PRIVACY POLICY

Version 240812

Welcome to Big Heart Trivia's Privacy Policy.

We respect your privacy and are committed to protecting it. This policy explains how we handle your Personal Information ("PI") in our Big Heart Trivia Game and website (collectively the "Game").

Any information you voluntarily enter into our Game is yours. We don't own any of it, nor are we responsible for its accuracy or appropriateness... because it's your information. However, by playing our Game, you consent to Big Heart Trivia, p.b.c.'s ("BHT", "we", "us", "our"), our Non-Profit Partners' ("NPPs"), our Referral Partners' ("RPs"), and our 3rd Party Partners' ("3PPs") handling of your PI as described in this Privacy Policy. And, by playing our Game, you also consent to the use of your information for the purposes stated in our Terms And Conditions ("T&C") and Game Rules.

You must be at least of legal age to play our Game, or if it's legally permissible in your state, you must have your parents or legal guardian’s consent and agreement to this Privacy Policy to play.

Note, BHT is a Public Benefits Corporation and does not sell your Personal Information, so it does not exceed any of the thresholds for application of the California Consumer Privacy Act (CCPA). In addition, the Game is only available for U.S. residents, so the EU General Data Protection Regulation ("GDPR") is not applicable.

If you have any questions, feel free to contact us at Legal@BigHeartTrivia.org.


Here's The Information We Collect:

* Information you provide when you sign up for a Game account or communicate with BHT.

* Information we collect during the normal operation of our Game, such as Game performance and metrics, location, IP address, electronic device info, and customer service data.

* In the case of in-game currency purchase, we may collect billing and financial information necessary to process a donation (purchase).

* In the case of a winning cash payout, we may collect necessary identity verification, including full name, email, address, financial, and tax identification information, and we share this information with our payment processing partner Dwolla, Inc. Dwolla’s Privacy Policy is available here. We may also collect other information such as an optional publicity photo.

* BHT does not store credit card or banking information but instead uses a variety of 3rd party services, including payment processing services, hosting, and report generation. These 3rd party services may collect information as part of servicing our Game and may additionally have their own policies as well.

We Are Not Collecting Photos: There is a component in the Game where – with your permission – we reach into your photo album and create a personalized trivia game just for you. Please know your photos are not uploaded, downloaded, indexed, or saved in any way. We simply just grab a few to temporarily display. And, only you can see these photos. To further illustrate, if there is a customer support problem with a Photo Trivia Question, we will not be able to diagnose or rectify because even our customer support systems can't see the photo in question. You can turn on or off the Photo Trivia feature at any time.


Here's How We Use The Information We Collect:

You agree that BHT, our NPPs, our RPs, our 3PPs, and anyone or any entity associated with BHT, may use the collected information for the purposes of:

* Providing, operating, personalizing, publicizing, servicing, fundraising, improving, and protecting our players, our Game, and our business.


Notes:

– Some of the information we collect will be visible to the other players in our Game, for example, a chosen nickname or profile picture.

– You can review and update your provided information in the Game's Profile settings. For security reasons, certain information, such as name, phone, and email, can only be updated before you start playing the daily Contest.

– We will comply with applicable laws and law enforcement.

– Our Game is intended for a general audience and not directed to children. If you believe we have collected a child's personal information, or that your child has misidentified their age, please contact us at Legal@BigHeartTrivia.org.

– We go to great lengths, including implementing enterprise-class security and strictly utilizing a unique Invite Only sign-up code, to protect your information from security threats and cross-contamination. We will only share registration information with your permission, but note that because the primary way you hear about the Game is via an Invite Code sent or shared directly from an NPP or RP, that means the NPP or RP may already have your information.

– If you want to delete Big Heart Trivia, simply delete your account. Please know, though, that we may be obliged to retain certain information, for example, for security and IRS purposes. In particular, the California Consumer Privacy Act (CCPA) has carved out exceptions that give companies the latitude to do this if necessary. Please see the CCPA for details.

