Privacy Policy - That Questions Game

This notice describes our Privacy Policy. Our Privacy Policy explains how Keoch Ventures (“Keoch”) collects, uses, and protects the Personal Data obtained through the use of our That Questions Game mobile application (“App”), our website or any of our other products and/or services (collectively, “Services”). By visiting the Site, using or downloading the App, or using any of our Services, you agree that your Personal Data will be handled as described in this Privacy Policy. Your use of our Site, App, or Services, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Keoch Terms of Use are incorporated by reference into this Privacy Policy.

DEFINITIONS:

DATA CONTROLLER: Data Controller is the publisher, owner, and operator of the Services and is the party responsible for the collection of information described herein. If Data Controller or Data Controller's property shall be referred to through first-person pronouns, it shall be through the use of the following: us, we, our, ours, etc.
YOU: Should you agree to this Privacy Policy and continue your use of the Services, you will be referred to herein as either you, the user, or if any second-person pronouns are required and applicable, such pronouns as 'your", "yours", etc.
PERSONAL DATA: "Personal Data" means personal data and information that we obtain from you in connection with your use of the Services that is capable of identifying you in any manner.

GENERAL INFORMATION:

This Privacy Policy does not cover any information that we may receive about you through sources other than the use of our Services, other than as explicitly stated herein. The Services may link out to other websites or mobile applications, but this Privacy Policy does not and will not apply to any of those linked websites or applications.

We are committed to the protection of your privacy while you use our Services.

By continuing to use our Services, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your information and the method of disclosure as described in this Privacy Policy. If you do not understand the Privacy Policy or do not agree to it, then you agree to immediately cease your use of our Services.

CHILDREN:

The Services are not intended for use by children under the age of 13. Keoch does not allow individuals under the age of 13 to create an account, nor do we knowingly collect or use any Personal Data from such children under the age of 13. If you are between 13 and 18 years of age, in selected territories at Keoch’s sole discretion, you may use the Services only if your parent(s) and/or legal guardian(s) review and agree to our Terms, this Privacy Policy and permit you to access and/or use our Service.

If you believe that your child has submitted personal data to Keoch without your consent, please contact us at TQG@thatquestionsgame.com. Keoch will take reasonable steps to delete such information as soon as possible.

CONTACT AND LOCATION:

Please be advised the data processing activities take place in the United States, outside the European Economic Area. Data may also be transferred to companies within the United States, but will only be done so in a manner that complies with the EU's General Data Protection Regulation or GDPR. The location where the data processing activities take place is as follows:

INSERT LOCATION

MODIFICATIONS AND REVISIONS:

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner. If we do so, however, we will notify you and obtain your consent to the change in processing. Unless we specifically obtain your consent, any changes to the Privacy Policy will only impact the information collected on or after the date of the change. It is also your responsibility to periodically check this page for any such modification, revision or amendment.

THE PERSONAL DATA WE RECEIVE FROM YOU:

We collect Personal Data to fulfill our functions and activities, as described herein. When you use our Services, you will be subject to different types of Personal Data collected and different manners of collection.

Personal Data That You Share with Us Directly

You may give us information directly in a number of ways, including:
to set up your Account;
in response to surveys or other research we conduct;
to participate in contests and sweepstakes;
via social media;
by participating in group communications;
in communications with customer support agents;
The information you share with us may include all information available in our Google Play or iOS Game Center accounts, for example:
your age;
your first and/or last name;
your country of residence;
your e-mail address;
the password you use to access our Service;
information about your account, a device on which you are playing or using our App, and/or other information about a request or inquiry you make;
other information that helps us make sure it’s you accessing your Account, including as necessary for us to provide the support you request, or information you provide to help us improve our Service (such as answers to an online survey or a feedback form).

Personal Data That We Get from Others

We may collect or receive information about you from other sources like third-party applications, such as an app stor or third party login services. We use this information along with information you provide us directly in a number of ways as described in this Privacy Notice, for example, to help you and your friends connect or to serve you advertising tailored to your interests.

If you play our App or access our Service on connected third-party applications or connect our Service to any third-party applications, Keoch may receive certain information about you from the provider of the third-party application. The information we receive depends on the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application.

