MY CODE PRIVACY POLICY

My Code Media, Inc. and its affiliates (collectively, “My Code,” “Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. Please read this Privacy Policy carefully to learn how we collect, use, share, or otherwise process your information (“personal information”), and to learn about your rights and choices regarding your personal information.

This Privacy Policy describes our information practices when you use any applications (“App(s)”) or websites (“Sites”) operated by My Code and its affiliates that link to this Privacy Policy (collectively, “Service(s)”).

1. INFORMATION WE COLLECT

We may collect various types of information when you use our Services. The information we collect may include personal information that you may choose to provide us and non-personal information that does not directly identify you, such as usage data, preferences and other anonymous information.

Information You May Choose to Provide to Us

You may provide us with personal information that can be used to identify you, such as your name, email address, postal address, phone number, and other similar data. For example, you may provide us with your name and contact information (such as an email address), date of birth, or other details of that nature, when you sign up for our newsletters, participate in contests, sweepstakes, or other promotions on the Services, or inquire about advertising, recruiting, media inquiries, research or publishing support services.

The categories of information include:

• Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

• Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state
  identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

• Characteristics of protected classifications under federal law – such as race, color, national origin, religion, gender (including pregnancy), disability, age (if employee is at least 40 years old), and citizenship status – or under California law – such additional categories as ancestry, medical condition, marital status, age, or sexual orientation.

• Commercial information, such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

• Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement

• Geolocation data.

• Audio, electronic, visual, thermal, olfactory, or similar information.

• Professional or employment-related information.

• Education information.

• Inferences drawn from the above categories of information.

The categories of sensitive information include:

• Social security, driver’s license, state identification card, and passport number.

• Account log-in, financial account, debit card, or credit card number, in combination with any required security or access code, password, or credentials allowing access to the
  account.

• Precise geolocation data.

• Racial or ethnic origin, religious or philosophical beliefs, or union membership.

• Contents of mail, email, and text messages, unless we are the intended recipient of the communication.

• Genetic data.

• Processing biometric information for the purpose of uniquely identifying you.

• Information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.

Information That Is Automatically Collected

• Sites: Like many website operators, we collect information that your browser sends whenever you visit our Sites. This includes log data, such as your computer’s IP address, browser type, browser version, the pages of our Sites that you visit, the time
  and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them. Learn more in our Cookie Policy.

• Apps: Certain information may be automatically collected as you use the App, including, but not limited to, the operation system used by your device, your device type and ID, your IP address, and your access times.

Information We Obtain From Other Sources

We may supplement the information we collect with information from third-party partners and service providers, including data brokers, customer acquisition vendors, and other companies that collect contact and consumer information such as demographic and interest data, in order to learn more about our users, better tailor the content and offers we make available to you, and for other lawful business purposes. We may combine the information we receive from those other (online and offline) sources with information we collect through the Services.

Social Network and Platform Integration

The Services may be integrated with social media networks and other platforms whereby information may be shared between us and those platforms. For instance, if you interact with our Services through a social media feature such as a plug-in, then you may be granting us on- going access to certain information from that social media account. If you do not want a social media platform to collect or share information about you, please review the privacy policy and privacy settings of the applicable social media property before using such features on our Services.

2. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

• To provide you with our Services, which includes: maintaining and servicing accounts, providing customer service, processing and fulfilling orders and transactions, verifying customer information, processing payments, providing financing, and providing advertising or marketing services to you.

• To provide analytic services, such as analyzing customer usage and improving services offered.

• To conduct market research and project planning.

• To detect security incidents, protect against fraudulent or other criminal activity, debug and repair errors, and maintain the overall quality and safety of our Services.

• To share your website visitor activity, through website cookies, with third-party marketing partners to market our services on our Services and other websites that you may visit.

•  To fulfill our legal and financial obligations.

•  To provide you with employment opportunities.

Marketing: We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Information” section below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).

3. HOW WE SHARE YOUR INFORMATION

To Users or the Public with Your Consent: We may share your information with other users or the public with your consent.

Affiliates and Service Providers: We share your information with our third-party service providers and any subcontractors as required to offer you our products and services. The service providers we use help us to:

• Run, operate, and maintain our Services through third-party platforms and software tools;

• Perform content moderation and crash analytics;

• Run email and mobile messaging campaigns;

• Perform game and marketing analytics;

• Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);

• Administer live events, competitions, sweepstakes, and promotions, including registering attendees, managing check-in and attendance, verifying eligibility and prize fulfillment;

• Provide payment attribution; and,

• Provide technical and customer support.

• Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.

Aggregated Data: We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. This data does not personally identify you and helps us to measure the success of our Services and its features and to improve your experience. We reserve the right to make use of any such aggregated data as we see fit.

Third Party Marketing and Advertising Organizations: With respect to website cookies, we share your information with third-party marketing and advertising partners to market our services on our Services and other websites that you may visit. Learn more in our Cookie Policy.

Disclosures Required by Law: We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your personal information to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

4. HOW WE USE COOKIES AND RESPOND TO ‘DO NOT TRACK’ SIGNALS

Do Not Track: Some browsers provide you with a way to signal that you do not want your browsing activity to be tracked. The Services may not currently respond to all Do Not Track (“DNT”) or similar signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of DNT and the best way to respond to these signals.

