Last Updated: February xx, 2015
1.2 SKILLZ is committed to the privacy and protection of information provided to us by our users. This includes any information provided to us through our Service, including any information submitted to us through various forms and through other mechanisms. By using our Service you are accepting the privacy practices contained in this Policy.
Shuman Concepts, Inc.
Privacy, c/o SKILLZ Privacy Officer
5543 Park St N., Saint Petersburg,
Phone: (727) 548-5425
2. Information Collected About You
2.1 There are various types of information that SKILLZ collects about you when you register with, interact with, or otherwise use our Service. Some of this information is provided voluntarily by you and other information is provided through automated processes under SKILLZ’ control.
2.2 Information Provided By You: In addition to personally identifiable information (“PII”) provided during the SKILLZ registration process, you may also provide us PII during the following non-exhaustive list of representative classes of interactions on our Service:
- requesting customer support and sending SKILLZ similar communications;
- making payments to SKILLZ for various offerings;
- signing up for SKILLZ email alerts, newsletters, and similar special offers;
- responding to SKILLZ surveys and other special information requests; and
- communicating with SKILLZ regarding our compliance with applicable law.
- A cookie is data stored in a small text file on your local access device that contains data about you. The information in the cookie is used to uniquely identify you and other users of our Service. The cookie may contain a token linked to our databases in order to provide you an enhanced feature set. It identifies a particular user at a particular point in time.
- A web beacon is used to enable communications with third parties. It is a small image in an HTML page with all dimensions set to one (1) pixel. Because of its insignificant size, it is not visible. It is used to pass certain non-PII anonymously to third-party sites, usually advertisers;
- A log file is a system created file that captures certain interactions between you and our Service.
2.4 Non-PII Reservation of Rights: SKILLZ reserves the right to adopt alternative methods for collecting non-PII consistent with the provisions of this Policy and without providing further notification to you, other than what is contained herein.
3. Implications Regarding Collected Information
3.1 Consent Regarding Data Storage and Transfer: Your use of our Service implies your consent to have your PII and non-PII (“Data”) (i.e. any data provided by you to SKILLZ via our Service or through other mechanisms) stored, transferred and processed within the United States, or in any other country in which SKILLZ or its affiliates, subsidiaries or agents maintain facilities. By providing us with your Data and using our Service you consent to any such transfer of Data outside of your country of origin, at SKILLZ’ sole discretion.
3.2 Control and Access to Data: SKILLZ respects both the need for you to control your Data and our need to use it in order to provide an enhanced experience on our Service. SKILLZ is diligent in ensuring that it has implemented appropriate administrative, technical, and physical safeguards to prevent the unauthorized or unlawful use of your Data, and to prevent any accidental loss, destruction, or damage to such information.
3.3 Use of Data Collected: SKILLZ is the sole business owner of the Data (i.e. as represented by the aggregate content and arrangement of the information collected about you on our Service) and will not sell, rent or share the information collected in a manner that differs from what is disclosed in this Policy. SKILLZ collects this information in order to:
- accomplish the objectives of our Service;
- provide you with a high quality user experience on our Service;
- offer you a personalized feature set on our Service; and
- to improve our Service.
3.4 Sharing of Data in General: PII provided by you will not be shared with third parties, without your permission, for any purpose other than those enumerated below. SKILLZ, in its sole discretion, reserves the right to share with third parties aggregated non-PII for the purpose of compiling information that is relevant to our business interests. SKILLZ, in its sole discretion, reserves the right to disclose any information that it obtains through our Service to appropriate governmental or regulatory authorities or governmental agencies, if required by law. SKILLZ, in its sole discretion, may share any information collected, stored and processed, if it has a good faith belief that to do so is reasonably necessary to:
- detect, investigate and otherwise address fraud, security or technical breaches or related matters; or
- protect against imminent harm to the rights, property, or safety of SKILLZ, its users, or the public at large, as required or permitted by law.
3.5 Sharing of Payment Data: SKILLZ may share transaction information with our third party payment processor (“Payment Processor”) when you pay for or renew your License on our Service. The information shared with our Payment Processor is limited to the information required by our Payment Processor to complete the payment transaction. SKILLZ does not capture or store the financial information provided by you to our Payment Processor. SKILLZ only stores the results of said transactions as provided via notifications from our Payment Processor to us upon the completion of a payment transaction.
3.6 Sharing of Data with Other Third Parties: In addition to disclosing information to our Payment Processor, SKILLZ may disclose your personal information to other third-party service providers (“Providers”) who perform services on our behalf. Examples of such Providers may include, but are not limited to, data storage and web hosting companies, as well as consultants we may engage for various reasons. SKILLZ requires Providers to use and protect your personal information consistent with the provisions of this Policy.
4. Security of Information
4.1 Any information sent by you to SKILLZ through Internet email or through our Service may not be secure and is therefore done on a non-confidential basis and at your own risk. Once such information is received, SKILLZ takes appropriate security safeguards to prevent its unauthorized use, alteration, disclosure or destruction. These safeguards include periodic review of our internal processes, and benchmarking of same with industry best practices.
4.2 Access to PII is restricted to SKILLZ employees, contractors, and agents on a need to know basis. Such individuals are generally bound by confidentiality agreements and may be subject to termination and criminal prosecution should they fail to comply as required by said agreements and/or with the contents of this Policy.
5. Data integrity
5.1 SKILLZ processes PII only for the purposes for which it was collected and in accordance with the provisions in this Policy. Reasonable steps are taken to ensure the quality of the PII that SKILLZ collects, processes, and stores. SKILLZ depends on its users to keep their PII current and accurate. SKILLZ conducts periodic reviews to ensure that only the PII required by our Service is captured and used consistent with the provisions of this Policy. The maintenance of data integrity is a joint collaborative effort between SKILLZ and our users.
5.2 SKILLZ may delete Data, from time to time, upon the request of an individual user. SKILLZ requires that a user present proper credentials for authentication before honoring all such requests. Good faith attempts are made to work with individual users regarding Data related issues. SKILLZ reserves the right to refuse such requests when they prove unduly burdensome and/or are impractical. SKILLZ will not delete Data required to be kept by applicable law or Data otherwise required by SKILLZ for legitimate business reasons.
6. Choices Regarding PII
6.2 You always have the option of contacting SKILLZ should you have questions regarding your PII. Please contact SKILLZ using the contact information provided above.
7. Protecting Children
SKILLZ restricts the use of our Service to individuals of legal age and above. SKILLZ does not knowingly collect or solicit PII from anyone under the age of 18, with or without parental consent.
Because we are committed to protecting our users’ PII, SKILLZ conducts periodic reviews of our internal processes to ensure that we remain in compliance with this Policy. We will cooperate with the appropriate authorities to resolve any user complaints regarding the transfer of PII. SKILLZ will initially try to resolve the complaint with the individual user. Formal complaints should be sent to SKILLZ using the contact information provided above.
10. Policy Changes