This Privacy Policy (“Privacy Policy”) describes how 228 Labs, Inc. doing business as Freeplay and its subsidiaries and affiliates (“Freeplay,” “us,” “we,” or “our”) may collect, use, and share your personal information in connection with our website located at freeplay.ai and any other websites and platforms we own and operate that link to this Privacy Policy (collectively, the “Site”), and our related services, events, social media pages, and email and other electronic communications (collectively, and together with the Site, the “Services”), and the choices you have with respect to your personal information. In some cases, region-specific terms may apply to you, which are indicated in the section headings below. This Privacy Policy does not apply to personal information that we may store or maintain on behalf of the users of our platform, where applicable.

Freeplay reserves the right, at any time, to modify this Privacy Policy. If we modify how we collect, use, or share personal information, we will post the updated Privacy Policy on this page. In some cases, we may notify you about an update by sending you an email, posting a notice about the update on the Services, or other means as may be required by applicable law. In all cases, your continued use of the Services following posting or other notification of changes constitutes your acknowledgement of such changes. Please review this Privacy Policy periodically to keep up to date on our most current policies and practices. 

COLLECTION OF PERSONAL INFORMATION

Personal Information Collected. We may collect the following categories of personal information about you. We may also collect other personal information that is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

• Contact information, such as first and last name, email address, and social media handle.

• Professional information, such as company name, location, and email, and other details we may collect about your company.

• Survey responses, such as the information you provide in response to our surveys or questionnaires.

• Communications, such as the information associated with your requests or inquiries, including for support or assistance, and any feedback you provide when you communicate with us. We and our service provider may also record or monitor any call or web chat you have with us for quality control or training purposes, or to enforce our rights.

• Online activity information, such as the website you visited before browsing to the Service, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

• Device information, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.

Sources of Personal Information. We obtain personal information from a variety of sources, including the following sources:

• Personal Information You Provide. Freeplay collects personal information when you voluntarily submit it to us, such as when you fill out a form on the Site, participate in a survey, or communicate with us.

• Personal Information Automatically Collected. Freeplay, our service providers, and our advertising partners may automatically log information about you, your computer, or mobile device, and your activity over time on our Services and other sites and online services, such as the online activity information and device information listed above. Like many online services, we use cookies and similar technologies to facilitate some of the automatic data collection described above, such as:

  • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

  • Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

• Personal Information Obtained from Third Parties. Freeplay may receive personal information from third parties, such as our service providers, advertising partners, data analytics partners, operating systems and platforms, social media platforms, event sponsors, publicly available sources, or data licensors/providers. We may merge or combine such personal information with the personal information we collect from you directly or automatically.

• Referrals. Users of the Services may have the opportunity to refer colleagues or other contacts to us and share their contact information. Please do not provide us with someone’s contact information unless you have their permission to do so.

USE OF PERSONAL INFORMATION

Freeplay’s primary purpose in collecting personal information is to provide the Services that you request. We also use personal information for the purposes set forth below and as otherwise described in this Privacy Policy or at the time of collection.

To Provide the Services. We use personal information to provide our Services and operate our business. For example, we use personal information to:

• improve and personalize your experience on or with the Services;

• verify your identity or determine your eligibility for offers and promotions;

• communicate with you, including responding to any of your requests, feedback, or questions;

• provide any surveys or other promotions you participate in;

• provide maintenance and support; and

• fulfill any other purpose for which you provide personal information
  
  

Research and Development. We use personal information for research and development purposes, including to study and improve the Services and our business, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.

Direct Marketing. We may send you Freeplay-related or other direct marketing communications as permitted by law, including materials, updates, information, special offers, and promotional material from us and our business partners. You may opt-out of our marketing communications as described in the “YOUR CHOICES” section below. 

Interest-Based Advertising. We may work with third-party advertising companies and social media companies to help us advertise our business and to display ads for our products and services. These companies may use cookies and similar technologies to collect information about you (including the online activity information and device information described above) over time across our Services and other websites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. In addition, some of these companies may use hashed customer lists that we share with them to deliver ads to you and to similar users on their platforms. You can learn more about your choices for limiting interest-based advertising in the “YOUR CHOICES” section below. 

To Comply with Laws and Regulations. We will use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For Compliance, Fraud Prevention, and Safety. We may use personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Services and our business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Services; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With Your Consent. We will disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy or at the point of collection, Freeplay may share your personal information with the following entities or persons:

Related Companies. We may share your personal information with our future affiliates, subsidiaries, and other related companies. 

Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with service providers that help us perform website hosting, maintenance services, database management, analytics, fraud protection, marketing, customer relationship management, finances, and other purposes.

Advertising Partners. We may also share personal information with third parties who we partner with for advertising campaigns or that collect information about your activity on the Services for the purposes described in the “Interest-Based Advertising” section above.

Other Users of the Services and the Public. We may provide functionality that enables you to disclose personal information to other users of the Services or the public. For instance, you may be able to submit content to the Services (such as comments, questions, and reviews), and we will identify you by displaying information such as your name or social media handle along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.

Professional Advisors. We may share personal information with persons, companies, or professional firms providing Freeplay with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.

Law Enforcement. Under certain circumstances, we may be required to disclose personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). 

Compliance. We may disclose personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “Compliance, Fraud Prevention, and Safety.”

Business Transaction Participants. We may disclose personal information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

CHOICES ABOUT YOUR PERSONAL INFORMATION 

You can make the following choices regarding your personal information:

Review and Request Changes to Your Personal Information. If the Site does not permit you to update or correct certain personal information, please submit a request to us using the contact information listed at the end of this Privacy Policy.

Marketing Emails. You may opt-out of marketing-related emails by clicking the “unsubscribe” link at the bottom of the email or by contacting us as described at the end of this Privacy Policy. 

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Services and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. 

Analytics. The Site uses Google Analytics to help us analyze how the Site is being accessed and used. You can learn more about Google Analytics cookies by clicking here and about how Google protects your data by clicking here. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on, available here. 

Advertising Choices. You can limit the use of your information for interest-based advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (https://optout.aboutads.info). Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here.

Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Site currently does not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. 

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Freeplay is based in the United States, and we have service providers in the United States and potentially other countries. Your personal information may be collected, used, and stored in these countries or other locations outside of your home country. Privacy laws in the locations where we handle your personal information may not be as protective as the privacy laws in your home country. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.

CHILDREN’S PRIVACY

The Services are not intended for use by anyone under the age of 16, and we do not knowingly collect personal information from children under 16. 

SECURITY OF PERSONAL INFORMATION

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use commercially reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. 

OTHER SITES AND SERVICES

The Services may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

NOTICE TO CALIFORNIA RESIDENTS (SHINE THE LIGHT)

Under California Civil Code sections 1798.83-1798.84, California residents who have an established business relationship with a company are entitled to ask the company for a notice describing what categories of personal information it shares with third parties for the third parties’ direct marketing purposes. We do not disclose personal information obtained through our Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code §1798.83.

NOTICE TO NEVADA RESIDENTS

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt-out of sales using the contact information listed at the end of this Privacy Policy and we will record your instructions and incorporate them in the future if our policy changes. 

CONTACTING US

If you have any questions or concerns about our Privacy Policy or any other privacy or security issue, please contact us at privacy@freeplay.ai.