SCAVENJER PRIVACY POLICY

Welcome to Scavenjer LLC!

We are a company specializing in augmented reality scavenger hunts in a competitive game form. In the future, we plan to incorporate more traditional forms of gaming. Scavenjer LLC takes your privacy and the protection of your personal information seriously. This Privacy Notice explains what personal information Scavenjer LLC collects when you visit or use the Scavenjer Services, as well as ways we might use or disclose it. By “personal information,” we mean any information from or about an identified or identifiable person, including information that Scavenjer LLC can associate with an individual person. This Notice only covers our practices—it doesn’t cover the practices of third parties we don’t own or control, including other companies you might interact with on or through the Scavenjer Services (see Third-Party Websites and Services).

California Residents – Our Notice at Collection is as follows:

Lists of the categories of personal information collected are in I. PERSONAL INFORMATION WE COLLECT.

The purposes for which the categories of personal information are collected and used are in III. HOW WE USE AND DISCLOSE PERSONAL INFORMATION. We do not sell or share personal information for cross-context behavioral advertising. We do not collect sensitive personal information. See D. Analytics & Advertising.

Our retention period explanation is in VI. YOUR RIGHTS, CHOICES, AND CONTROLS.

When we say “Scavenjer LLC” (or similar things like “we” or “us”), we’re referring to Scavenjer LLC as the entity that controls and is responsible for your personal information (see Contact Us to see who that is).

When we say “Scavenjer Services,” we mean our current and future games, websites, applications, entertainment content, and services that link to this Notice, regardless of how you access or use them or engage with us, including through mobile devices or offline such as by phone. Your use of the Scavenjer Services is also subject to the Terms of Service in your region (including its provisions regarding limitations on damages, resolution of disputes, and application of governing law). Please read this entire Notice to make sure you understand it. You should also read the Terms of Service carefully, and make sure you understand and agree to them before using the Scavenjer Services.

We’ve written summaries to identify the key issues discussed in many sections at a glance. However, these summaries are intended solely to simplify things, and the full Notice should be read as it takes priority in the event of any ambiguity or conflicts (so be sure to read the whole thing carefully!).

If you don’t understand any parts of the Notice, Contact Us with questions.

Personal Information We Collect
- Personal Information You Provide
- Personal Information We Collect Automatically
- Personal Information We Collect From Third Parties
- Categories of Personal Information Collected & Disclosed
How We Collect Personal Information
- Cookies & Related Technologies
- Analytics & Advertising
- Social Media Platforms
How We Use and Disclose Personal Information
- Legal Basis
- Using Personal Information
- Disclosing Personal Information
- Communication & Player Behavior
- Anti-Cheat
Third-Party Websites and Services
International Personal Information Processing
Your Rights, Choices, and Controls
Security
Updates and Revisions
Contact Us

I. PERSONAL INFORMATION WE COLLECT

We collect personal information in three main ways:

You provide it directly (such as by registering for an account).
We record it automatically (including with technologies like cookies).
We receive it from third parties (like social media companies).

The particular types of personal information we gather usually depend on how you interact with us, like which Scavenjer Services you use and how you use them.

Information that is de-identified, aggregated, or anonymized so that it cannot be used to identify an individual is not considered personal information. If we de-identify, aggregate, or anonymize your personal information (for example, by deleting your email address, user ID, and other identifiers), we commit to maintain and use it in such form without attempting to re-identify it.

A. Personal Information You Provide

Summary: We collect personal information you choose to provide. You don’t have to disclose personal information when we ask you for it, but if you decline, you might not be able to access certain Scavenjer Services or take advantage of their full functionality.

We collect personal information you provide on the Scavenjer Services, including:

Your email address, date of birth, in-game name (e.g. User ID), and similar contact info (like when you register for an account);
Your username, password, and other details that help us secure and provide access to the Scavenjer Services (like when you login to our games or websites);
Your name, billing address, telephone number, payment method, and other details to help process purchases you make (like when you buy virtual goods or shop at our Merch Store);
Your support-related info, including the nature of your concern and your account or order details (like when you request help from us by submitting a support ticket);
Your preferences, interests, and general demographic info (such as your hobbies, favorite games, or other info you disclose, like when you respond to a survey);
Info related to contests or promotions (like to submit an entry, prove your eligibility, or claim a prize if you win); and
Your Scavenjer LLC account info (like your preferred game settings, friends list, and in-game achievements).

The Scavenjer Services also offer social features like text chat. When you use these features, the personal information you disclose may be seen by others. We may collect and use the personal information you provide, including to enforce our Terms of Service, and in some cases, it may also be collected or used by others without your express knowledge.

We may record gameplay and related personal information, and replay or otherwise make it available to other players without further notice to you. For example, we may record event-related footage and we may use the footage to help promote or improve the Scavenjer Services.

