Effective Date: [10/10/2022]

Welcome to Sqillerapp! This Privacy Policy explains how we at TEQBALL Korlátolt Felelősségű Társaság, a company registered in Hungary at the Fővárosi Törvényszék under n° 01-09-174699, having its registered address at Expo tér 5-7, Budapest 1101, Hungary (“Teqball,” “we,” “us,” or “our”) collect, use, and share your information when you visit our website and use our mobile application Squillerapp, or other applications we make available to you (collectively the “Platform”). When you are using the Platform without signing up, the data we process in connection with your use is limited to Video Data. Therefore, we do not request any additional information from you. In addition, any and all information collected by us automatically (see more below) is deleted or rendered anonymous upon your exiting the Platform.

If you live in the United Kingdom or any part of the European Economic Area, please see the “Additional Disclosures for People in Europe” section.

In case you wish to participate in one of our separate, in-App events (see the “How Do We Share Your Information?” section for the definition) that are currently running on the Platform, please refer to the “In-App Events” addendum for further terms.

Acknowledgement

Please read this Privacy Policy carefully. BY ACCESSING AND/OR USING OUR PLATFORM YOU REPRESENT THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY.

What Information Do We Collect And How Do We Use It?

Depending on how you interact with our Platform and our interactions with third parties, we may collect your information when it is voluntarily provided to us by you, automatically when you use the Platform, and in certain circumstances from third-parties.

1. Information Provided By You

We may collect your information when you use the Platform to actively send information related to your participation in different challenges offered through the Platform (including but not limited to events, battles, timed-runs, target-runs) as well as when you register you for an account, select favorites in the Platform, upload videos, request or otherwise engage with customer service and/or support, update your profile, and participate in a promotion. This information includes, but may not be limited to: 

• Contact Data, including your first and last name, email address, postal address, shipping address and phone number.
• Account Credentials, including your username, and information for authentication and account access.
• Personal Identification Data, including your passport number, ID number or a scanned copy of your ID or passport.
• Personal Characteristic Data, such as your age, gender, height, weight, skill level, country of nationality.
• Profile Data, including your interests, inferences, preferences, and favorites.
• Winnings-related Data, including your financial information, information necessary to verify your identity and shipping data.
• Participation Data, including your participation information in the In-App Events.
• Video Data, including videos of your skills, challenges, and performance.
• Content, including content within any messages you send to us (such as feedback and questions to customer support) or post via the Platform.

2. Information Collected Automatically

When you use our Platform, we collect certain information automatically in order to operate and improve the Platform, provide advertising to you and others, ensure the security and reliability of the Platform, communicate with you, and conduct internal analysis and analytics on the Platform. This information includes:

• Service Use Data, including data about features you use on the Platform, pages/tabs you visit, in-App products and services you view and purchase (if any), the time of day you browse, and your referring and existing pages/tabs.
• Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.
• Log Files, such as record events that occur in connection with your use of the Platform, including protocol status and substatus, bytes sent and received, and server information.
• Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of necessary cookies: session and persistent. Session cookies make it easier for you to navigate our Platform and expire when you close your browser. Persistent cookies help us personalize your experience, remember your preferences, and support security functions. If we collect cookies other than necessary cookies, we will do so with your consent as required under applicable law.
• Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).
• App Technologies, which are technologies included in our application that are not browser-based cookies and cannot be controlled by browser settings. For example, our Platform may use SDKs, which is code that sends information about your use to a server. These SDKs allow us to track our communications with you, bring you advertising both on and off the Platform, and provide you with additional functionality, such as the ability to connect to Information Received from third-party sources

3. Information Collected From Third Parties

In limited circumstances, we may receive certain information from third parties such as when you register or log in to the Platform using a third-party login like Google or Facebook, from social media platforms that you have linked your account to, and to better assess how our Platform is used and can be improved through the use of publicly available data.

When linking an account like through Facebook, such third-party provider may provide us information such as list of “friends” or “contacts” also using the Platform as a result of the use of such third party’s API servers. Please ensure that your settings related to sharing of data is set as you desire in any linked third-party platform such as Facebook.

