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Privacy Policy

Effective: 7/1/2023 | Last Reviewed: 7/1/2023

Welcome to the Funzpoints Privacy Policy. Woopla Inc. operates the funzpoints website. This Policy details information regarding our website located at funzpoints.com and other features, tools or other services offered by Woopla Inc. (“Service”). For purposes of this Policy, the terms “Woopla,” “we,” “us,” and “our” refer to Woopla Inc. and all of its parent, subsidiaries and affiliates. We provide this Privacy Policy to help you make an informed decision about whether to use or continue using the Service. For the purposes of this Privacy Policy, the terms “you” and “your” refer to you, a user of our Service.

By using our Service, you represent that you understand and agree to this Privacy Policy, and consent to the collection and use of personal information as described in this policy. If you do not consent to our practices, can choose not to use the Service.

This Policy describes:

  • Personal Information We Collect
  • How We Collect Your Personal Information
  • How We Use Personal Information
  • Disclosure of Personal Information
  • California Privacy Rights
  • Changes to the Policy
  • Questions About the Policy

PERSONAL INFORMATION WE COLLECT

“Personal Information,” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or a household. It does not include anonymous or aggregated data that cannot be associated with an individual or household.

Personal information that we collect may depend on how you use the Service. We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:

  • Identifiers such as name, address, phone number, email, username or similar unique personal identifier, password, driver’s license number or other government ID last four digits of social security number, and date of birth.
  • Financial Information such as bank account number, routing number, credit or debit card number, and payment details.
  • Commercial Information such as details about payments to and from you, other details of products and services you have purchased from us, or payment history.
  • Characteristics of protected classifications under California or federal law, such as age to verify that you are at least 18 years of age.
  • Geolocation Data
  • Audio, Electronic, and Visual Information such as photographs.
  • Internet and Other Electronic Network Activity Information includes internet protocol (IP) address, device ID, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Service.
  • Usage Data includes information about how you use our Service.
  • Marketing and Communications Information such as marketing campaign data, click throughs, your preferences and consent in receiving marketing from us and our third parties, email and text communications, and your communication preferences.
  • Inference Data including inferences drawn from the Personal Information identified above.

Sensitive Personal Information

We collect Personal Information that is defined as “Sensitive Personal Information” under California law, including social security number, and driver’s license number or other government ID. We do not use or disclose Sensitive Personal Information for any business purposes other than as permitted by law, including to providing good and services, verifying your information, and/or as permitted by further regulations.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Information but is not considered Personal Information as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy notice.

How Long Will You Use My Personal Information For?

We will only retain your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Information You Provide To A Third Party. The Service may include links and plug-ins to websites operated by third parties (“Third-Party Sites”). We do not control any Third-Party Sites and are not responsible for any information they may collect. The information collection practices of a Third-Party Site are governed by the privacy policy of such third parties. It is your choice to enter any Third-Party Site. We recommend that you read its privacy policy if you choose to do so.

Children’s Privacy. FUNZPOINTS IS A SWEEPSTAKES THAT IS ONLY AVAILABLE TO RESIDENTS OF THE UNITED STATES WHO ARE 18 YEARS OF AGE OR OLDER. The Service is intended for adult use only and is not directed towards children, minors, or anyone under the age of 18. If you are under the age of 13, you are not authorized to provide us with any Personal Information. To the extent that we receive Personal Information of a child under 13 from their parent or guardian, we do not sell this information.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Personal Information You Provide to Us

As a user of our Service, you will provide certain personal information to Woopla when choosing to participate in the various activities on the Service such as:

  • Playing games and participating in sweepstakes
  • Registering for an account
  • Taking advantage of promotions
  • Providing us feedback or contacting us via email
  • Verifying your identity

Information We Collect When You Use Our Service

Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include your browser type, operating system, device fingerprint, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, clickstream data, referring/exit pages, and/or a date/time stamp for your visit. We use this information to analyze trends, administer the Service, gather demographic information about our user base as a whole, and to improve our Service and for product development purposes. For example, some of the information may be collected so that when you visit the Service again, it will recognize you and the information appropriate to your interests.

Cookies. Cookies are small files that we or our service provider transfers to your computer's hard drive through your web browser that enables us or our service provider's systems to recognize your browser and capture and remember certain information. We use cookies to help us understand how users use the Service. For example, cookies gather information about how long you spend on a web page so that we can understand what web pages are of most interest to users. If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off cookies by adjusting your browser settings. For more information about cookies and about turning off cookies, please see: allaboutcookies.org. If you turn off your cookies, some of the features of the Service may not function properly.

Information We Collect From Third Parties

We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.

Third Party Service Providers. We collect Personal Information from service providers including where we operate accounts on third-party platforms, such as marketing partners, identity verification services, anti-fraud services, payment processors, and other service providers.

Google Analytics. We use third party cookies provided by Google Analytics to assist us in better understanding our website visitors. Google Analytics uses a first party cookie, identifiers for mobile devices, or similar technology to collect usage data. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences, perform analytics, analyze traffic, personalize content, and offer ads that match your interest. You can learn more about how Google Analytics collects and uses information from their website at: google.com/policies/privacy/partners/.