If you disclose any personal information relating to other people to us or to our service providers in connection with the Scavenjer Services, you represent that you have the authority to do so and to permit us to use the personal information in accordance with this Notice.

B. Personal Information We Collect Automatically

Summary: We automatically collect some personal information about how you interact with and navigate the Scavenjer Services, as well as the device and software you use to do so.

Common examples include personal information regarding:

Your use of the Scavenjer Services (such as timestamps, clicks, scrolling, browsing times, browsing heatmaps, searches, referral/exit pages, and activity and interactions on our websites and in our game clients, including chat logs)
Your computer or device (such as IP address, which may be used to infer general location at a city or country level, unique device IDs, processing capabilities, manufacturer and model, language and other regional settings, and screen resolution and similar settings);
Your connection to the Scavenjer Services, including details about the network and software you’re using (such as browser type and version, operating system name and version, ISP, and your preference settings); and
How the Scavenjer Services perform, including problems you may encounter (such as loading errors and response times).

We may use technologies like cookies, scripts, and our own servers to help us collect and store this personal information, including in log files

C. Personal Information We Collect From Third Parties

Summary: Sometimes we obtain personal information from third parties to use along with the personal information we collect ourselves.

We obtain personal information from third parties to supplement the personal information you provide and the personal information we collect automatically, including from the following sources:

We obtain personal information from third-party integrations if you activate their services in connection with the Scavenjer Services. Your privacy settings on the third party’s service control what personal information they can disclose to us. Please make sure you’re comfortable with what they might disclose by reviewing their posted policies, and if applicable, modifying your privacy settings directly on their service.
We obtain information from third parties in the analytics and advertising ecosystem to help support our marketing initiatives, improve the Scavenjer Services, and better manage our ad campaigns.
We obtain information from vendors to help us identify from where you’re using the Scavenjer Services (like your approximate location based on your IP address). This helps us, for example, process purchases (like assessing tax obligations), prevent fraud or abuse of the Scavenjer Services, and customize your visit.
We also receive personal information from third-party platforms (like the Apple App Store or Google Play) if you download the Scavenjer Services on your mobile device. This might include, for example, technical details (like device IDs) and the fact that you’ve downloaded one of our apps. We also obtain personal information from third-party gaming platforms in connection with your use of the Scavenjer Services.
We obtain personal information from social media platforms with which you interact. For example, we may receive personal information about your use of our social media pages from those platforms.
We obtain personal information that developers and other players provide to us.
We obtain personal information from public sources, such as personal information in the public domain.

D. Categories of Personal Information Collected & Disclosed

Depending on your use of the Scavenjer Services, the following categories of personal information may have been collected and disclosed for a business purpose in the preceding 12 months:

Identifiers, including name, in-game name, username, email address, billing address, telephone number, IP addresses, unique device IDs, and online identifiers
Characteristics or demographics, including age and gender
Commercial information, including interaction with the Scavenjer Services, customer support information, preferences, interests, hobbies, favorite games, purchase history, and payment method
Internet or other electronic network activity information, including the use of the Scavenjer Services (timestamps, clicks, scrolling, browsing times, browsing heatmaps, searches, referral/exit pages, and activity and interactions on our websites and in our game clients, including chat logs), computer or device (processing capabilities, manufacturer and model, language and other regional settings, screen resolution and similar settings, and IP address (which may be used to infer general location at a city or country level)), connection to the Scavenjer Services (browser type and version, operating system name and version, ISP, and your preference settings), how the Scavenjer Services perform (loading errors and response times), third-party platform and usage data, and advertising and analytics information
Audio, electronic, or similar information
Inferences drawn from any of the above in this section
Account and payment credentials, including passwords, card numbers, and security codes

We do not collect sensitive personal information as defined under comprehensive state privacy laws, including the California Consumer Privacy Act and the European Union’s GDPR.

II. HOW WE COLLECT PERSONAL INFORMATION

As discussed above (Personal Information We Collect Automatically), we automatically collect some personal information about how you use and navigate the Scavenjer Services. We may combine this personal information with other personal information we gather from or about you as described in this Notice, including to enforce our Terms of Service.

A. Cookies & Related Technologies

Summary: We use our own servers and technologies like cookies to automatically collect and store information about how you interact with the Scavenjer Services, as well as the device you use to do so.

“Cookies” are small pieces of data that online services you use place on your device for record-keeping and identification purposes. “Web beacons” are transparent pixel images that allow online services to collect information about the ways you interact with them (like whether you’ve opened an email or clicked on an ad). Similar common technologies include things like tags, scripts, local shared objects, local storage (e.g., HTML5), and related tools.