How Do We Share Your Information?

• Service Providers and Vendors. We may share your information with entities that process information on our behalf for our business and commercial purposes. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support.
• Affiliates. We may share your information with our related entities (hereinafter “TEQBALL Group”[1]) for business purposes such as customer support, marketing, product development, technical operations, information sharing, and other related business purposes. We also may share information with affiliates for commercial purposes.
• Partners. We may share your information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities. For example, we may share information with our retailer partners for purposes of providing you with product support.
• In-App Event Organizers. From time to time, we may collaborate with our Affiliates to bring you separate in-App events (including but not limited to tournaments, cups, etc.) run by one or more of our Affiliates (“In-App Event Organizer”). In compliance with our general terms and conditions and this privacy policy, such in-App events are governed by the separate competition and privacy terms of the relevant In-App Event Organizer insofar it is different from this Privacy Policy. In such cases, we merely provide the technical facilities (i.e. the Platform) and other administrative, technical assistance to these organizers. Doing so, we may share your information with the In-App Event Organizers, among others, to enable your participation in the in-App events, to verify your SQILLER account, your performance utilizing the Platform and your identity, to determine your session’s result and to prevent fraudulent activity.
• Promotions. When you voluntarily enter a sweepstakes, contest, or other promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list).
• Public Forums. We share your information you make public through the Platform, such as specified information in your profile or that you post on public boards.
• Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition, business combination of all or any portion of our business or assets, change of control, or a transfer of all or a portion of our business or assets to another third party (including in the case of any bankruptcy proceeding).
• Security and Compelled Disclosure. We share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share information to protect the rights, property, life, health, security and safety of us, the Platform or anyone else.
• Facilitating Requests. We may share your information at your request or direction, such as when you choose to share information with a social network about your activities on the Platform.
• Consent. We may share your information with your consent. 

Social Media and Technology Integrations

We integrate technologies operated or controlled by separate entities into parts of our Platform. Some examples include:

• Liking, Sharing, and Logging-In. We may embed a pixel or SDK on our Platform that allows you to log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.

Please note that when you interact with other entities, including when you leave our Platform, those entities may independently collect information about you and solicit information from you. The information collected and stored by those entities remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Analytics and Advertising

We use analytics services, such as Google Analytics, to help us understand how users access and use the Platform. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services. For more information about how to opt-out of Google Analytics, please see the section entitled “Your Rights and Choices: 3. Analytic and Interest-Based Advertising” below.

Your Rights and Choices.

1. Account Information.

You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings or sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

2. Tracking Technology Choices.

• Cookies and Pixels. Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
• Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
• App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.

Please be aware that if you disable or remove tracking technologies some parts of the Platform may not function correctly.

3. Analytics and Interest-Based Advertising.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

4. Communications.

• E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or Teqball’s ongoing business relations.
• Push Notifications. If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our App.

Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions. 

How Do We Secure Your Information?

Although no system can guarantee the complete security of your information, we take commercially reasonable steps to ensure your information is protected in alignment with all applicable laws and regulations, as appropriate to the sensitivity of your information. 

How Long Do We Keep Your Information?

We keep your information for as long as necessary in accordance with the purpose for which it was collected, our business needs, and our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is secure and appropriate to nature of the information subject to disposal.

Third Party Tracking / Do Not Track

We may, from time to time, collect information about your online activities, over time and across different websites. When you use our Platform, third parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Platform does not currently change the way they operate based upon detection of a “Do Not Track” or similar signal. For details, including how to turn on Do Not Track, visit www.donottrack.us.

Changes to this Privacy Policy

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address. 

Contact Us

For queries relating to your data or this Privacy Policy, please contact our data protection officer (DPO): privacy@teqball.com  - KCG Partners Ügyvédi Társulás

Additional Disclosures for Data Subjects in Europe.

1. Roles

The data controller for your personal data is, unless otherwise specified:

TEQBALL Korlátolt Felelősségű Társaság, a company registered in Hungary at the Fővárosi Törvényszék under n° 01-09-174699, having its registered address at Expo tér 5-7, Budapest 1101, Hungary.

