WHAT INFORMATION DOES PROVVY COLLECT
Provvy endeavours to collect information that contains personal details only when absolutely necessary to achieve the aim of the platform.
Provvy collects two types of data about Users: (1) information that you or others voluntarily submit to us (described below under User-Supplied Information) and (2) technical data automatically collected from all visitors to the Wormhole Service (described below under Automatically Collected Data).
- Mobile device information: We may store your phone number, as well as information regarding your mobile device, including your mobile phone number, device type, and operating system and information in your mobile phones, address book, or in other applications as permitted by the functionality of such mobile device.
- Location: You may allow the Provvy mobile application to have access to your location to provide helpful information and services based on where you are located (i.e., by allowing your mobile device to send us your location) and to display locations where users upload UGC when using the Provvy platform.
- App Usage Information: Provvy collects and stores information on user activity such as how many tokens users have collected.
Non-personally identifiable information: The Provvy Platform operating on a website automatically logs non-personally identifiable information such as Internet Protocol address (IP Address), a unique user ID, the content and pages that you access on the Provvy Platform, and the dates and times that you visit the Provvy Platform. Also, if you come to the Provvy Platform via a link from another site, we may track the source of that link.
INFORMATION FROM OTHER SOURCES
We may collect information about you from other sources, including from partners and commercially available sources (such as data aggregators and public databases), including YouTube API Services, Google, and Facebook Connect. You can learn more about the associated terms of service and privacy policies via the links below:
- YouTube Terms of Service: https://www.youtube.com/t/terms
- Google Terms of Service: https://www.google.com/intl/en/policies/terms/
- Facebook Terms and Policies: https://www.facebook.com/policies
For data collected and used by the YouTube API services, Users can review and revoke access to their data via the Google security settings page at https://security.google.com/settings/security/permissions.
THE WAY PROVVY USES INFORMATION
Provvy uses personally identifiable information to establish and enhance our relationship with you. Provvy does so in compliance with the EU General Data Protection Regulation (the “GDPR”), the California Consumer Privacy Act (“CCPA”), to comply as a service provider with the Digital Millennium Copyright Act (“DMCA”) and other applicable laws. Provvy may use the information that you provide, or that we collect, to operate, maintain, enhance, and deliver the various features and services found on the Provvy Platform as well as to track user-generated content and users to comply as a service provider with the DMCA and other applicable laws.
Provvy uses the information that we collect from Users to understand and analyze the usage trends and preferences of our Users, to improve the way the Provvy Platform works and looks, and to create new features and functionality. Further, Provvy may use automatically-collected data to (a) remember your information so that you will not have to re-enter it during your visit or the next time you visit Provvy; (b) monitor your participation in various sections of the Provvy Service; (c) customize our service to you, including by providing you with recommendations and (c) monitor aggregate site usage metrics such as the total number of visitors and pages viewed.
We may use your e-mail address for administrative communications such as notifying you of major Provvy Platform updates, for customer service purposes, and to send privacy or security-related policies. In certain cases, we may contact you to offer to facilitate an introduction to another company or person, including companies with which we have business relationships. If you do not want to have us contact you for these purposes in the future, you can opt out.
PURPOSES FOR USE AND LEGAL BASES FOR PROCESSING PERSONAL INFORMATION
While the purposes for which we may process personal information will vary depending upon the circumstances, in general, we use personal information for the purposes outlined in this section. In this section, we also explain the legal bases for which we process personal information about Users, as required by the EU General Data Protection Regulation (the “GDPR”).
Our Legal Bases For Processing: Pursuant to the GDPR (and other relevant laws), in general, we process your personal information for the following legal bases:
- Performance of our contract with you: The personal information we collect may be used to perform our agreements with you, including our Terms of Service, the End User License Agreement, and other terms and conditions applicable to the Provvy Platform.
- Performance of our contract with you: The personal information we collect may be used to perform our agreements with you, including our Terms of Service, the End User License Agreements, and other terms and conditions applicable to the Provvy Platform.
- For our legitimate business interests: We may process personal information in furtherance of our legitimate business interests in protecting, maintaining, and improving the Platform; developing new games, features, and services; marketing and promoting our Platform (including by profiling and marketing to Users); protecting our legal rights and interests; in support of mergers, acquisitions, reorganizations, and other business transactions; and to generally operate and improve our business.
- In certain corporate transactions: Your personal information may be disclosed as part of any proposed or actual merger, a sale and transfer of Provvy assets, an acquisition, bankruptcy, or similar event.
- With your consent: We may process personal information about you based on your consent, for example (where required by law) to send you marketing communications, surveys, news, updates, and other communications.
Purposes of Use and Processing: While the purposes for which we may process personal information will vary depending upon the circumstances, in general, we use personal information for the purposes set forth below. Where GDPR or other similar laws apply, we have set forth the legal bases for such processing (see above for a further explanation of our legal bases) italicized in parenthesis.