The Scavenjer Services use cookies, web beacons, and similar technologies to automatically collect, store, and read files on your device. They may be delivered in a first-party (i.e., by Scavenjer LLC) or third-party (i.e., by other companies) context. These tools help the Scavenjer Services work and operate more efficiently, as well as collect information about how you interact with us (see Personal Information We Collect Automatically).

We also use our servers in connection with these technologies to collect information about the ways you interact with the Scavenjer Services and store it in log files. This may include, for example, information that your device, browser, or operating system sends to us when you access the Scavenjer Services (like device IDs, IP addresses, and hardware or software specifications) and details about how you use your Scavenjer LLC account (like the particular features you use, your in-game interactions and statistics, and other similar personal information).

We use personal information gathered through our servers and technologies like cookies in accordance with this Notice, including:

To monitor, secure, and maintain the Scavenjer Services (like preventing fraud);
To enhance your browsing experience (such as allowing you to log in to your account);
To analyze and improve our operations (like aggregating traffic and usage patterns);
For advertising purposes (see Analytics & Advertising);
To support and gauge the effectiveness of our communications and marketing campaigns (like letting us know if you’ve clicked on our ads or opened our emails);
To better personalize your visit and store your preferences and settings (for example, displaying content in your local language); and
To otherwise manage our relationship with players and provide the Scavenjer Services under the Terms of Service (including to improve our services and ensure a more positive and fair gaming environment).

You can learn more about cookies and similar technologies, including details of how to manage or disable them by visiting AboutCookies.org or consulting your browser’s privacy features. Some ways of managing traditional cookies may not impact the use of other technologies, but certain browsers may offer their own tools for removing HTML5. Website visitors who are using a browser that sends a Do Not Track signal or a browser that is Global Privacy Control compliant will have their signals automatically applied to their consent settings on Scavenjer LLC websites.

Please note that disabling technologies like cookies may prevent you from using the full functionality of the Scavenjer Services and the Scavenjer Services may not work as we intended.

B. Social Media Platforms

Summary: Scavenjer LLC has official social media pages across various platforms. These include official Scavenjer LLC pages on platforms like Facebook, Instagram, and Twitter. Social media platforms collect personal information from these pages according to their privacy policies and provide statistics and insights to Scavenjer LLC to help us understand the types of actions people take on our pages.

You can find out more about how each social media platform collects insights data and what personal information it discloses to us by visiting the information pages of those platforms. These platforms may disclose insights data to us relating to our engagement with players, feedback on the Scavenjer Services, and statistics and demographics such as age, gender, or approximate location.

Please remember to contact these third parties directly (and not Scavenjer LLC) if you have any questions or concerns about their practices.

III. HOW WE USE AND DISCLOSE PERSONAL INFORMATION

We use and disclose your personal information in accordance with the legal bases set out below to help us provide, operate, improve, understand, customize, support, and market the Scavenjer Services.

A. Legal Basis

Summary: We rely on the following legal bases to use and disclose personal information for individuals where required by applicable law: (i) to provide the services under the Terms of Service, (ii) with your consent, (iii) in our legitimate interests (such as safety, security, and providing a tailored service), and (iv) for other legal reasons.

We rely on several legal bases to collect, use, disclose, and otherwise process the personal information we have about you for the purposes described in this Notice. These legal bases include:

As is necessary to perform the Terms of Service and to provide the Scavenjer Services;
Where you have consented to the processing, which you may revoke at any time;
For Scavenjer LLC to comply with a legal obligation, a court order, or to exercise and defend legal claims;
Occasionally to protect your vital interests, or those of others;
Where necessary in the public interest; and
Where necessary for the purposes of Scavenjer LLC’s or a third party’s legitimate interests, such as those of visitors, users, or partners.

To find out which specific legal bases we rely upon to use personal information about you for a particular purpose, go to Using Personal Information and Disclosing Personal Information.

B. Using Personal Information

Summary: We use the personal information we collect (both individually and in combination with other personal information collected under this Notice) to help us operate our business, provide and improve our products and services, communicate with you, and advertise effectively. The particular ways we use your personal information often depend on how you choose to use the Scavenjer Services.