For example, Keoch may collect and store some or all of the following information and Personal Data shared by the third-party application:

your first and last name;
your profile picture or its URL;
your user ID number (like your Facebook ID number), which may be linked to other information like your name and profile photo, and your friends’ identifiers;
your friends list, which includes the user ID number and other information of your friends, like their names and profile photos;
the login e-mail you provided to the third-party application;
your physical location and that of the devices you use to access our Service;
your gender;
your birthday and/or age;
information about your activities on or through the third-party application;
other information you have shared on the third-party application;
any other information that you or the provider of the third-party application share with Keoch.
If you access our Service from a third-party application or connect our Service to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Notice.

If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices

Payment & Billing Information

In order to purchase any of the Services on the Services, you will be asked to pay directly through the applicable app store account in which the App was downloaded.

Remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So, if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. Once you leave our Services or are redirected to a third-party application, you are no longer governed by this Privacy Policy or our Terms of Use.

Related Entities

We may share your Personal Data, including Personal Data that identifies you personally, with any of our parent companies, subsidiary companies, affiliates or other trusted related entities.

However, we only share your Personal Data with a trusted related entity if that entity agrees to our privacy standards as set out in this Privacy Policy and to treat your Personal Data in the same manner that we do.

Email Marketing

You may be asked to provide certain Personal Data, such as your name and email address, for the purpose of receiving email marketing communications. This information will only be obtained through your voluntary disclosure and you will be asked to affirmatively opt-in to email marketing communications.

User Experience

From time to time we may request information from you to assist us in improving our Services, and the Services we sell, such as demographic information or your particular preferences.

Combined or Aggregated Information

We may combine or aggregate some of your Personal Data in order to better serve you and to better enhance and update our Services for your and other consumers' use.

COOKIE POLICY AND THE PERSONAL DATA WE RECEIVE AUTOMATICALLY:

Keoch may use cookies and other tracking mechanisms to track information about your use of our Services. Cookies are typically defined in one of two categories, session and persistent. Session cookies do not stay on your device after you close your browser and persistent cookies do remain on your device until deleted or they expire. We may combine this information with other Personal Data we collect from you. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster login and payment process or to allow us to track your activities on our Site. Our Third-Party Service Providers and Site host may also place cookies on our Site in order to properly provide their services

WHAT ARE THE DIFFERENT TYPES OF COOKIES AND HOW DO WE USE THEM?

Essential: These are cookies which are essential for the running of our Site. Without these cookies, parts of our Site would not function. These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.

Examples of how we may use essential Cookies include:

Setting unique identifiers for each unique visitor, so that user numbers can be analyzed.
Functional: These cookies are used to remember your preferences, login information and store shopping cart items on our Site and to provide enhanced, more personal features. The information collected by these cookies is usually anonymized, so we cannot identify you personally. Functional cookies do not track your internet usage or gather information which could be used for selling advertising.

Examples of how we may use functional Cookies include:

Gathering data about visits to our Site, including numbers of visitors and visits, length of time spent on the Site, or where visitors have come from.
Eliminating the need for returning users to re-enter their login details.
Third Party Cookies: You may notice on some pages of our Site that cookies have been set that are not related to us. When you visit a page with content embedded from these third-party service providers, they may set their own cookies on your computer or mobile device. We do not control the use of these third-party cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. Please check the third-party websites or mobile applications for more information about these cookies.
Advertising: Behavioral advertising cookies, which may be placed on your device by us or our trusted third-party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. This is often called online behavioral advertising and is done by grouping together shared interests based upon web browsing history. Your web browsing history can be used to infer things about you (e.g. your age, gender etc.), and this information may also be used to make advertising on websites more relevant to you. Although behavioral advertising cookies can track your activity around the internet, these cookies cannot identify you personally.

Examples of how we may use advertising cookies include:

Manage advertising. Our approved advertising partners use cookies together with web beacons to provide advertising to you and to enable us to manage our relationship with those advertisers by, for example, tracking how many unique users have seen a particular advertisement or followed a link in an advertisement.
To market to specific users across our Site and third-party sites, so that we and third parties can target advertising to users that will be more relevant to users’ interests.
Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to refuse, disable, or delete cookies, some of the functionality of our Site may no longer be available to you. Without this information, we are not able to provide you with all the requested services, and any differences in services are related to your information.
Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
Clear GIFs, pixel tags and other technologies: Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer and phone hard drives, clear GIFs are embedded invisibly on web pages. We currently do not use any pixels or clear GIFs on our Services.