Cookies: To make our Sites and Services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, shopping cart, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the site or browse from one page to another. Learn more in our Cookie Policy.

Google Analytics: We may use Google Analytics. We use the information we get from Google Analytics only to improve the Services. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out
browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our Services may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

• Cookie settings in Chrome

• Cookie settings in Firefox

• Cookie settings in Microsoft Edge

• Cookie settings in Safari web and iOS

5. HOW WE RESPOND TO USERS UNDER 18 YEARS OF AGE

Our Services are not directed at individuals under the age of 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information, please contact us using the contact details provided below. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information.

6. HOW WE SECURE AND RETAIN YOUR INFORMATION

Data Security: We take the security of your information seriously and implement appropriate measures to protect it from unauthorized access, alteration, disclosure, or destruction. We implement a variety of security measures to maintain the security of users’ personal information.

We offer the use of a secure server. Any sensitive data supplied, such as credit card information, is transmitted through Secure Socket Layer (SSL) and, upon payment, is encrypted through our database providers, accessible only by authorized persons and with special rights of access to the mentioned systems, which are also obliged to keep the information confidential. After a commercial transaction, users’ private information (credit cards, social security numbers, bank information, etc.) will not be stored on our servers.

However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of personal information obtained through the Services, we cannot ensure or warrant the security of any information you transmit to us.

Data Retention: We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted
by law. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

7. HOW A CHANGE IN CONTROL MAY AFFECT YOUR INFORMATION

Personal information may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of the business, part of the sale may include your personal information.

8. HOW WE MAY UPDATE THIS PRIVACY POLICY

This policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting personal information to our Services. The date the Privacy Policy was last updated is indicated at the top of this page.

9. CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or the use of your personal information, please contact us at [email protected].

You may also write to:
My Code Privacy
401 Wilshire Blvd Suite 920, Santa Monica, CA 90401

10. PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES FOR EEA AND UK INDIVIDUALS

Lawful Bases for Processing (EEA and UK Individuals). If you are from the European Economic Area (EEA) or United Kingdom (UK), our legal bases for collecting and using your
personal information is as follows:

• The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration.

• Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and services, direct marketing to you, and improvement of our services.

• Compliance with a mandatory legal obligation. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your Personal Information to record your requests to exercise your rights and to verify your identity for such requests.

• Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.

• In some limited cases, we may also have a legal obligation to collect personal information from you in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in the “How We Share Your Information” section.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided above.

EEA or UK Individuals’ Rights: If you are from the EEA or UK, you have the right, under certain circumstances, to:

• Access your personal information;

• Correct inaccurate information in your personal information;

• Request erasure of your personal information without undue delay;

• Request restriction of, in certain circumstances, the processing of your personal information;

• Request receiving a portable copy of your personal information held by us, and to have that portable copy transmitted to another controller; and

• To object to the processing of your personal information.

To exercise any of these rights, contact us using the contact details provided above, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor
your request.

International Transfers of Data: Any data that you provide to us may be accessed, shared, or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract). This may entail the transfer of your personal information across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction. We maintain appropriate safeguards as required by applicable law for any personal information transferred internationally, and as required by applicable law, will seek your consent prior to such transfers.

Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.

11. PRIVACY RIGHTS AND ADDITIONAL DISCLOSURES FOR CERTAIN U.S. RESIDENTS

Several U.S. jurisdictions grant state residents certain rights and disclosures. We provide the following information to further help you understand your potential privacy rights. If you would like to exercise any rights or inquire as to whether such rights are available to you, please email us at [email protected].

Request for Information or Deletion: Residents of certain U.S. states have the right to know whether we are processing your personal information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide to you:

• The categories of personal information we collect about you.

• The categories of sources from which your personal information is collected.

• The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your personal information, and the categories of personal information disclosed for such purpose(s).

• The categories of third parties with whom we share your personal information.

• The categories of personal information we have sold, if any, about you and the categories of third parties to whom your personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.

• The specific pieces of personal information we have collected about you.

In addition, you may have the right to request we delete your personal information.

Request for Correction: Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in the resident’s personal information.

Request for Portable Data: Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their personal information that allows the data to be transmitted to another entity.

Do Not Sell or Share My Personal Information: Residents of certain U.S. states have the right to opt out of the sale or sharing of the consumer’s personal information. However, we do not sell your personal information, nor do we share your personal information to provide personalized or targeted advertising. If you have any questions or further comments on the matter, please reach out to us via the contact information in this Privacy Policy.

Limiting the Use of Sensitive Personal Information:  Residents of California have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive personal information for any purpose other than providing our goods and services to you, or as otherwise minimally permitted under applicable law.

Third Party Marketing: If you are one of our customers, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information to third parties for the third parties’ direct marketing purposes. However, we do not disclose your personal information to third parties for the third parties’ direct marketing purposes.

Automated Processing and Profiling: Residents of certain U.S. states have the right to opt out of the processing of personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Right to Equal Service and Price: You have the right to receive equal service and price, even if you exercise a privacy right.

Verification Process for Exercising Rights: To protect our consumers’ privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information in this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process: If we do not decide to act in response to your request to exercise a right, we will provide a timely response detailing the reasons for not taking the action and, depending on your jurisdiction, any rights that you may have to appeal our decision.