Some of the most common examples of how we use personal information include:

To provide the Scavenjer Services to you, respond to inquiries, fulfill requests, and process transactions (like helping you create an account, participate in scavenger hunts, and resolve support issues). We engage in these activities to manage our contractual relationship with you and, where relevant, to comply with a legal obligation (e.g., related to payment transactions) or based upon our legitimate interest in doing so;
To deliver and tailor our communications with you, like by sending you important account-related announcements or promotional communications that we believe may interest you (for details about managing your communication options, check out Your Rights, Choices, and Controls below). We engage in these activities with your consent (where required by law), where we have a legitimate interest (e.g., to promote the Scavenjer Services and keep you interested in them through personalized messages) or, in the case of account-related announcements, to perform our contract with you;
To administer surveys, contests, sweepstakes, competitive game modes, and similar offerings (such as confirming your eligibility or sending you a prize if you win). We engage in these activities to manage our contractual relationship with you, or for our legitimate interest (e.g., to promote the Scavenjer Services and keep you interested in them);
To monitor, analyze, protect, test, and improve our services and operations (like measuring how the Scavenjer Services perform, tracking usage patterns, and fixing bugs or errors). We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation (e.g., to keep the Scavenjer Services secure), and/or because we have a legitimate interest (e.g., understanding how the Scavenjer Services are used, keeping them secure, improving them, and developing new products);
To research and better understand the Scavenjer Services and how they’re used. We engage in these activities with your consent and/or because we have a legitimate interest (e.g., understanding how the Scavenjer Services are used, keeping them secure, improving them, developing new products, and understanding the impact and reach of the Scavenjer Services);
To advertise and promote the Scavenjer Services, including displaying advertising related to the Scavenjer Services on third-party websites and platforms, improving, developing, and implementing marketing campaigns, analyzing and measuring the effectiveness of those ads and campaigns, and showing you ads that are most relevant to you about the Scavenjer Services. We engage in these activities with your consent or where we have a legitimate interest (marketing our and others’ products and services and understanding the effectiveness of our marketing campaigns). For information on how to opt out of personalized advertising on third-party platforms, please see Your Rights, Choices, and Controls;
To personalize your experience with the Scavenjer Services, including by presenting content or features better tailored to your interests. We engage in these activities with your consent or where we have a legitimate interest (e.g., improving our Scavenjer Services by making them more personalized);
To improve and provide updates for the Scavenjer Services (like patching our games and releasing new features). We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest (e.g., understanding how the Scavenjer Services are used, keeping them secure, improving them, developing new products, and understanding the impact and reach of the Scavenjer Services);
To operate and expand our business. We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest in operating and expanding our business; and
To facilitate use of or integration with the Scavenjer Services, social sharing, third-party partnerships, and related functionality (such as supporting chat features). We engage in these activities with your consent or where we have a legitimate interest (e.g., increasing customer engagement with our products and the Scavenjer Services).

We may also use, disclose, and preserve personal information as necessary or appropriate, including when necessary for a legal obligation or legitimate or public interest or to protect the vital interest of you or someone else, such as to:

Comply with applicable law or respond to legal processes (like requests from law enforcement or other public or government authorities);
Securely operate the Scavenjer Services (like stopping attacks on our systems);
Protect players and third parties (such as to help prevent serious injury, abuse, or crime); and
Protect our own rights, property, and operations (like enforcing our contracts and terms—including the Terms of Service—and pursuing available remedies or limiting the damages we may sustain).

We use advanced tools to automatically scan certain types of content such as communications through social features like voice and text chat, and to monitor activity, such as patterns of behavior. Such advanced automated tools are used for the purposes of detecting and preventing violations of our policies or terms, unauthorized activity, or other security risks, and illegal, fraudulent, offensive, inappropriate, or other harmful behavior.

C. Disclosing Personal Information

Summary: We disclose your personal information for the purposes set out in this Notice, including to provide the Services, for advertising purposes, to enforce the Terms of Service, secure the Scavenjer Services, or if we’re required to do so by law or respond to legal process. In certain jurisdictions, we may use advertising services that obtain information from cookies or other trackers or use your email address, including for the purpose of delivering advertising to you based on your activities across third-party, non-affiliated websites and platforms. In states with comprehensive privacy laws where this sort of advertising may be subject to an opt-out, we do not do this. In other words, we do not “sell,” “share,” or use personal information for “targeted advertising” purposes in those U.S. states that require these defined activities to be subject to an opt-out.

We may disclose the personal information we collect to the following categories of parties:

