform.

Legal Disclaimer
Our App operates as-is, and we do not represent or warrant that our App will be available at all times, or that your use of the App will be uninterrupted or error-free. We are not responsible for your ability to access the App or for matters beyond our control. This Privacy Policy is governed by California law, excluding its provisions on choice of law.

Contact Us
Please contact our Privacy Officer at legal@suprize.win if:
you have any questions or comments about this Privacy Policy
you wish to access, update, and/or correct inaccuracies in your personal information, or
you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.

This Privacy Policy is effective as of 11 January 2018 and has not been modified since that date.