Privacy Policy Notice

Last Updated: 05/25/2021

This Privacy Policy is designed to help you understand how M-League Pte. Ltd. and its affiliates, including Mobile Premier League Inc.  (collectively, “MPL,” “we,” “us,” “our”), collect, use, and share your personal information and to help you understand and exercise your privacy rights in the course of your use of the web portal at https://us.mpl.live (“the Site”), partner websites, the mobile application (“the App”) and other portals operated by MPL (collectively, the “Platform” or the “MPL Platform”).  MPL offers various skill and learning-based digital games and other promotional and interactive features (collectively “Services”) which shall include matches, challenges, tournaments and competitions in respect of such skill and learning-based digital games (“Competitions”).

1.  SCOPE

This Privacy Policy applies to personal information processed by us, including on our website, platform, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called “Services.”

2.  PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

  • a. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

  • Account Creation and use of Services. We may collect information when you create an account, such as name, date of birth, email address and other information that we may be granted access to through your social media profiles, when you deposit funds, such as date of birth, and when you initiate an account withdrawal, such as address and government identifiers.
  • Purchases. We may collect personal information and details associated with your purchases, including payment information.  Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but it may receive information associated with your payment card information (e.g., your billing details), transaction reference numbers etc.
  • Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support or otherwise communicate with us.
  • Surveys. We may contact you to participate in surveys.  If you decide to participate, you may be asked to provide certain information which may include personal information.
  • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

  • b. Information Collected Automatically

We may collect personal information automatically when you use our Services:

  • Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, device-related information, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address and GPS), and Internet service provider. We may also automatically collect information regarding your use of our Services, activities and transactions in the course of use of Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. In addition, we may collect information that other people provide about you when they use our Services.
  • Location Information. We may collect location information, including your approximate location derived through IP Address, as well as your precise location using GPS (if you give us permission to use your device’s location services) when you use our Services.
  • Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.
  • Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

  • Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
  • Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
  • Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
  • Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See Section 5 below to understand your choices regarding these Technologies.

  • Analytics. We may use Technologies and other third-party tools to process analytics information on our Services.
  • Social Media Platforms. Our Services may containsocial media buttons (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

  • c. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

3.   HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

  • a. Provide Our Services

We use your information to fulfil our contract with you and provide you with our Services, such as:

  • Managing your information and accounts;
  • Verifying your account information, location, and identity;
  • Compiling, maintaining and submission of information and forms for tax-related filings.
  • Providing access to certain areas, functionalities, and features of our Services such as fulfilling and delivering prizes and coupons to you;
  • Enhancing and customizing your experience;
  • Answering requests for customer or technical support;
  • Enabling you to communicate with other users;
  • Communicating with you about your account, activities on our Services, and policy changes;
  • Processing your financial information and other payment methods for products or Services purchased;
  • Learning about your playing habits and communicating with you about our Services;
  • Allowing you to register for events.

  • b. Administrative Purposes

We use your information for various administrative purposes, such as:

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
  • Measuring interest and engagement in our Services;
  • Aiding in strategic development, data collection and business analytics;
  • Managing our relationship with advertisers and partners;
  • Short-term, transient use, such as contextual customization of ads;
  • Improving, upgrading or enhancing our Services;
  • Offering you opportunities to participate in surveys, contests, or sweepstakes;
  • Developing new products and Services;
  • Keeping you posted about our latest announcements and those of our partners, software updates, and upcoming promotions, contests, and events;
  • Marketing to you;
  • Ensuring internal quality control and safety;
  • Authenticating and verifying individual identities;
  • Debugging to identify and repair errors with our Services;
  • Auditing relating to interactions, transactions and other compliance activities;
  • Enforcing our agreements and policies; and
  • Complying with our legal obligations.

  • c. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements and build up marketing profiles. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, “look-alike” modeling, and “interest-based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

  • d. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

  • Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
  • De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create, so that such information can no longer reasonably be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, partners, and investors, in our discretion.
  • Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

4.   HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

  • a. Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below.

  • Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, information verification/KYC verification, hosting, payment processing, customer service, and related services.
  • Business Partners. We may share personal information with business partners with whom we jointly offer products or services, like game developer partners.
  • Affiliates. We may share your personal information with our company affiliates.
  • Other individuals, services, and partners. We may share your personal information at your request or with your consent for other purposes that are clearly disclosed to you at the time you make a request or provide consent.
  • Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

  • b. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with our legal obligations; comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

  • c. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

  • Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).

We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.

  • Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information if you use our mobile application. You may opt out of this collection by changing the settings on your mobile device. However, as set out in our Terms, collection of location-based information is crucial for the provision of our Services and your access to Services may be limited if you choose to opt out of collection of this information.
  • “Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
  • Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada

Please note you must separately opt out in each browser and on each device.  If you choose to opt out of interest-based advertising using the methods described above, you may still see ads online, but they are less likely to be tailored to your interests.

If you are a California resident, please see the “Privacy Information for California Residents” section immediately below for information about your specific rights under California law.

6. PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

In many cases, if you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, unless certain exceptions apply, the CCPA allows you to request us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
  • Provide access to and/or a copy of certain personal information we hold about you.
  • Delete certain personal information we have about you.
  • Provide you with information about certain financial incentives that we offer to you, if any.

You also have certain rights under the CCPA not to be subject to certain negative consequences for exercising CCPA rights.

We reserve the right to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, phone number, or other information. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Please note that certain information may be exempt from such requests under California law.  For example, we need certain information in order to provide the Services to you or to comply with legal obligations, so we would need to either reject your request to delete the information or, if we are legally permitted to delete it, we would need to terminate our provision of the Services to you after deleting it. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at CCPArightsrequest@mplgaming.com.