To Scavenjer LLC-controlled subsidiaries and affiliates that provide services to us so we can more seamlessly operate, support, and improve the Scavenjer Services (such as to facilitate account transfers and provide support in your local language). Since we’re a global company, this means your personal information may be transferred to or stored in locations outside your country of residence (see International Personal Information Processing). To learn more about the Scavenjer LLC entity or, where applicable, entities that control and are responsible for your personal information, see Contact Us below.
To service providers that operate on our behalf for the purposes discussed in this Notice (see Using Personal Information). For example, when you buy something on the Scavenjer Services, we’ll disclose your payment-related personal information to entities we’ve engaged to process payments and provide similar financial services (like fraud prevention). Other common examples include service providers that help us store data, send marketing emails, provide player support services, assist with research and analysis of our services, and organize competitive tournaments. We may also transfer your personal information in some cases to our professional advisers (who are sometimes independent “data controllers”) such as lawyers and accountants (e.g., when enforcing our contract with you).
To marketing, advertising, and analytics partners (see Analytics & Advertising).
To allow you to make information available to other players. For example, if you choose to disclose personal information publicly through interactive features we control, such as voice and text chat, you should understand that this personal information becomes viewable and/or accessible to others. We reserve the right (but have no obligation) to monitor and record your use of them, including for purposes like enforcing our Terms of Service and applicable player behavior requirements (see Communication & Player Behavior and Anti-Cheat).
To recipients in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). This means your personal information may be one of the assets transferred to the acquiring entity in such situations, according to Scavenjer LLC’s legitimate interest in engaging in such transactions and operating and expanding our business.
To the Scavenjer LLC developer community via the Scavenjer LLC API so they can help contribute to the player experience. Please note that your in-game name and gameplay statistics (like your match history, item builds, and average number of kills and deaths) are viewable to others and may be disclosed through the API.

We may also disclose personal information to:

Comply with applicable law or respond to legal processes (like requests from law enforcement or other public or government authorities), including based upon our legitimate interest in doing so;
Securely operate the Scavenjer Services (like stopping attacks on our systems), based on Scavenjer LLC players’ and non-players’ legitimate interest in the Scavenjer Services being a safe and secure environment;
Protect players and non-players (such as to help prevent serious injury, abuse, or crime), based on Scavenjer LLC players’ and non-players’ legitimate interest in the Scavenjer Services being a safe and secure environment; and
Protect our own rights, property, and operations (like enforcing our contracts and terms—including the Terms of Service—and pursuing available remedies or limiting the damages we may sustain), based on Scavenjer LLC’s legitimate interest in protecting and preserving such and enforcing its legal rights.

D. Analytics & Advertising

Summary: Some of the personal information we collect is used and disclosed for analytics and advertising purposes.

Some of the personal information we collect is used and disclosed for analytics and advertising purposes. This personal information may be collected through cookies and other technologies incorporated into the Scavenjer Services as described in Cookies & Related Technologies. In addition to the technologies we operate, we incorporate technologies offered by service providers. For example, we use technologies from analytics providers (like Google Analytics) to help evaluate and report on the use of Scavenjer Services and technologies from ad partners to support our marketing and advertising efforts. Some of these technologies are able to track your activities across non-affiliated services and obtain or infer personal information about you for purposes of showing you relevant advertising based on your preferences and interests.

We have chosen not to use advertising services that constitute a “sale,” “share,” or use of personal information of consumers for “targeted advertising” purposes in those U.S. states that require these defined activities to be subject to an opt-out. For those U.S. states that require an opt-out, we require the ad partners we work with to process the personal information they receive only as permitted by a service provider or processor under state privacy law, and only to provide the services. We accomplish this through contractual restrictions with our ad partners and technical controls, including by enabling settings (where offered by an ad partner) limiting their processing of personal information (such as the “Limited Data Use” setting within Meta). We are therefore not required to provide an opt-out of the “sale” or “sharing” or use of personal information for “targeted advertising,” as those are defined under applicable laws.

Some analytics providers and ad partners offer you choices about how they collect and use your personal information directly on their websites. To learn more about opting out of Google Analytics, please review Section VI. Your Rights, Choices, and Controls. Please note that opting out through these industry tools won’t necessarily prevent personal information from being collected automatically on the Scavenjer Services, and it doesn’t mean you’ll receive fewer ads or stop them from being displayed. Instead, the ads you do receive might be less relevant to your interests.

E. Communication & Player Behavior

We’ve empowered our players to help enforce our policies (e.g., the acceptable use and behavioral policies that we publish from time to time on the Scavenjer Services) related to certain in-game behavior. For example, players may report each other and submit information about their in-game activity and actions to help us determine if the reported behavior constituted a violation of rules and procedures that apply to player conduct, as well as any potential repercussions (such as temporary or permanent account suspensions or chat restrictions).

We also record and store, and reserve the right (but have no obligation) to monitor voice and text chat and similar details about optional interactions for a period we determine is appropriate to help us, among other things, address disruptive behavior, improve our services, enforce our rules and policies and Terms of Service, and foster a more positive gaming community for our players. We engage in these activities to manage our contractual relationship with you, comply with a legal obligation (e.g., to keep the Scavenjer Services safe and secure), and/or because we have a legitimate interest (e.g., understanding how the Scavenjer Services are used, keeping them secure, and improving them).

We use both manual (like enabling you to report such behavior through support tickets) and advanced automated (such as machine learning, transcription, and analysis) tools and techniques to support these efforts.