Log Data: Like all websites and mobile applications, this Services also makes use of log files that store automatic information collected during user visits. The different types of log data could be as follows:

internet protocol (IP) address;
type of browser and device parameters used to connect to the Services;
name of the Internet Service Provider (ISP);
date and time of visit;
web page of origin of the user (referral) and exit;
possibly the number of clicks.

The aforementioned information is processed in an automated form and collected in an exclusively aggregated manner in order to verify the correct functioning of the Services, and for security reasons. This information will be processed according to the legitimate interests of the Data Controller.

For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, in accordance with applicable laws, in order to block attempts at damage to the Services or damage to other users, or in the case of harmful activities or crime. Such data are never used for the identification or profiling of the user, but only for the protection of the Services and our users. Such information will be treated according to the legitimate interests of the Data Controller.

THIRD PARTIES:

We may utilize third-party service providers ("Third-Party Service Providers"), from time to time or all the time, to help us with our Services, and to help serve you.

We may use Third-Party Service Providers to assist with information storage (such as cloud storage).

We use Third-Party Service Providers to process payment through the Services. In this instance, the Third-Party Service Provider will have access to your Personal Data.

We may provide some of your Personal Data to Third-Party Service Providers in order to help us track usage data, such as referral websites, dates and times of page requests, etc. We use this information to understand patterns of usage of, and to improve, the Services. Such Third-party Service Providers may include Google Analytics, Facebook Pixels, and Firebase.

When you click on links through our Services or visit affiliate websites or mobile applications, they may direct you away from our Services. We are not responsible for the privacy practices of other websites, virtual servers or mobile applications and encourage you to read their individual privacy policies. If you visit a third-party website, virtual server or application link from our Services, you do so at your own risk.

We may use Third-Party Service Providers to host the Services. In this instance, the Third-Party Service Provider will have access to your Personal Data.

We may allow third parties to advertise on the Services. These third parties may use cookies in connection with their advertisements (see the "Cookies" clause in this Privacy Policy).

We only share your Personal Data with a Third-Party Service Provider if that provider agrees to our privacy standards as set out in this Privacy Policy.

Your Personal Data will not be sold or otherwise transferred to other third parties without your consent.

Notwithstanding the other provisions of this Privacy Policy, we may provide your Personal Data to a third party or to third parties in order to protect the rights, property or safety, of us, our users or third parties, or as otherwise required by law.

We will not knowingly share your Personal Data with any third parties other than in accordance with this Privacy Policy.

If your Personal Data might be provided to a third party in a manner that is other than as explained in this Privacy Policy, you will be notified. You will also have the opportunity to request that we not share that information.

In general, you may request that we do not share your Personal Data with third parties. Please contact us via email, if so. Please be advised that you may lose access to certain services that we rely on third-party providers for.

HOW PERSONAL DATA IS STORED:

To protect your personal identifiable information, we take reasonable precautions and follow industry standard SSL/TLS end-to-end encryption of data in transit and limit internal access to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. If you provide us with any Personal Data, the information is encrypted using industry standard protections in our database. No payment information is ever stored in our database, as it is solely processed through Third Party Service Providers and is only temporarily stored during the processing of payment.

Although we have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Personal Data is stored throughout your relationship with us. We delete your Personal Data upon request for cancellation of your Account or other general request for the deletion of data. However, we are not able to remove certain Personal Data in which we require for legitimate business purposes.

In the event of a breach of your Personal Data, you will be notified in a reasonable time frame, but in no event later than two weeks, and we will follow all applicable laws regarding such breach.

INFORMATION YOU GENERATE PLAYING THE APP AND USING OUR COMMUNICATIONS FEATURES

When you play our App, you generate certain information, such as information about game sessions (including timing, number and length), progress in the game (e.g, level and achievements), items collected or purchased, collaborations, and other choices you make in the game (like the way you interact with certain features or pop-ups).

You also may be able to take part in certain activities on our Service that let you communicate or share information with Keoch and/or other players. These include:

uploading photos, videos and/or drawings;
communicating with customer support agents and/or account managers.