California residents also have the right to opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include allowing third parties to receive certain information such as cookies, IP address and/or browsing behavior for interest-based advertising or related purposes. Advertising, including interest-based advertising, enables MPL to provide relevant offers to you. It may also cover certain disclosures of personal information by MPL to other entities.

Depending on what Services you use, we may share the following categories of information for such advertising (which may be considered a sale as defined by California law):

  • Identification and demographics; device information and identifiers, such as IP address, and unique advertising identifiers and cookies; connection and usage information, such as browsing history or app usage; geolocation information, such as city; and inference data.

If you or your authorized agent would like to opt out of MPL’s use of your information for such purposes (to the extent this is considered a sale), you may do so as outlined on the following page: Do Not Sell My Personal Information.   Please note that we do not knowingly sell the personal information of minors under 16 years of age.

Collection, Use, and Disclosure of Californians’ Personal Information. During the 12 months leading up to the effective date of this Privacy Policy, we collected (and continue to collect) all of the categories of personal information described in the “Personal Information We Collect ” section of our Privacy Policy and listed in the chart below. That section also explains the sources from which we collect information about you, including, for example, you, service providers, other users, third party applications, analytics providers, cookies and tracking technologies, survey partners, related entities and affiliates, developer partners, your interaction with us on our social media channels, and marketing partners.

The “How We Use Your Information” section of this Privacy Policy explains how and why we use your information. Generally speaking, we use your information to provide our Services, send communications, personalize the Services, engage in transactions, improve the Services, enforce legal terms and defend our rights, investigate and prevent security issues, fraud, and abuse, and comply with laws.

We share certain personal information as set forth in “How We Disclose Your Information” section and in the chart below, and allow third parties to collect certain information about your activity, for example through cookies, as explained in “Personal Information We Collect” section. During those 12 months, we made the following disclosures of personal information about Californians:

Category of Personal Information Collected by MPL Category of Third Parties Information is Disclosed to for a Business Purpose
Contact and account registration information, such as real name, alias, postal address, email address, date of birth, account name and password, account ID, Social Security number, or other similar identifiers. ·     Service providers who perform functions on our behalf, such as data storage and hosting providers, email and notification providers, network and system management providers, communication tools, IT support providers, CRM providers, payment providers (“Service Providers”)
·     Affiliates
·     Game developer partners
·     Data analytics providers
·     Online advertisers and ad networks
·     Other individuals, services, and partners at your request or with your consent
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes  
Financial and transactional information, such as billing information, financial account information, and information about your transactions with us and other users. ·     Service Providers
·     Affiliates
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes  
User-generated content, such as photos, videos, or audio uploaded to your profile or account and information you submit to a public forum. ·     Service Providers
·     Affiliates
·     Game developer partners
·     Other individuals, services, and partners at your request or with your consent
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes  
Customer service information, such as questions and other messages you address to us and summaries or voice recordings of your interactions with customer care. ·     Service Providers
·     Affiliates
·     Game developer partners
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes
Research or survey information, for example, if you participate in a survey, we collect information needed for you to participate (such as contact information). ·     Service Providers
·     Affiliates
·     Game developer partners and others with your consent
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes  
Device information and identifiers, such as IP address, browser type and language, operating system, platform type, device type, software and hardware attributes, and unique device, advertising, and app identifiers. ·     Service Providers
·     Affiliates
·     Game developer partners
·     Data analytics providers
·     Online advertisers and ad networks
·     Other individuals, services, and partners at your request or with your consent
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes  
Connection and usage data, such as  information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, whether you open an email and your interaction with email content, access times, error logs, and other similar information, and sensory and telemetry data. ·     Service Providers
·     Affiliates
·     Data analytics providers
·     Online advertisers and ad networks
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes  
Geolocation data, such as city, state, country, and ZIP code associated with your IP address or derived through Wi-Fi triangulation, and with your permission in accordance with your mobile device settings, and precise geolocation information from GPS-based functionality on your mobile devices. Please note that some location-based services may require your personal information for the feature to work as intended.   ·     Service Providers
·     Affiliates
·     Data analytics providers
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes
Information about others, such as if you use a “refer-a-friend” tool (or similar feature) that allows you to send information to another person, or invite them to participate in the Services. ·     Service Providers
·     Affiliates
·     Data analytics providers
·     Online advertisers and ad networks
·     Other individuals, services, and partners at your request or with your consent
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes
Other information, such as any other information you choose to directly provide to us in connection with your use of the Services. ·     Service Providers
·     Affiliates
·     Game developer partners
·     Data analytics providers
·     Online advertisers and ad networks
·     Other individuals, services, and partners at your request or with your consent
·     Entities involved in actual or potential significant corporate transactions
·     Third parties for legal purposes

California “Shine the Light” Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes.  We do not share your personal information with third parties for their own direct marketing purposes within the meaning of that law.

7. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

Under Nevada law, certain Nevada residents may opt out of the “sale” of “covered information” (as such term is defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.  We do not engage in such activity as of the effective date of this Privacy Policy; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of the sale of your covered information under Nevada law by emailing us at Nevadarequests@mplgaming.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

8. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

9. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

10. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy until you delete the app or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, enable compliance with applicable laws by us as well as any of our service providers or vendors, conduct audits, pursue legitimate business purposes and enforce our agreements.

11. CHILDREN’S INFORMATION

The Services are not directed to children under 18, and we do not knowingly collect personal information from children under the age of 18. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

12. OTHER PROVISIONS

12.1     Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

12.2     Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

13. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:

Mobile Premier League Inc.

77 Sands Street, 6th Floor

Brooklyn, NY 11201

Legal.US@mplgaming.com