- Providing the Provvy Platform and related support: including operating the Provvy Platform; communicating with Users about their access to and use of the Provvy Platform; to respond to User inquiries; to fulfilling User orders and requests; to processing payments; to providing troubleshooting and other technical support; to administer contests, programs, and promotions; and for other customer service and support purposes. (Legal basis: performance of our contract with you; and for our legitimate business interests)
- Protecting the integrity of the Provvy Platform: including verifying your identity; detecting and preventing fraud and unauthorized activities; to facilitating software updates; to secure of our systems and the Provvy Platform; to prevent hacking, cheats, and spamming; to enforcing our Terms of Service, End User License Agreements, and other applicable policies; and to protect the rights and safety of Users. (Legal basis: performance of our contract with you; compliance with laws; and for our legitimate business interests)
- Analyzing and improving the Provvy Platform and our business: including to better understand how Users access and use the Provvy Platform; to evaluate and improve the Provvy Platform and our business operations; to develop new features, offerings, and services; to conduct surveys and other evaluations and for other research and analytical purposes. (Legal basis: our legitimate business interests)
- Personalizing the Provvy Platform: including tailoring content we send or display on the Provvy Platform (e.g., for your geographic area); offering personalized help and instructions; tailoring your experiences, and otherwise personalize your experiences with the Provvy Platform. (Legal basis: our legitimate business interests)
- Advertising, marketing, and promotional purposes: including to send or display targeted marketing; to reach you with more relevant ads and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about the Provvy Platform or information we think may interest you; and to administer promotions, games, and contests. Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes. (Legal basis: our legitimate business interests and/or with your consent)
- Securing and protecting our business: including to protect and secure our business operations, assets, the Provvy Platform, our network and information and technology resources; to investigate, prevent, detect and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or a third party, or other unauthorized activities or misconduct (Legal basis: our legitimate business interests and/or compliance with laws)
- Defending our legal rights: including the right to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with Users or third parties. (Legal basis: our legitimate business interests and/or compliance with laws)
- Auditing, reporting, corporate governance, and internal operations: including relating to financial, tax, and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping, and legal functions; to maintain appropriate business records; to enforce company policies and procedures; and related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business. (Legal basis: our legitimate business interests and/or compliance with laws)
- Complying with legal obligations: to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal processes; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority. (Legal basis: our legitimate business interests and/or compliance with laws)
ADDITIONAL INFORMATION FOR USERS IN THE EEA
Subject to the conditions set out in the applicable law, Users in the European Union/European Economic Area (and in other jurisdictions where similar rights apply) have the following rights regards our processing of their personal information:
- Right of access. If you ask us, we will confirm whether we are processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details).
- Right to correction (rectification). If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it corrected. If you are entitled to have the information corrected and if we have shared your personal information with others, we will let them know about the rectification where possible.
- Right to erasure. You can ask us to delete your personal information in some circumstances such as when we no longer need it or if you withdraw your consent (where applicable) by sending an email to email@example.com. If you request that we delete your personal information, we may do so by deleting your account(s) with us.
- Right to restrict (block) processing. You can ask us to restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to our use or stated legal basis.
- Right to data portability. You have the right, in certain circumstances, to receive a copy of personal information we have obtained from you in a structured, commonly used and machine-readable format, and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
- Right to object to marketing. You can ask us to stop processing your personal information to the extent we do so based on our legitimate interests for marketing purposes. If you do so, we will stop such processing for our marketing purposes.
- Right to object. Where our processing is based on our legitimate interests (other than marketing purposes), we must stop such processing unless we have compelling legitimate grounds that override your interest or where we need to process it for the establishment, exercise, or defense of legal claims. Where we are relying on our legitimate interests (other than marketing), we believe that we have a compelling interest in such processing, but we will individually review each request and related circumstances.
- Rights are not to be subject to automated decision-making. You have the right not to be subject to a decision when it is based on automatic processing if it produces a legal effect or similarly significantly affects you unless it is necessary for entering into or performing a contract between us. Provvy does not engage in automated decision-making.
- Right to withdraw your consent. In the event your personal information is processed based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
- Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority if you consider that our processing of your personal information infringes the law.
Please note that some of these rights may be limited, such as where we have an overriding interest or legal obligation to continue to process the data. Please contact us at firstname.lastname@example.org if you wish to exercise any of your rights or if you have any inquiries or complaints regarding the processing of your personal information by us.
TRANSFER OF YOUR INFORMATION TO THE UNITED STATES
The Provvy Platform is a worldwide service. All information collected or received by Provvy in connection with the Provvy Platform is collected in, processed in, or transferred to Australia. While your information is in another jurisdiction, it may be accessed by the courts, law enforcement, and national security authorities according to the laws of those jurisdictions. If you are a consumer residing in the European Union, Provvy relies on the consent of the individual to transfer personal information from the European Economic Area (EEA) to non-EEA countries. By using the Provvy Platform, you expressly consent to such collection, transfer, and processing. Backup data, matchmaking data, and administrative data may also be stored on media or servers located in Australia.
INFORMATION REGARDING UNDERAGE PERSONS
Provvy does not knowingly collect or retain personally identifiable information about persons under 13 years of age or allow third parties to collect such personal information. Any person who provides their personal information through the Provvy Platforms represents that they are 13 years of age or older. If Provvy learns that personally identifiable information of persons under the age of 13 years has been collected on the Provvy Platform without verifiable parental consent, then Provvy will take the appropriate steps to delete this information.
If you are a parent or guardian and discover that your child under the age of 13 has obtained a Provvy Platform account, then you may alert Provvy at email@example.com and request that Provvy deletes that child’s personal information from its systems.
ACCESS TO YOUR PERSONAL INFORMATION
If you register as a member of Provvy, you may update, correct, or delete your profile information and preferences at any time by accessing the “My Account” area of the Provvy Service or by emailing us firstname.lastname@example.org. To protect your privacy and security, we take reasonable steps to verify your identity before granting account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times. If you close your account, Provvy may retain certain information about you for the activities described in this Privacy Notice, or as permitted or required by applicable law.
Provvy uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. However, no data transmissions over the Internet can be guaranteed to be 100% secure. We cannot, therefore, ensure or warrant the security of any information you transmit to Provvy, and you do so at your own risk. Please know that although we make our best efforts to keep your information secure, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If Provvy learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Provvy Platform or providing personal information to us you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of this website. Provvy may post a security notice on the Provvy Platform if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach, or to opt-out of receiving electronic notice, you should notify us at email@example.com.
CHANGES AND UPDATES