EXPONENTIAL ENTERTAINMENT PRIVACY POLICY

Privacy Policy Kids

Exponential Entertainment, Inc. is committed to Protecting your Privacy

Exponential Entertainment and HollywoodPlayer services are brought to you by Exponential Entertainment Inc. (collectively, “Exponential Entertainment” or “EE” or “We ”or “Us” or “Our”). We recognize the sensitive nature of personal information and respect your privacy.  This privacy policy (the “Privacy Policy” or “Policy”) governs our collection, use, and disclosure of “Personal Information” in the course of our commercial activities.

“Personal Information” (or, pursuant to the General Data Protection Regulation (“GDPR”), “Personal Data”)means any information about a person from which that person can be identified.

This Policy applies to the collection, use, and disclosure of Personal Information acquired by EE when you use the EE services through the Internet or your TV (the “Service”).

By using the Service or by submitting your Personal Information to EE in any other way, you hereby agree and consent to the processing, uses, and disclosures of Personal Information set out in this Privacy Policy.

Who we are and how to contact us

Exponential Entertainment Inc.

21702 S.E. May Valley Rd

Issaquah, WA 98027

Phone: 206 903 0815

You can contact our Privacy Officer by email at Privacy@HollywoodPlayer.com with the subject line ”Attention: Privacy Officer,” and by mail at:

Attention: Privacy Officer

Exponential Entertainment, Inc

21702 SE May Valley RD.

Issaquah, WA 98027

United States of America

Under the European General Data Protection Regulation (”GDPR”), we are the Data Controller of our European Service users’ Personal Data (to the extent such data is being collected).  With respect to such data, we assume the responsibilities of Data Controller, as set forth in this policy.  Similarly, under the California Consumer Privacy Act (“CCPA”) which may be relevant for California residents(if and where applicable), we are the Business with respect to the Personal Information processed by us.

Questions, comments, requests, and complaints regarding this policy and the information we hold are welcome and should be addressed to us by using the contact details above.  All requests will be dealt with promptly and efficiently.

How do we collect your Personal Information?

We use different methods to collect Personal Information from and about you, including, without limitation:

–      Direct interactions – You may give us your information by corresponding with our customer service by email or otherwise.

–      Automated technologies – As you use the Service through your Internet or TV, the Service may access your Internet Protocol (“IP”) address.

Types of Information we may collect about you

By using the Service or contacting us otherwise, you agree to the collection of the information set out below:

●       When you use the Service through the internet or your TV, we may collect some general usage information. Such data generally does not allow us to identify the individual user of the Service, e.g., technical information regarding your TV service, content accessed, times of use, language preference, etc., and such non-identifying data is generally not Personal Information. We may also access your IP address, which is considered Personal Information under some privacy laws.

●       When you submit an inquiry to our customer service, we may collect your name, email, relevant service (platform), and any other information regarding your inquiry as provided by you.  In addition we will record and retain any further correspondence and interaction with us.  

●       Some of our games in the Service allow the user to provide a screen name for saving score history, etc. (saved locally on your device only; we do not upload, publish, or share that screen name with anyone).

We also collect, use, and share Aggregated Data such as statistical or demographic data (e.g. location of devices in use, time those devices were used, etc.).  Aggregated Data may be derived from your Personal Information but does not reveal your identity.

What types of Personal Information do we access and why?

The only types of Personal Information that we access are (a) your IP address, which allows us to provide advertising content via our third-party advertising partners, and (b) any information that you voluntarily provide us if you contact our customer service (for example, if you email us, you will be giving us whatever email address you choose to use).  

Do we store, retain, or sell any Personal Information?

No.  We do not store, retain, or sell any Personal Information.  The IP address information that we access is only accessed temporarily in order to provide advertising content at the time you use the Service. 

Any general usage information that we store or retain is Aggregated Data that does not reveal your identity and is used solely for analytics purposes to help us improve the Service.  In the event of a sale, merger, or other change of control of Exponential Entertainment, this Aggregated Data may be transferred to another entity.

Cookies and other tracking technologies

Like many other services, the Service, whether directly and/or through third parties, may use cookies” (which are small data files containing information about your use of a service that are stored locally on your device) and other similar tracking technologies (collectively, “Cookies”)to improve your user experience on the Service.

We may use various types of Cookies:

Functional Cookies – designated to save your settings on the Service, including, without limitation, your language preference and game play data (progression, points or other statistics, etc.).

Analytics Cookies – give us aggregated information which enables us to improve the way our Service works, e.g. Google analytics.