2. Lawful Basis for Processing.

Our lawful bases for processing your personal data may include to:   

• Perform a contract with you to (Article 6 1 (b) of GDPR):

• • Provide our Platform to you;
  • Sign you up to our Platform;
  • Notify you about changes to our Platform;
  • Enforce our terms, conditions, and policies (including the provision of winnings);
  • Personalize content you receive and provide you with tailored content; and
  • Communicate with you.

• Further our legitimate interests to (Article 6 1 (f) of GDPR):

• • Perform data analytics (including market research, trend analysis, financial analysis);
  • Operate, evaluate, develop, manage and improve our Platform (including but not limited to operating, administering, analyzing, and improving our Platform, image analysis and cheat prevention, delivering results on Platform use, enhancing our algorithms and related technologies, analyzing the available data linked to through our Platform, managing and evaluating the effectiveness of our communications and Platform, and, performing accounting, auditing, and billing reconciliation and collection activities);
  • Protect against, identify and prevent fraud and/or other criminal activity, claims and other liabilities; and
  • Comply with and enforce relevant industry standards and policies, including this Privacy Policy and other related terms of use.

• Comply with a legal obligation (Article 6 1 (c) of GDPR), act in the public interest (Article 6 1 (e) of GDPR) by:
  • Preventing and responding to abuse and fraud;
  • Preventing and responding to illegal activity;
  • Preventing and responding to other harmful content distributed through our Platform;
  • Prevent the unlawful use and/or selling of our Platform; and
  • Enforcing our terms, conditions, and policies.
• Proceed with your consent (Article 6 1 (a) of GDPR):
  • For us to maintain your contact information with a readable account name;
  • For us to use your name and email for marketing purposes by us and the members of the TEQBALL Group;
  • For us to use your specific information to play challenges provided on the Platform with your friends and other users from third-party sources like Facebook;

3. Data processors

To process your data, we use specialized service providers to a certain extent. We carefully select these Service Providers and Vendors and check them regularly. These Service Providers and Vendors process personal data only on our instructions and strictly according to our guidelines, in accordance with the relevant data processing contracts. Our Service Providers and Vendors include:

• Firebase, Inc. (1600 Amphitheatre Pkwy Mountain View, CA, 94043-1351) and PlayFab Inc. (101 Yesler Way # 501, Seattle, Washington 98104, US) – storage and analysis of the video files;
• Microsoft Corporation (98052 One Microsoft Way, Redmond, WA, USA): Microsoft Azure and Microsoft Outlook – cloud environment, hosting, email system.

4. Your Rights under the GDPR

You have the following rights in relation to your personal data:

• Right to be informed: You have the right to be informed about the collection and use of your personal data in a clear and transparent way. Please review the information provided in the section entitled What Information Do We Collect And How Do We Use It?
• Right to access: You have the right to request access to your personal data and obtain information regarding the purpose of processing, what categories of personal data are processed, data processors, length of processing, your rights relating to our processing, your right to lodge a complaint with a supervisory authority regarding our processing, information on third-party sources of your personal data communicated to us, and the existence of automated decision-making and related information, including the logic involved, as well as the significance and the envisaged consequences of such processing for you, whether your personal data is transferred outside the EEA, and the conditions of these transfers.
• Right to rectification: You have the right to request rectification or completion of your personal data.
• Right to erasure: You have the right to request erasure of your personal data without delay if:
• your personal data is no longer necessary for the purpose under which it was collected;
• you withdraw your consent and there is no other legal basis for processing;
• you object to the processing and there are no overriding legitimate grounds for the processing;
• your personal data has been processed unlawfully;
• your personal data has to be erased according to relevant laws.

Please note that we are entitled to not erase your personal data if it is necessary for legal or regulatory purposes.

• Right to restrict processing: You have the right to restrict processing of your personal data if:
• you have contested the accuracy of your personal data, for a period enabling us to verify the accuracy of your personal data;
• the processing is unlawful and you oppose the erasure of your personal data and request the restriction of its use instead;
• they are required by you for the establishment, exercise or defense of legal claims.