You may choose to disclose information about yourself in the course of contributing User Content to the Service (as described in our Terms of use).

Additionally, you should be aware that any Personal Data you submit, including videos and images, can be accessed, read, watched, collected, or otherwise used by Keoch and by other players of these forums. Keoch is not responsible for the Personal Data you choose to make public in any of these forums.

We may use any information you share for any purpose as described in this Privacy Policy.

Note that you should consider any information you post or otherwise share with other players through a Service or a third-party site or service as “public” and you should have no expectation that it be kept private.

PURPOSES OF PROCESSING OF PERSONAL DATA:

We primarily use your Personal Data to help us provide a better experience for you on our Services and to provide you the services and/or information you may have requested, such as use of our Services.

Information that does not identify you personally, but that may assist in providing us broad overviews of our customer base, will be used for market research or marketing efforts. Such information may include, but is not limited to, interests based on your cookies.

Personal Data that may be considering identifying may be used for the following:

Improving your personal user experience
create game accounts and allow gameplay;
operate, improve, and optimize our Service and our players’ experiences, including by measuring interest in and engagement with our Service;
facilitate in-game purchases;
personalize our Service, including to identify and suggest connections with other Keoch players, and convert connections from your social media into in-game connections;
enable players to communicate with each other;
provide technical support and respond to player inquiries;
authenticate and/or verify individual identities;
protect the safety and well-being of our players;
protect Keoch’s rights and property in connection with our Service;
address technical issues and maintain and/or enhance network and information security;
conduct audits, ensure internal quality control, and take safety precautions;
prevent, investigate, and/or prosecute fraud or potentially illegal activities and enforce our Terms of Use;
manage and deliver contextual and behavioral advertising
notify players of in-game updates, new products, content or promotional offers;
administer and deliver rewards, surveys, sweepstakes, contests, gifts, and/or other promotional activities or events sponsored or managed by us or our business partners;
comply with our legal obligations, resolve any disputes we may have with you or other players, collect any money owed us, and enforce our agreements;
conduct research, including by using personal data to create de-identified and/or aggregated data. De-identified and aggregated data are not personal data and we may use and share such data for any legally permissible purposes.

Your interactions with our Service may be tracked across platforms and/or devices.

We may use technologies that (a) may be considered automated decision-making or profiling, and/or (b) include artificial intelligence to evaluate personal data that we collect (including, for example, in-game activity and communications within our Service) to improve our Service (for example, to prioritize customer support inquiries to shorten response times, personalize the game experience, and to understand trends in response to certain features in our Service) and for other legitimate business purposes. We will not use these technologies in a way that has a legally significant impact on you, unless we have your consent or we are otherwise legally permitted to do so.

We may use personal data for any other purposes communicated to you at the point of collection, or otherwise with your consent.

DISCLOSURE OF PERSONAL DATA:

Although our policy is to maintain the privacy of your Personal Data as described herein, we may disclose your Personal Data if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such cases may include, but are not limited to:

To satisfy any local, state, or Federal laws or regulations
To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies
If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
To bring legal action against a user who has violated the law or violated the terms of use of our Services
As may be necessary for the operation of our Services
To generally cooperate with any lawful investigation about our users
If we suspect any fraudulent activity on our Services or if we have noticed any activity which may violate our terms or other applicable rule

Additionally, we may disclose or publish aggregated and analytical information and other non-personal data about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.

Advertising, Including Third-Party and Tailored Advertising

We may have advertising on our Service. When advertisers or ad networks place ads in our Service, they may collect or we may share the following types of information from within our Service:

performance data (like the number of clicks on an advertisement);
aggregated and/or de-identified information about players that is not intended to specifically identify any individual player;
certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs, and device identifiers); and
your in-game activity.

The information collected may be used to:

measure how effective certain ads are;
personalize the player experience by showing advertisements for products and services that may be more likely to appeal to you;
undertake web analytics (like Google Analytics) to analyze traffic and other player activity.

Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time.

Please note, after clicking on a third-party advertisement, you may no longer be on the App, Site or any other Service operated by Keoch.

CAN-SPAM ACT:

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to:

Send information, respond to inquiries, and/or other requests or questions.
We may also send you additional information related to your Account, your purchases and our Services.
Market to our mailing list, if you provide us with such consent.