To enable us to monitor compliance with our policies and terms, we develop template patterns of inappropriate behavior (e.g., abuse, hate speech, cheating, threats, offensive or inappropriate names), which we consider indicative of prohibited behaviors. We do this based upon an analysis of social features like voice and text chat, including files uploaded or exchanged through chat, and actual behaviors when you use the Scavenjer Services. We grade these patterns of inappropriate behavior based upon their severity with different consequences (e.g., temporary or permanent account restrictions or communications restrictions) for players based upon how serious their conduct is. If another player makes a complaint about your behavior, our advanced automated tools use these patterns of inappropriate behavior and grading system to compare your behavior over time with these patterns of inappropriate behavior and, if it is determined that you have engaged in inappropriate behavior, make a decision as to the consequences for you of your behavior. This helps us enforce our policies and terms, secure the Scavenjer Services, detect and prevent unauthorized activity, maintain the competitive integrity of the Scavenjer Services, and prevent illegal, fraudulent, offensive, inappropriate, or other harmful behavior.

Our complaints procedure may allow you to appeal a decision. In this case, we may provide you with information that illustrates our rationale and factors that contributed to our decision, along with some tips on how to avoid repeating such behavior in the future. If you still wish to appeal, you may request one of our agents to review your case who will make a final manual determination as to the correct outcome based on the available evidence.

Please be kind to other players, observe our policies related to player behavior (including our Terms of Service), and always be thoughtful about how you communicate with others!

F. Anti-Cheat

We always seek to offer players a fair, fun, and competitive gaming experience on the Scavenjer Services. Our Terms of Service strictly prohibit use of unauthorized third-party programs that interact with the Scavenjer Services, including mods, hacks, cheats, scripts, bots, trainers, and automation programs. As described in Communication & Player Behavior, we may use anti-cheat and fraud prevention technologies (such as anti-cheat software that may run in the background of your device) that may make automated decisions (such as temporary or permanent account suspensions, communications restrictions, removal of content, or limited access to game content) based on our monitoring of social features like voice and text chat and actual behaviors when you use the Scavenjer Services (see Personal Information We Collect). We engage in these activities to manage our contractual relationship with you, comply with legal obligations (e.g., to keep the Scavenjer Services secure), and/or because we have a legitimate interest (e.g., understanding how the Scavenjer Services are used, maintaining their integrity, and improving them).

Our complaints procedure may allow you to appeal a decision. In this case, you may request one of our agents to review your case who will make a final manual determination as to the correct outcome based on the available evidence.

IV. THIRD-PARTY WEBSITES AND SERVICES

Summary: We allow interactions with third parties to make your experience better, but our Notice doesn’t and can’t apply to third parties. We’re unable to guarantee that independent third parties adhere to the same practices as us, so please be sure to read their policies and terms before disclosing personal information to them.

There are several ways you might disclose personal information to third-party websites or services in connection with your visit, including:

External Links. If you click on links to external websites or services that are operated by third parties, they may collect, use, and disclose your personal information pursuant to their own policies (not ours). Including a link to or from third-party services doesn’t mean we’ve endorsed their practices.
Account Integrations. The Scavenjer Services use interfaces that allow you to interact with third-party websites, applications, or similar services during your visit, including on or through your Scavenjer LLC account or an account you’ve created with such third parties. For example, we partner with social media companies to provide features that facilitate social sharing and connections. These features may collect information about your interactions with them and the Scavenjer Services, and may use technologies like cookies to function properly. How third-party companies process and control your personal information they collect directly from you is controlled by their own privacy policies.

Please remember to contact third parties directly (and not Scavenjer LLC) if you have any questions or concerns about their practices.

V. INTERNATIONAL PERSONAL INFORMATION PROCESSING

Summary: We’re a global company with operations around the world. When you use the Scavenjer Services, your personal information may be processed anywhere we, our partners, or service providers do business, including the United States, provided that adequate technical and organizational measures are in place to ensure the security of your personal information.

(1) OPERATING THE SCAVENJER SERVICES. Depending on your location, the Scavenjer Services are operated by or on behalf of Scavenjer LLC from the United States.

For important details regarding which laws apply to your use of the Scavenjer Services and any disputes with Scavenjer LLC, be sure to check out the Terms of Service. See Contact Us to see who is the Scavenjer LLC entity or entities which control and are responsible for your personal information.

(2) CROSS-BORDER TRANSFERS AND STORAGE. To facilitate our operations, we may transfer, process, and store your personal information in jurisdictions other than where you live, including the U.S. and other regions. Laws in these countries may differ from the laws applicable to your country of residence. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.