Where processing has been restricted, such personal data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defense of legal claims, for the protection of the rights of another natural or legal person, or for reasons of public interest as such is defined in the EU.

• Right to object to processing: Where personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

You also have the right to object to the processing of personal data where the legal basis of processing activity is our legitimate interest, or the legitimate interest of a third party.

• Right to data portability: You have the right to receive the personal data in our possession or control in a structured, commonly used and machine-readable format, and have the right to transmit that data to another data controller without hindrance from us. You also have the right to have your personal data transmitted directly from us to another data controller where technically feasible.
• Right to withdraw your consent: You have the right to withdraw any consent you have given at any time, without affecting the lawfulness of processing based on your consent given previously.
• Rights related to automated decision-making including profiling: The video of your gameplay shall be assessed by our algorithms to:
  1. assess the matches (i.e. determine who won and who lost),
  2. provide you your score and

• to improve the game.

The algorithms will compare your movements against the required curvatures and formations of movements. These assessments are fully automated.

• Right to lodge a complaint with a supervisory authority: You have the right to lodge a complaint with the (governmental) authority supervising data protection in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us. In addition to the contact information above, please contact our:

Data Protection Officer

privacy@teqball.com  - KCG Partners Ügyvédi Társulás

5. International Data Transfers

If your data is collected in Europe, we will transfer your personal data subject to appropriate safeguards, such as Standard Contractual Clauses, or through appropriate derogations such as through your consent.

Addendum No. 1. – In-App Events

As noted under the “How Do We Share Your Information?” section, from time to time, we may collaborate with our Affiliates to bring you separate In-App events (including but not limited to tournaments, cups, etc.) run by one or more of our Affiliates (“In-App Event Organizer”). To assist these organizers, we make available their event-specific terms, including their privacy notices applicable to each In-App Event here, in this addendum. Therefore, this addendum is subject to recurrent updates.

A/1. SQILLER CUP I.; Organizer: TEQBALL INTERNATIONAL LIMITED (registered seat: 1st Floor, 16/17 College Green, Dublin, D02 V078, Ireland, registration no.: 556927); 31/03/2022 – 07/04/2022 ;

A/2. POLISH CUP I.; Organizer: TEQBALL INTERNATIONAL LIMITED (registered seat: 1st Floor, 16/17 College Green, Dublin, D02 V078, Ireland, registration no.: 556927); 16/05/2022 - 23/05/2022;

A/3. USA CUP I.; Organizer: Teqball USA Limited Liability Company (United States of America) [registered seat: 10811 Washington Blvd, Culver City, CA 90232, California, USA; registered at the California Secretary of State under n° 201616710107]; 19/07/2022 – 26/07/2022;

[1] TEQBALL Group refers to the following legal entities for the purposes of this Privacy Notice: Teqball Holding S.à r.l. (Luxembourg) [registered seat: 44 Avenue John F. Kennedy, L-1855 Luxembourg, LU; registered with RCS Luxembourg under n° B191050]; TEQBALL Kft. (Hungary) [registered seat: Expo tér 5-7., H-1101 Budapest, Hungary; registered with the Budapest-Capital Regional Court under n° 01-09-174699]; Teqball USA Limited Liability Company (United States of America) [registered seat: 10811 Washington Blvd, Culver City, CA 90232, California, USA;  registered at the California Secretary of State under n° 201616710107]; Teqball International Ltd. (Ireland) [registered seat: 16/17 College Green D02 V078 Dublin 2, Ireland; registry n° 556927]; Teqball Ltd. (UK) [registered seat: 5th Floor 167 - 169 Great Portland Street, London, England, W1W 5PF; registry n° 08503971]; International Teqball Federation (“FITEQ”) (Hungary) [registered seat: Expo tér 5-7., H-1101 Budapest, Hungary; registry n° 01-02-0017651] and TEQBALL Global Management S.à r.l. (Luxembourg).