To be in accordance with CAN-SPAM we agree to the following:

NOT use false, or misleading subjects or email addresses
Identify the message as an advertisement in some reasonable way
Include the physical address of our business or site headquarters
Monitor third party email marketing services for compliance, if one is used.
Honor opt-out/unsubscribe requests quickly
Allow users to unsubscribe by using the link at the bottom of each email

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your Account or any other transactional or service-oriented request.

YOUR RIGHTS:

You have many rights in relation to your Personal Data. Specifically, your rights are as follows:

the right to be informed about the processing of your Personal Data
the right to have access to your Personal Data
the right to update and/or correct your Personal Data
the right to portability of your Personal Data
the right to oppose or limit the processing of your Personal Data
the right to request that we stop processing and delete your Personal Data
the right to block any Personal Data processing in violation of any applicable law
the right to launch a complaint with the Federal Trade Commission (FTC) in the United States or applicable data protection authority in another jurisdiction

Such rights can all be exercised by contacting us at the relevant contact information listed in this Privacy Policy.

If you wish to modify or delete any information we may have about you, or you wish to simply access any information we have about you, you may do so from your Account settings page.

We may take steps to verify your identity before we can respond to your request. To the extent these rights apply to you, they may be limited in some situations -- for example when we are under a legal requirement or have a compelling interest for processing your Personal Data, or when the Personal Data is protected by trade secret. If you have unresolved concerns, where applicable, you may also have the right to complain to a privacy authority. A list of privacy authorities is available here. Alternatively, if you wish to make a data request or appeal a data request decision, please contact Keoch using the details provided in the Contact Us section. To opt out, please click on the Do Not Sell or Share My Personal Data on our site footer (and available here) and follow the instructions on that page. To opt out of online personalized advertising more broadly, please see the opt-out options identified in the Manage Your Account, Communications, and Data section. We will not discriminate against you for exercising any of these rights.

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you've authorized them to act on your behalf, or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent's identity.

Opting Out of Push Notifications

When you install our App on your mobile device, you can choose to receive push notifications, which are messages a mobile application sends you on your device even when the mobile application is not on. You can turn off notifications by visiting your mobile device’s “Settings”.

Additionally, in some of our game apps, you may find an option under “Settings” to turn off push notifications.

Opting Out of Third-Party Tailored Advertising

In our App, we provide a toggle button to disable tailored advertising.

For more information about tailored advertising and your choices to prevent third parties from delivering tailored web and mobile web advertising you can visit www.aboutads.info. To opt out, for businesses that participate in the Digital Advertising Alliance, you can exercise that option at www.networkadvertising.org/choices and www.aboutads.info/choices.

If you live in the EU, you can get information and exercise your choices at www.youronlinechoices.com.

These opt-out tools are provided by third parties, not Keoch. Keoch does not control, operate, or endorse these tools or the choices that advertisers and others provide through these tools. They are listed here only as a convenience for our users and players.

In addition, if you do not want to receive third-party tailored ads, you may opt-out by adjusting the ad tracking settings on your mobile device. You can also reset the advertising identifier (like an IDFA) from your mobile device’s Settings, which will prevent continued use of existing behavioral data tied to the previous advertising identifier. Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties. Keoch does not control, operate or endorse these tools or the choices that advertisers and others provide through these tools.

Please note that you may still receive advertisements from Keoch and third parties within the App even if you opt out of tailored advertising; these ads will not be tailored to you.

INTERNATIONAL DATA TRANSFER FOR RESIDENTS OF THE EUROPEAN UNION, SWITZERLAND OR THE UNITED KINGDOM:

WE CAN UPDATE THIS ONCE THE GDPR POLICIES ARE FINALIZED

EU data protection law through GDPR or the UK GDPR and UK Data Protection Act makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.

Legal Grounds for Processing your Personal Data

The GDPR requires us to tell you about the legal ground we're relying upon to process any Personal Data about you. The legal basis for us processing your Personal Data for the purposes set out in this Privacy Policy will typically be because:

you provided your consent;
it is necessary for our contractual relationship;
the processing is necessary for us to comply with our legal or regulatory obligations; and/or
the processing is in our legitimate interest as an event organizing and content providing platform (for example, to protect the security and integrity of our systems and to provide you with customer service, etc.).

