Effective Date: March 2, 2022
Last Updated: March 15, 2023
Triumph Labs, Inc. ("Company" or "We") takes your privacy seriously and is committed to protecting it through our compliance with this policy.
The Company provides software to game developers to allow them to integrate and offer to the players of their games (each a “Player” and together “Players”), this policy covers all information collected in a game using Triumph’s software, including:
(i) leaderboards that publish Player scores in a given game category or multi-game category (”Leaderboards”);
(ii) match-making between real players which may or may not include leaderboard functionality (”Match-Making”); (iii) real-cash prize tournaments and other real-cash prize games, including, in certain cases offering of leaderboards, ,match-making, and the creation and development of real-cash entry prize structures for each tournament or game with a prize (”Real Cash Tournaments”).
This policy describes:
- The types of information we may collect or that you may provide when you register with, access, use, or transact with the Triumph SDK.
- Our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies only to information we collect in the Triumph SDK and in electronic communications sent through or in connection with the Triumph SDK. This policy DOES NOT apply to information that:
- We collect that is not accomplished through the App or Triumph SDK including, offline, by email, direct text message, phone, or on any Company websites.
- You provide to or is collected by any third party.
- 2.Age Limits.
Certain features of the App are not intended for all age groups. For the Leaderboard and Match-Making products the Company uses an age-gate to determine the age of a user. If a person is under the age of 13 certain features will not be available, for example, the uploading of avatars, the changing of default username, and reuse of a username in multiple sessions (together the features available after such restriction being referred to as “Anonymous Mode”) in order to ensure that no data is collected from such users.
If a user is under 18 years of age Leaderboard and Match-Making will be available but the Real Cash Tournaments feature will not be available.
We do not knowingly collect personal information from children under 13 years of age. If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, or if a child under the age of 18 has accessed any of the Real Cash Tournament features, please contact us at [email protected].
- 3.Information We Collect and How We Collect It
We collect information from and about users of the App:
- Directly from you when you provide it to us.
- Automatically when you use the App.
- Automatically when you execute transactions on the App.
- Automatically when you communicate through the App.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through the App and details related to the fulfillment of your transaction.
- Automatically when you allow various permissions (location, camera, etc.).
A. Information You Provide to Us
When you download, register with, or use the App, we may ask you provide information:
- By which you may be personally identified, such as name, email address, telephone number, and birthdate.
- Information submitted by you that may allow you to be personally identified, such as a user selected image, a username, and information that you communicate to the Company within the App, for example when you report a problem within the App using the customer support chat function.
- That is about you but individually does not identify you, such as the following: App input data, for example the buttons you press when interacting with the App, score data, and mathematical skill rankings based on your score data.
- When placing orders through the App you may be required to provide financial information including credit or debit card information, address, or bank account information.
- In order to withdraw from the App you will be required to provide or we will collect the following additional information by which you may be personally identified including: an image of a government issued identification document or such other identification document as may be accepted by the Company; a short video that includes your face; the location of access; the internet protocol (IP) address from which you access the system; data regarding the browser or software used to access the system; and the time of access (the “Customer Authentication Data”).
You may also provide information for publication or display ("Posted") on public areas of the App, such as username, the selected user image, and gameplay score data, gameplay visual data, and prize outcomes (collectively, "Public Account Data "). Your Public Account Data is posted and transmitted to others at your own risk. We cannot control the actions of third parties with whom your Public Account Data is visible and such Public Account Data should be understood as being generally available to the public both within the App and outside of the App.
B. Automatic Information Collection and Tracking
When you download, access, and use the App, it may use technology to automatically collect:
- Device Information. We may collect information about your mobile device and internet connection including the IP address, operating system, browser type, mobile network information, the device's telephone number, and the devices data service providers.
- Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device that you provide access to. This includes, for example, photographs which you select for upload as a user image.
- Location Information. This App does collect and log real-time information about the location of your device in order to limit use is jurisdictions in which real-cash tournaments are not allowed.
If you do not want us to collect this information do not download or use the App or delete your account as well as the applications from your device.
C. Third-Party Information Collection
When you use the Company Apps certain third parties may use automatic information collection technologies to collect information about you or your device. Third parties that are contracted with by the Company for the provision of services related to the app (“Integrated Third Parties”) and may collect data include:
- Payment processors.