HOW WE USE PERSONAL INFORMATION

In general, the personal information you submit to us is used either to respond to the requests you make or to provide to operate, maintain, and provide to you the features and functionality of the Service, including but not limited to the following:

  • To provide you with our products and services and to operate our business.
  • To facilitate the creation and security of your Account on our network.
  • To identify you as a user in our system and to otherwise administer and operate our Service.
  • To process your Prize Redemption Request(s).
  • To improve the quality of your experience of our Service.
  • To send you email notifications or otherwise communicate with you.
  • To deliver customized or personalized content, information, or advertising.
  • To enforce the legal terms that govern the use of our Service.
  • To protect the integrity of our Service.
  • For the investigation of suspected unlawful, fraudulent, or other inappropriate activity connected with the use of our Service.
  • To respond to your inquiries and other requests.
  • To send newsletters, surveys, offers and other promotional materials related to our Service or on behalf of third parties and to monitor the effectiveness of our marketing programs.
  • To improve the quality and design of our Service and to create new features, promotions, functionality, and services.
  • Protect our interests, including establishing, exercising and defending legal rights and claims.
  • As necessary to comply with legal requirements such as customer identity verification and reporting obligations in accordance with anti-money laundering laws and other applicable laws relating to sweepstakes and online gaming, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities.
  • For purposes disclosed at the time you provide/we request your personal information or as otherwise set forth in this Privacy Policy.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We disclose your personal information with third parties only in the ways that are described in this Policy and with our business partners, suppliers and sub-contractors in order to provide you with our Service and perform any contract we enter into with them or you.

Third Party Service Providers

We may disclose the information we collect or receive from you with third parties such as service providers or other businesses who process your information on our behalf in order to provide or operate the Service. For instance, these entities may have access to your information for purposes including, but not limited to, facilitating the creation of accounts, providing account authentication and user verification services, billing and accounting, hosting, marketing, promotional and email services, customer and technical support, conducting quality assurance testing, facilitating the back-office support for the Service, and for the purpose of accepting deposits, processing Prize Redemption Request(s), fraud dispute and prevention, and chargeback prevention.

Internal Third Parties

We may share personal information with our parent company, subsidiaries, successors, predecessors, assigns, licensees, affiliates, or business partners, and others who may use the personal information for the purposes described above.

Categories of Personal Information that have been disclosed to service providers and internal third parties for a business purpose in the past twelve months include:

  • Identifiers
  • Financial Information
  • Commercial Information
  • Characteristics of protected classifications under California or federal law
  • Geolocation Data
  • Audio, Electronic, and Visual Information
  • Internet and Other Electronic Network Activity Information
  • Usage Data
  • Marketing and Communications Information
  • Inference Data

Business Transactions. We may do business with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Policy.

Legal Process. Subject to applicable law, we may disclose information about you: (i) if we are required to do so by law, regulation or legal process, such as a subpoena; (ii) in response to requests by government entities, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to prevent physical, financial or other harm, injury or loss; or (iv) in connection with an investigation of suspected or actual unlawful activity.

Personal Information Sold or Shared: We have not sold or shared (as those terms are defined under California law) any Personal Information in the past twelve months. Woopla has no actual knowledge of any sales or sharing of Personal Information of minors under 16 years of age.

CALIFORNIA PRIVACY RIGHTS

California Consumer Privacy Act. The California Consumer Privacy Act as amended (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know: You have a right to know what Personal Information we have collected about you in the immediately preceding 12-month period, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we have disclosed Personal Information, and the specific pieces of Personal Information we have collected. You may exercise this right no more than twice in any 12-month period.

Right to Delete: You have the right to request that we delete Personal Information that we collected from you and retained, subject to certain exceptions.

Right to Correct: You have the right to correct inaccurate personal information that we maintain about you.

Right to Opt-Out of the Sale/Sharing: You have the right to opt-out of the sale or sharing of their personal information by the business. We do not sell or share your Personal Information.

Right to Limit the Use or Disclosure of Sensitive Personal Information: You have the right to request that we limit the use and disclosure of sensitive personal information to specific business purposes approved by the CCPA. Our use of Sensitive Personal Information is already limited to the approved business purposes identified above.

Right to Non-Discrimination: Unless permitted by applicable law, we will not discriminate against you for exercising any of your privacy rights under the CCPA or applicable law, including by, but not limited to:

  1. Denying you goods or services;
  2. Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  3. Providing you a different level of quality of goods or services; or
  4. Suggesting that you will receive a different price or rate for goods or services or a different level of quality of goods or services.

Exceptions.

These rights are not absolute and are subject to certain exceptions. For example, we cannot disclose or permit access to specific pieces of Personal Information if granting your request would present a certain level of risk to the security of the Personal Information at issue, your account with us or the security of the website. We may deny your deletion request if retaining the information is necessary for us or our service providers and/or contractors to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your California Rights

Requests can be submitted by emailing us at hello@funzpoints.com. Please include your full name, email, phone number and a description of your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Please note that these rights apply only to California consumers. Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

Authorizing an Agent to Act on Your Behalf

Except where you have provided an agent with a Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code, when using an authorized agent you must: (i) provide the agent with signed written permission clearly describing their authority to make a request on your behalf; (ii) verify your own identity; and (iii) directly confirm that you have provided the authorized agent permission to submit the request. We may deny a request from an authorized agent if the agent does not provide us with the signed written permission demonstrating that they have been authorized to act on your behalf.

Verifying Your Request

The verifiable consumer request must:

  • Include your full legal name, email, and phone number, which we will need to contact you in order to verify that you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Other California Privacy Rights: California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes. We do not share information we collect about you with third parties for those third parties' direct marketing purposes.

Your ‘Do Not Track’ Brower Setting. Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites, including the Service, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit allaboutdnt.com. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

CHANGES TO THE POLICY

We may modify or update this Policy from time to time. We encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy. Where changes to this Privacy will have a fundamental impact on the nature of how we collect, use, or share your data, we will give advance notice of such changes.

QUESTIONS ABOUT THE POLICY

For questions regarding this Policy, please contact us at: hello@funzpoints.com.

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