Keoch as a Data Controller

EU data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process Personal Data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.

Keoch will act as a data controller concerning Personal Data. For example, if you create an account with us, make a purchase or access the message boards or forums, Keoch will be a data controller for the Personal Data you provide as part of your account.

We will also be a data controller of the Personal Data we may obtain through the use of the Services or our Services. We use this to conduct research and analysis to help better understand and serve users of the Services as well as to improve our Services.

Transfers of Personal Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note we transfer the data, including Personal Data, to the United States and process it here. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. When we transfer your information to the U.S., we will protect it as described in this Privacy Policy. By visiting the Site, using our Services or providing Keoch with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States.

We retain your Personal Data for as long as necessary to provide you with our Services or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. Keoch may retain non-Personal Data for as long as necessary for the purposes and uses described in this Privacy Policy, including as necessary for Keoch to pursue legitimate and lawful business interests.

Data Access and Data Deletion

Data protection law provides you with rights regarding Personal Data that we hold about you, including the right to request a copy of the Personal Data, request that we rectify, restrict or delete your Personal Data, and unsubscribe from marketing communications.

There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation. If you have a complaint about how we handle your Personal Data, please get in touch with us as at TQG@thatquestionsgame.com to receive further clarification. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App, Site or the Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features in an effort to prevent loss, theft and unauthorized access, use and disclosure.

CALIFORNIA RESIDENTS: CALIFORNIA CONSUMER PROTECTION ACT (“CCPA”)

The California Consumer Privacy Act (CCPA) provides consumers who are residents of the State of California with specific rights related to their Personal Data (which includes Personally Identifiable Information), subject to certain exceptions. It also requires us to disclose the information we collect, the purposes for which we collect it, and what we share and disclose.

Categories of Information Collected

This section describes the types of Personal Data that Keoch collects, uses, discloses, and may sell (as described more fully below). We discuss the business and commercial purposes for collecting this information in the Disclosure of Personal Data section above. We categorize this Personal Data as follows:

Identifiers/Contact Information: Identifiers, including your real name, postal and email address, phone number, unique identifiers, location information, characteristics of protected classifications under California or federal law, and IP address.
Commercial Information: Your purchase and usage history and preferences.
Internet/Electronic Activity: Your web/app browsing and gameplay information related to the Services and information related to your online interaction(s) with the Services or our advertising.
Profile Inferences: The inferences that we draw from your information and web activity to help create a personalized profile so we can better identify goods and services that may be of interest.

Categories of Information Sold

In the last 12 months, as defined by California law, Keoch has sold unique identifiers, IP address, as well as Internet/Electronic Activity and Profile Inferences to enable us to provide personalized advertising to you and others like you. We do not sell Personal Data about persons that we know are under the age of ___ without their (or depending on age, their parent’s) consent.

Categories of Information Disclosed

In the last 12 months, Keoch has disclosed each of the categories of Personal Data described above (e.g., Identifier/Contact Information, Commercial Information, Internet/Electronic Activity, and Profile Inferences) for a business or commercial purpose.

Your Rights

To make an access or deletion request, please email us at TQG@thatquestionsgame.com. We may take steps to verify your identity before we can respond to your request.

Access Request. You may make up to two requests per year for information as to:

The categories of Personal Data that we’ve collected and sold about you, or shared for a business or commercial purpose with our service providers;
The sources from which we’ve collected such Personal Data;
The third parties with whom we’ve shared that Personal Data and to whom we’ve sold that information;
The business or commercial purpose for collecting or selling that Personal Data; and
The specific pieces of Personal Data we’ve collected about you.

Deletion Request. You may request that we delete the Personal Data that we’ve collected from or about you, although there are some reasons we will need to retain information, such as to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to maintain for internal purposes, to comply with a legal obligation, or to exercise our rights.

We will respond to your access and deletion requests within 45 days, unless we require additional time, in which case we will let you know.

Opt-Out Request. You have the right to opt out of Keoch’s sale of your Personal Data to third parties for their commercial purposes. This means that if you opt out, going forward, we will not share your Personal Data with such third parties to use for such purposes unless you later direct us to do so.

To opt out, please email us using the title Do Not Sell My Info or Opt Out of Online Personalized Advertising.