– The rights you are consenting to are transferrable in the case that BHT is merged, acquired, or sold.


Here's How Our Survey Partners Use Information Collected:

As a fundraising game, BHT does not engage traditional online advertising. Therefore, we do not collect or sell information normally associated with presenting relevant display or video ads.

However, as a fundraising game, we may engage other forms of digital advertising, which is how those players who do not want to make a direct donation may contribute (i.e., those that play for free).

In particular, we may work with leading market research networks. Since market research surveys involve asking questions, we believe this is a consistent user experience with a trivia game that also asks questions.

Note, our market research survey partners each have their own privacy policies and you are required to read, and if appropriate, consent to these as well. While your identity will be anonymous, they may initially ask you generic information about your demographic, i.e., when you were born, level of education, working status, zip code, and so on. They may ask you this information in order to match you with appropriate and relevant market research surveys. Please know the better the match, the more funds that are raised for the Daily Prize and non-profit. Said another way, if a dog food company wants to ask dog owners in California a question, then knowing someone is a dog owner living in California is more valuable to them than someone that's not.

However, know that we will not work with a market research survey partner that collects any Personally Identifying Information (PII). That is, your name, an address, a telephone number, or any other piece of information that removes your anonymity. If you come across a survey that asks for PII, please contact Big Heart Trivia immediately at Legal@BigHeartTrivia.org. It is always your choice to opt-out of any digital advertising we may do.


Security Of Information:

BHT takes appropriate technical and organizational measures to safeguard your information.

However, when it comes to digital information, including digital information flowing over the Internet or other networks that we may or may not control, no one can guarantee 100% security, including BHT. By consenting to this Privacy Policy, you understand this limitation.

Further, you may find links to 3rd party content outside of the control of our Game, and by consenting to this Privacy Policy, you also understand that any information you provide to such outside content is subject to that 3rd Party's privacy and security policies. As such, we take no responsibility for your information for activities outside of the control of our Game.


A Note About the California Consumer Privacy Act ("CCPA"):

BHT is a Public Benefits Corporation and does not sell your Personal Information, so it does not exceed any of the thresholds for application of the California Consumer Privacy Act (CCPA).

Further, our situation is a bit different than most apps. A player is voluntarily signing up for the Game via a unique game invitation code sent to them directly by our NPPs and RPs. So our NPPs and RPs may already have personal information about the California resident in question, and any player can exercise their CCPA Right to Opt-Out by following the NPPs or RPs privacy instructions.

Even though our NPPs and RPs may already have your personal information, as an extra layer of safety, we also ask you to specifically Opt-In during the sign-up process if you would like to share your registration information with your NPP or RP (i.e., affirmative consent).  Note that you may change this setting at any time on your Profile screen within the Game.

By the way, all players have other ways in which they can control their personal information as well, for example, limiting ad tracking altogether using the settings in your mobile device.


Governing Law And Jurisdiction:

The T&C and Privacy Policy are governed by United States federal law and the laws of the State of California, including the Federal Arbitration Act. Any disputes arising out of or relating to this T&C and Privacy Policy or your use of our Game are subject to binding arbitration and a waiver of class action rights.

Should any court of arbitration, or any other competent authority, find any of the provisions in the T&C or Privacy Policy to be void or unenforceable, it shall not affect the rest of the terms in the T&C and Privacy Policy.


Privacy Policy Changes:

BHT may at its sole discretion revise and amend this Privacy Policy from time to time. If we do this, we will inform you by posting the newly revised Privacy Policy in the Game.


If You Don't Agree With Our Privacy Policy:

It is your prerogative to not agree with some or all of our Privacy Policy, T&C, or Game Rules. In this situation, however, please immediately stop using our Game and delete your account. Because by continuing to play our Game, you agree to be bound by the entirety of our Privacy Policy, T&C, and Game Rules, including any updates.