Managing Cookies and opting out

You may opt out of any such Cookies usage in the Service by sending an inquiry Privacy@HollywoodPlayer.com .  However, please note that opting out of, deleting, or disabling the Cookies may result in a loss of access to certain features of the Service, and some aspects of the Service may not function properly.

“Lawful Basis” for processing of your Personal Data under the GDPR

Where the GDPR applies (i.e. when we process Personal Data of European residents), we will only process and use your Personal Data when the law allows us to, i.e. when we have a Lawful Basis for such usage.  Such Lawful Basis can be any of the following:

·        Processing actions which we need to take as part of a contract we have between us and you as our Customer, e.g., providing you with the Service or contacting you per communication initiated by you;

·        Processing actions which are necessary to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities;

·        Our use of your information is in our legitimate interest as a commercial organization.  For example, to operate and improve the Service and to keep people informed about our products and services.  In these cases, we will look after your Personal Data at all times in a way that is proportionate and respects your privacy rights, making sure our legitimate interest is not overridden by your interests or fundamental rights and freedoms.

In general, and as detailed above, we do not rely on consent as a legal basis for processing your Personal Data.  Yet, in any case in which you have provided your consent to our processing of your information (to the extent provided), you can withdraw this consent at any time by contacting us through the contact details provided above.

Information Processing Location

We will always keep and store your in accordance with requirements of applicable law.  Any transfer of data which originates in the European Union (including the United Kingdom -“EU”) to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR.  Such transfer can be made to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights, e.g. signing a Standard Contractual Clauses which were published and authorized by the relevant EU authorities.

Please note that we are head quartered in The United States, a country which is considered by the European Data Protection Board to be offering adequate level of Personal Data protection regulation.  

Security of Personal Information

We are committed to protecting your Personal Information.  We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your Personal Information from loss, misuse, unauthorized access, and alteration.  However, no data transmission over the Internet can be guaranteed to be 100% secured from any intrusion or malfunction.  

Your rights under data protection laws

Where the GDPR applies, EU residents and individuals have certain rights with regard to their Personal Information. Similarly, California residents have such rights under the CCPA(to the extent applicable). Those rights might include:

·        Right to access your Personal Information – you can ask us to confirm whether or not we have your Personal Information, and if so, you can ask for a copy of your information;

·        Right to correct your Personal Information – you can ask us to correct any of your Personal Information, which is incorrect, after verifying the accuracy of the data first;

·        Right to erase your Personal Information (“the right to be forgotten”) -you can ask us to erase your Personal Information if you think we no longer need to use it for the purpose we collected it from you.  You can also ask for such erasure in any case in which the process of your data was based on your consent, or where we have used it unlawfully or where we are subject to a legal obligation to erase your Personal Information.  Any request for such erasure will be subject to our obligations under the law (e.g. our obligation to keep some records for tax or customs purposes);

·        Right to restrict our use of your Personal Information – you can ask us to restrict our use of your Personal Information in certain circumstances;

·        Right to object to how we use your Personal Information – you can object to any use of your Personal Information in which we have justified by legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information;

·        You can always require us to refrain from using your data for direct marketing purposes;

·        You can ask us to transfer your information to another organization and/or provide you with a copy of your Personal Information (“Portability Right”);

·        You have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we would appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us using the contact information included in this Privacy Policy.

We will do our best to fulfill your request but may not always be able to so. For example, if the fulfillment of a right would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way. In addition, not all rights apply in every jurisdiction, e.g., the Portability Right doesn’t apply under the CCPA. So we may not be obligated to provide you with those rights. However, we encourage you to contact us with any such request, and we will be happy to assist you.

Privacy protection of Children

We encourage parents and guardians to participate in their children’s activities and to supervise them when they access the Service.  We do not knowingly collect Personal Information from children under the age of 13.  No Personal Information should be submitted to or posted through the Service by users under 13 years of age.  If a child under the age of 13 submits Personal Information to Exponential Entertainment, we will delete the information as soon as we discover it was provided by a child under 13 years of age.  We will not and do not use such information for any purpose.  You can learn more about our privacy policy for children in our Children’s Privacy Policy listed below.

Special Notification for California Residents

We do not sell your Personal Information for the intents and purposes of the CCPA.  We can use your personal data for our purposes, but only as described above or after the anonymization of such data, including aggregate data which can no longer associated to you.

We will not discriminate against you for exercising any of the rights described in this policy.  Specifically, we will not deny you any of our services including the Service, or charge you different prices or rates for goods or services, including through the use of discounts or other benefits, or by imposing penalties.

