Effective Date: September 28, 2022
Summary of Key Points
Information We Collect
When you register as a User on the Application or use a Free Play Service, you will be required to enter the information set out in the registration application or the Free Play Service, which may include your first and last name, your email address, phone number and other identifying information. The Company will use that information to create your account or allow participation in the Free Play Service. The Company may also use this information to contact you with Services updates and relevant opportunities, and for such other purposes as it deems necessary in its discretion.
We do not collect or process credit or debit card (“Payment Card”) data. Apple, Google, and any other External Service Provider (as defined in the Terms of Service, which may be found at https://eliasgameplan.com/terms/) you use collects Payment Card data with respect to purchases made through the Application. Such External Service Providers generally provide us with some limited data related to you, such as the status of your Subscription. When you access your account on the Application, the Company’s servers may automatically record information about that access. The Company will use this information to monitor and analyze use of the Application and for technical administration, to increase the Application’s functionality and user-friendliness, and to better tailor it to Users’ needs.
The Company may use persistent state (“cookies”, “HTML5 local storage”, etc. – collectively “persistent cookies”) to collect information on the Website. Persistent cookies are data that the Company transfers to your computer’s storage system(s) for record-keeping purposes. The Company may also use session ID cookies to enable certain features of the Website, to better understand how you interact with the Website and to monitor aggregate usage by visitors and web traffic routing on the Website. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Website and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the Website. If you do not accept cookies, however, you may not be able to use all functionality of the Website.
The Company may also anonymously aggregate User data, including data supplied by Users as part of the Services, to understand and report on geographic areas of activity (e.g., top cities).
When you use the Free Play Service, the Company also collects your inputs (i.e., your picks).
When you use the Company’s Application, we also may collect mobile device information like operating system and hardware type, numbers or codes that are unique to your particular device (such as IDFA or an Android Ad ID), device information, default device language, the location of your device (at a GPS level), and app usage information. This data also may be linked to your other information, including your location data. You can use settings on your mobile device to change or restrict the data collected by the Application and to limit the access of the Application to your device. Such changes or restrictions may affect the performance of the Application.
We do comply with Do Not Track requests.
As explained in the Terms of Service, the Company allows Users to send messages to individuals through the Third-Party Messaging App Feature using separate messaging applications in use on your mobile device or through other third-party software or applications (the “Third-Party Messaging App”). While the Company does collect and store information relating to your use of the Third-Party Messaging App Feature, the Company does not collect or store any information from a Third-Party Messaging App.
The Company will retain this information as long as necessary to fulfill these purposes unless the law requires us to keep it for a longer period of time. To provide security and business continuity for the activities described here, we make backups of certain data, which we may retain for longer than the original data. The Company may share information it collects with its affiliated companies.
Use of Information and Disclosure
Account information. The Company does not share your account information with anyone unless you direct us to do so.
Unsolicited communication. The Company may send you email or other communications for promotional purposes or to advise you of potential opportunities. You will have a chance to change the frequency or discontinue such emails.
Legal requirements. We may use your information to verify your identity, age, and location to assist the Company in compliance with applicable laws. We may disclose your information in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.
Investigation. We may disclose your information when we believe it appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Service for the Services you accessed, or to protect our rights and property.
Sales to Third-Parties.
The Company may anonymously aggregate User-generated content and Subscription status to sell or provide to third-parties. The Company will not sell or provide User-generated content to third-parties that contains personal data or information of the User, except to third-parties you have already provided some or all of your personal data or information to through your use of the Free Play Services (e.g. the third-party that invited you to participate in the Free Play Services). Personal data – or personal information – is any information that relates to you – an identified or identifiable natural person.
Bankruptcy. In the unlikely event of the Company’s 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 data is treated, transferred, or used and your personal data may be included in the transferred assets.
The Company is very concerned with safeguarding your information. The Company employs reasonable electronic measures designed to protect your information from unauthorized access.
Although the Company takes such precautions against possible security breaches, no website, mobile application, or internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss or other breach will never occur. If any information under our control is compromised as a result of a breach of security, the Company will take reasonable steps to investigate the situation. The Company will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “data” (as defined in applicable state statutes on security breach notification) to you via conspicuous posting on the Company website or through any other means required by law in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
The Company currently does not intentionally accept users from outside the United States, and we will take reasonable steps to delete any data we receive from outside the United States. If you provide us data from outside the United States, it will necessarily be transferred to the United States for processing and storage, and by using the Services, you consent to such transfer.
Our Services are restricted to individuals who are 21 years of age or older. We do not permit individuals under the age of 21 on our platform. If you suspect that a user is under the age of 21, please report the situation to us by emailing us at firstname.lastname@example.org.
If you have any questions regarding this information or our privacy practices, or if you wish to make a complaint, email us at email@example.com, or write to us at:
c/o Elias Digital Solutions LLC
New York, New York 10018