We’ve implemented and maintain a framework consistent with applicable law and this Notice for transfers of personal information outside the country of collection, including, for example, through the use of Standard Contractual Clauses when we transfer personal information outside of the EEA and the UK. You can learn more about EU Standard Contractual Clauses on the European Commission website and to request a copy of them Contact Us. We may also need to transfer your personal information to provide the Scavenjer Services to you in accordance with the Terms of Service. By using the Scavenjer Services, you acknowledge that we may transfer your personal information to (and process it in) countries outside of your country of residence, each of which may have different privacy rules than your country.

VI. YOUR RIGHTS, CHOICES, AND CONTROLS

Summary: You have rights and choices regarding your use of the Scavenjer Services and the ways we process personal information. Since you can interact with us in many different ways, the particular controls available to you often depend on the nature of our relationship.

You can use many parts of the Scavenjer Services without ever creating an account, purchasing our products or services, or otherwise submitting personal information like your name or email address to us. If you do choose to visit or use the Scavenjer Services, we generally retain the related personal information as long as your account is active or as is otherwise necessary to provide the Scavenjer Services, operate our business (including for legitimate purposes like complying with our legal obligations, managing internal books and records, preventing fraud, resolving disputes, and enforcing our contracts and terms, such as this Notice and the Terms of Service) or to achieve the purposes set out in this Notice, unless a longer retention period is permitted or required by law.

The precise periods for which we keep your personal information vary depending on the nature of the personal information, why we need it, and relevant legal or operational retention needs. Factors we consider in determining these periods include the minimum required retention period prescribed by law or recommended as best practice, the period during which a claim can be made with respect to a contract or other matter, whether the personal information has been aggregated or pseudonymized, and other relevant criteria. For example, the retention period applicable for your personal information needed to provide the Scavenjer Services to you (such as accessing the games) is limited to how long you maintain an account. When your account is deleted, Scavenjer LLC will delete the relevant personal information for that purpose (providing the service to you) but will keep some account-related personal information (your event history, for instance) for other defined purposes such as security and fraud detection. As another example, communications logs/history information is retained at a minimum for a period of time sufficient to allow any complaints to be filed after a match, and if such a complaint is filed, for a period of up to two years from their creation or a period of time sufficient to investigate the complaint. This is to enable Scavenjer LLC to properly investigate infringements of our rules and policies such as fraud, cheating, and disruptive behavior.

You can limit the personal information you disclose to third parties through integrations, such as by choosing not to link your Scavenjer LLC account with third-party services or disabling such links through your account.

We offer players choices about the types of communications they receive from Scavenjer LLC. If you choose to receive marketing and promotional emails from us but later change your mind, simply “unsubscribe” by following the instructions in the relevant email. These choices don’t apply to mandatory communications that are part of the Scavenjer Services, like important account-related notices.

Many Internet browsers allow you to reject, manage, and delete cookies. You may also be able to manage other similar technologies, like HTML5, by changing your browser settings. To learn more about cookies and similar technologies, including details of how to manage or disable them, go to Cookies & Related Technologies.

If you don’t want to take advantage of the services that third-party analytics and advertising companies provide on the Scavenjer Services, you may be able to opt out (or opt in if you are in the EEA or UK) of some of them by visiting YourAdChoices.com or Optout.NetworkAdvertising.org, or if you’re located in the EEA, UK, or Canada, YourOnlineChoices.eu or YourAdChoices.ca respectively. For a representative list of third-party advertising and analytics partners that operate on the Scavenjer Services, as well as details about how to opt out (or opt in if you are in the EEA or UK) to the extent applicable, see Cookies & Related Technologies.

Some U.S. states (like California) and non-U.S. regions (like the EEA and UK) provide additional rights by law. Based on your jurisdiction, you may have some or all of the rights listed below:

Access: The right to obtain confirmation as to whether your personal information is being processed, to know what personal information we have about you, 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 the personal information, the categories of personal information sold, shared, or disclosed for a business purpose, the categories of third parties and vendors to whom we disclose the personal information, and the specific pieces of personal information we have collected about you. You can also learn more about how to request access to your account information using the information in the Contact Us section below.
Correction: The right to have rectified any inaccurate personal information concerning you.
Deletion: The right to delete personal information that we have collected from you, subject to certain exceptions. You can correct your personal information in the Account Management portal or submit a request for access or deletion with Player Support.
Restriction: The right to restrict the processing of your personal information in certain cases.
Data portability: The right in certain cases, to receive the personal information concerning you in a structured, commonly used and machine-readable format and/or transmit that personal information to another data controller.
Objection: In some cases required by law, the right to ask us to stop processing your personal information. Your right to object includes where we process your personal information for performing a task in the public interest or pursuing our legitimate interests or those of a third party.
Right to withdraw consent: Where your consent is required, you may at any time withdraw such consent (though this will not affect the lawfulness of any processing of your personal information prior to that).

We do not “sell,” “share,” or use personal information of consumers for “targeted advertising” purposes in those U.S. states that require these defined activities to be subject to an opt-out. We are therefore not required to provide an opt-out.