- Customer authentication providers.
- App publishers.
- In-app communication providers.
- Device authentication providers.
- Customer identity authentication providers.
Information provided to Integrated Third Parties should not be used for any other purpose outside of fulfilling their service to the Company. If you believe that your information is or has been used inappropriately by any Integrated Third Parties, please contact [email protected].
Third parties that are not the Company, the Developer, or Integrated Third Parties may use tracking technologies to collect information about you when you use download or use the Company Apps. For example:
- Platforms from which you download the App.
- Your internet service provider.
- Your device manufacturer.
- Your mobile or data service provider.
The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
- 4.How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information, to:
- Track your score and prize outcomes.
- Develop and create prize structures.
- Provide you with the App features.
- Give you notices about your account, including expiration and renewal notices.
- Contact you regarding any App issues. (Please note that you will never be requested to provide your account credentials to the Company, the Developer, or any Integrated Third Parties – you should not share your account information with anyone. If you have issues with account access contact [email protected].)
- Notify you when App updates are available and of changes to any products or services we offer or provide though it.
- Confirm your identity.
- Fulfill any other purpose for which you provide it.
- Provide a personalized experience, for example use of skill-based matchmaking in tournaments.
- Employ anti cheating and anti-fraud algorithms and features.
- Track the performance of the App, improve the Company Apps and company practices.
The usage information we collect helps us to improve our Company Apps and to deliver a better and more personalized experience by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our App according to your individual interests or skill level.
- Recognize you when you use the Company Apps.
- Maintain compliance, financial, tax, and other legally required records.
- Improve App performance.
We use location information we collect to ensure that you are in a jurisdiction where the use of the App is authorized or to assist in the confirmation of your identity, and for no other purposes.
We may use the information we collect to display advertisements to you within the App, including in certain cases advertisements based on your personal information.
- 5.Disclosure of Your Information
We may disclose: (i) aggregated information about our users in a de-identified form, (ii) information that does not identify any individual or device, and (iii) Posted information without restriction.
In addition, we may disclose personal information that we collect or you provide:
- To our subsidiaries and affiliates, including with the Developer of the App.
- To contractors, service providers, and other third parties we use to support our business, such as the Integrated Third Parties, who are bound by contractual obligations to keep personal information disclosed to them confidential and use it only for the purposes for which it is disclosed it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our users is among the assets transferred.
- To fulfill the purpose for which you provide it. For example, if you upload an image as your user image it will become Posted and publicly associated with your App account.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To comply with service provider obligations, including payment processor, compliance requirements.
- To execute deposits, withdrawals, any other in-App transactions.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- 6.Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
- Tracking Technologies. You can choose whether or not to allow the App to collect information through other tracking technologies by not authorizing such collection or terminating the authorization. If you block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
- Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the App may become inaccessible or not function properly.
- Advertising by the Company. If you do not want us to use information that we collect or that you provide to us for the delivery of advertisements within the App, you can terminate use of any App that contains advertisements.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
Residents in certain states, such as California, may have additional personal information rights and choices. Please see the section Your State Privacy Rights for more information.
- 7.Accessing and Correcting Your Personal Information
You can review and change your personal information by logging into the Company Apps and visiting your account profile page.
If you are unable to do so in your account or require additional data you may contact [email protected] to request access to, correct, or delete any personal information that you have provided to us. Please note that we cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We cannot delete certain information that is required to be maintained for legal, tax, or compliance purposes, for example, phone number, personal identity verification information, account data, and personally identifiable prize data (and gameplay data underlying it). We maintain such information for the periods stated in the Company’s Record Retention Policy.
Residents in certain states, such as California, may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.
- 8.Your State Privacy Rights
State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. If you are a resident of, or otherwise covered by, state privacy laws in California, Colorado, Connecticut, Nevada, Utah and Virginia or to learn more about such privacy rights, visit our State Specific Privacy Policies and Notices, as follows:
- 9.Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure, for example, any deposit or withdrawal transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or you have chosen) a password for access to certain parts of the Company Apps. This password can allow access to the account you hold with in the Company Apps and allow the person with such a password to withdraw available funds from your account. You are responsible for choosing a strong password, regularly changing it, and keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or through our Company Apps. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
- 11.Contact Information