Changes to this Privacy Policy

We reserve the right to change this policy from time to time at our sole discretion.  If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it.  We will provide advance notice of any such changes in a commercially reasonable manner, but please note that we do not have any access to Personal Information that allows us to contact you directly, such as an email address, mail address, or telephone number.

By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree to this policy as modified.

Contact us

If you need further assistance, please contact us through Privacy@HollywoodPlayer.com, or any of the other means of contact listed above, and we will be happy to assist you.

Last updated:  March 17, 2021

EXPONENTIAL ENTERTAINMENT PRIVACY POLICY KIDS

Exponential Entertainment and Hollywood Player services are brought to you by Exponential Entertainment Inc. (collectively, “Exponential Entertainment” or “EE” or “We ”or “Us” or “Our”).   We recognize the need to provide additional privacy protections when and if children visit and use any online service.

The purpose of this Privacy Policy – Kids (the “Supplement”) is to supplement our general Privacy Policy (incorporated here by reference) and to outline our policy with regard to the processing of Personal Information of children.  The policy applies to the potential collection, use, and disclosure of Personal Information acquired by us in the course of our ongoing conduct, for example when you use the EE services through your Internet or TV (the “Service”).  Please refer to the Privacy Policy for additional information and definitions where applicable.

“Personal Information” means any information about a person from which that person can be identified.

When we use the term “child” or “children” we mean an individual under 13 years of age, or the appropriate age for services directed toward children as defined under applicable laws in other relevant jurisdictions, or an individual under 18 years of age where the collection, use, or disclosure of Personal Information about such an individual is restricted by applicable law.  When we use the term “parent” below, we refer to a legal guardian of such a child.

Access to Children’s information

While some elements of the Service are directed at Children, the Service only has limited, temporary access to any Personal Information, including from Children, in compliance with applicable law.  Such access is limited to Internet Protocol (“IP”) addresses and is for the sole limited purpose of our internal operations so that we may provide advertising content through our third-party advertising partners.  The IP address information that we access is only accessed temporarily in order to provide advertising content at the time you use the Service, and we do not store, collect, or sell any Personal Information.

The Service collects general usage data, such as, without limitation, your TV service, content accessed, times of use, language preference, etc., which is generally not Personal Information as it does not allow us to identify the individual user of the Service.  To the extent that such general usage data contains data regarding Children’s usage of the Service, we are unable to identify or distinguish such data regarding Children’s usage of the Service, because we have no access to the types of Personal Information that would allow one to do so:

–         The Service does not require or collect any personal contact information (e.g., full name, date of birth, phone number, or home address).  The only user-generated information that the Service collects is a user screen name for the purpose of game play; this screen name is stored locally via a Cookie on the user’s device and is not uploaded to, stored, or shared by the Service in any way, and there is no requirement, expectation, or suggestion of any kind that the user should enter any Personal Information as part of a screen name.

–         The Service does not involve the sharing of any players’ or users’ information with other players or users.

–           We do not have any access to any Personal Information that allows us to contact a user directly, such as an email address, mail address, or telephone number.

We do not condition a Child’s participation in an online activity on the child’s providing more contact information than is reasonably necessary to participate in that activity.

The use of Cookies

Some data on the Service may be collected and processed through the use of Cookies or any other similar technology, as detailed under the Cookies section in our Privacy Policy.  Cookies are small data files containing information about your use of a service that are stored locally on your device.  Cookies help us to improve your user experience on the Service.

Some of our Cookies usage is done through third-party providers which provide us with analytics services, e.g. Google analytics.

To learn more about the Cookies usage in the Service and/or the Website, please see under the “Cookies” section in our privacy policy.

Security of Personal Information

We are committed to protecting any Personal Information collected by us. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect Personal Information from loss, misuse, unauthorized access, and alteration.  However, no data transmission over the internet can be guaranteed to be 100% secured from any intrusion or malfunction.  

Changes to this Children’s Privacy Policy

We reserve the right to change this policy from time to time at our sole discretion.  If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it.  We will provide advance notice of any such changes in a commercially reasonable manner, but please note that we do not have any access to Personal Information that allows us to contact you directly, such as an email address, mail address, or telephone number.

By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree to this policy as modified.

Contact us

If you need further assistance, please contact us through Privacy@HollywoodPlayer.com , or any of the other means of contact published in our general Privacy Policy, and we will be happy to assist you.

Last updated:  November 4th, 2021