In all other jurisdictions, you may be able to opt out of having information about your activity on the Scavenjer Services (such as use of the website and app) disclosed to partners for personalized advertising purposes on third-party platforms by following the instructions in the Analytics & Advertising section.

Account holders who have requested to receive our marketing communications may opt out by logging in and visiting your Account Management Portal and unchecking the box in Communication Preferences. This will opt you out of communications regarding new releases, game updates, events, or other Scavenjer LLC-related content.

If you’re concerned with the way we’re handling your personal information, or if you would like to exercise the rights available to you, please Contact Us. For account holders, you may also submit requests through your Account Management portal. We will confirm receipt of and respond to your request consistent with applicable law.

Before we process such requests, we may ask you to verify your identity (like by logging in to your account or providing us with certain personal information to help us confirm ownership) and we may request payment where allowed by law.

You may also make a rights request using an authorized agent. Authorized agents can Contact Us in the same manner as you to initiate the rights request on your behalf. An authorized agent request must include (a) the name and email address of both you and the agent, and (b) the written permission, signed by you, granting authority to the agent, such as a power of attorney. If we receive a rights request from an authorized agent who does not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may require you to verify your own identity directly with us, confirm with us that you provided the authorized agent permission to submit the request, or deny the request.

Note that asking us to delete personal information or refrain from processing it may also result in us being unable to make certain Scavenjer Services available to you, in which case you’ll no longer be able to access those Scavenjer Services. If you withdraw your consent (including for marketing purposes), it does not affect the lawfulness of what we did up until that point. We may also retain certain personal information associated with your account for purposes like complying with our legal obligations, managing internal books and records, preventing fraud, resolving disputes, and enforcing our contracts and terms, such as this Notice and the Terms of Service.

You also have the right not to be discriminated against for exercising any of these rights.

If we don’t take action on your request, or you’re not satisfied with a decision, you may appeal the decision by submitting an appeal request through Contact Us.

If you appeal the decision, a support representative will review your request independently, and inform you of any action taken or not taken in response to the appeal, along with a written explanation of the reasons in support of the response within 45 days (unless a further extension is needed, which we will inform you about in advance). If the appeal is denied, we will also provide you with a method through which you may submit a complaint.

If you’re in the EEA or UK, you may lodge a complaint with an EEA or UK data protection authority for your country or region where an alleged infringement of applicable data protection law occurs. Scavenjer LLC's lead supervisory authority under the GDPR is the Irish Data Protection Commission.

If you’re in Australia, please note that you generally have the right to deal with us anonymously or using a pseudonym (unless it’s not practicable for us to deal with you on this basis). Also, please Contact Us if you would like to complain that we have breached the Australian Privacy Principles or any applicable code.

VII. SECURITY

Summary: We’re committed to securing personal information and complying with our obligations under applicable data protection laws, but can’t absolutely guarantee the security of any personal information we collect from you. By choosing to disclose personal information to us (or anybody else online these days), you’re acknowledging this risk.

We use appropriate physical, technical, and organizational security safeguards to help protect your personal information from unauthorized access, destruction, use, modification, or disclosure both during transmission and in storage. For example, we use computer systems with limited access in controlled facilities to store personal information. We also use technologies like encryption and hashing to protect some of the personal information we collect.

However, please note that no server, communications network, or data transmission over the Internet is 100% secure. The Scavenjer Services are no exception. We can’t guarantee the security of any personal information transmitted through the Scavenjer Services and make no assurances about our ability to prevent any such loss or misuse.

It’s up to you whether you’d like to disclose personal information to us; if you do, you’re acknowledging that you’re doing so with this risk.

VIII. UPDATES AND REVISIONS

We’ll update this Notice from time to time to reflect changes in technology, law, our business operations, or any other reason we determine is necessary or appropriate. When we do make changes, we’ll update the “Last Modified” date at the top of the Notice and post it to the Scavenjer Services. If we make material changes to the Notice or the ways we process personal information, we’ll provide you additional notice as well (such as by prominently posting a notice of the changes on the Scavenjer Services before they take effect or sending you a notification directly).

We encourage you to check back periodically to review this Notice for any changes since your last visit. This will help ensure you better understand your relationship with Scavenjer LLC, including the ways we process your personal information.

IX. CONTACT US

For game-related requests or concerns (e.g., trouble accessing your account, billing matters, content availability, reporting bugs or similar technical issues, discussing a ban, deleting an account, reporting a player, etc.), please contact our support team. You can also view our support page for up-to-date information and troubleshooting guides.

If you have any questions or concerns about this Notice or our privacy practices, please send them to our Data Protection Officer via email at privacy@scavenjer.com.