We at Show recognize and respect the importance of maintaining the privacy of our users. If you are a user from outside the United States Personal Data is collected by Show Advertising Ltd. If you are a user in the US, Personal Data is collected by Show Advertising Inc. (collectively “Show”, “us”, “our”, or “we”). This Privacy Notice describes the types of information we collect from you when you use our Platform or the Services available thereon as a Streamer or an Advertiser. This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in the Terms of Service, available at http://show.gg/tos/ (“Terms”). “You” means any adult user of the Platform and/or Services as a Streamer or on behalf of an Advertiser.
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If you are an individual located in the European Union (“EU Individual“), some additional terms and rights may apply to you, as detailed herein. Show is the data controller in respect of the processing activities outlined in this Privacy Notice. Our registered office is Halamish 14, Caesarea, Israel and our company number is 516455243.Â
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If you are an individual who is a resident of the State of California, some additional terms and rights may apply to you, as detailed in the Supplemental Privacy Notice for California Residents available below.Â
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“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data is collected by us in connection with provision of the Services.Â
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Privacy Notice Key PointsÂ
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The key points listed below are presented in further detail throughout this Privacy Notice. You can click on the headers in this section in order to find out more information about any topic. These key points do not substitute the full Privacy Notice.    Â
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Personal Data We Collect, Uses and Legal Basis. Â
Additional Uses. Â
Sharing the Personal Data We Collect. Â
International Transfer. Â
Security. Â
Your Rights – How to Access and Limit Our Use of Certain Personal Data. Â
Data Retention. Â
Third-Party Applications and Services. Â
Communications. Â
Children. Â
Changes to the Privacy Notice. Â
Comments and Questions. Â
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Personal Data We Collect, Uses and Legal Basis. Depending on your usage, we collect different types of data and we and any of our third-party subcontractors and service providers use the data we collect for different purposes, as specified below. You have no legal obligation to provide us with certain Personal Data, but if you refuse to provide such Personal Data, we may not be able to register you to the Platform and/or provide you with the Services or part thereof.Â
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Registration Data – Â
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In order to use our Platform as a Streamer and/or receive related Services, you will be required to register. You can register by providing us with your email address or by using your Twitch account. We receive certain Personal Data about you as available through your Twitch account, such as your profile information and emails. Â
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If you are using the Platform on behalf of an Advertiser, the Advertiser will be required to enter into a services agreement with us (“Advertiser Agreement“) and to provide us with the name and email address of a designated contact person. Â
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How we use this data: (1) to provide you with the Platform and/or Services and to respond to your inquiries and requests and to contact and communicate with you; and (2) to prevent fraud, protect the security of and address any problems with the Platform, and to provide you with promotional materials relating to our Platform and Services, including via email. For more information about our direct marketing activities and how you can control your preferences, please see the Direct Marketing section below. Â
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Legal Basis: (1) We process this Personal Data for the purpose of providing the Services to you in accordance with the Terms or Advertiser Agreement, as applicable, which is considered performance of a contract with you, including responding to your inquiries and requests and providing customer support. (2) When we process your Personal Data for the purposes of preventing fraud, protecting the security of and/or addressing problems with the Platform and Services and/or for the purpose of providing you with promotional materials relating to our Services, such processing is based on our legitimate interests.Â
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Payment Data – In order to transfer payments to you, you will be required to provide certain information about your bank account.Â
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How we use this data: To transfer payments to you.Â
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Legal Basis: We process this Personal Data for the purpose of performance of a contract with you when we transfer payment. Â
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Contact Information – When you request information from us, or contact us for any other reason, we will collect any data you provide, such as your email address and the content of your inquiry. Â
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How we use this data: To respond to your request or inquiry.Â
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Legal Basis. We process this Personal Data based on performance of a contract when we respond to your inquiry.Â
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Videos – If you are a Streamer, we collect records of the videos you stream in which Ads are placed.Â
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How we use this data. To provide you with the Services and to analyze your reactions to the Ads being placed in order to improve the Services generally and for the purpose of marketing our Platform.Â
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Legal Basis. When we process this data in order to provide you with the Services, we do so for the purpose of performance of a contract with you. When we process this data for purposes of analysis and improvement and marketing of our Services, we do so based on our legitimate interest.Â
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Additional Uses. Â
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Statistical Information and Analytics. We and/or our service providers use analytics tools, including “Google Analytics” to collect and analyze information about the use of the Site and/or Services, such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users, which helps us improve our Site and Services, understand trends and customer needs and consider new products and services, and tailor existing products and services to customer desires. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.  Â
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Direct Marketing. As described above, we may use Personal Data to let you know about our products and Services that we believe will be of interest to you. We may contact you by email or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect privacy rights and to ensure you have control over how we manage marketing with you:Â
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We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.Â
At any time you can change your preferences for the way in which you would like us to communicate with you, including how you receive details of latest offers from us. Â
You can ask us to stop sending email marketing by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact us at coo@show.gg. Â
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We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us and your Twitch account.Â
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Sharing the Personal Data We Collect. We share your information, including Personal Data, as follows:Â
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Affiliates. We share information, including your Personal Data, with our affiliated companies, Show Advertising Ltd. where this is necessary to provide you with our products and Services, and for the purpose of management of our business.Â
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Advertisers. If you are a streamer, information about your activities on Twitch will be made available to Advertisers as part of the Service.Â
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Service Providers, and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Platform and/or Services; (2) aid in their understanding of how users are using our Platform and/or Services; (3) for the purpose of direct marketing (see above for more details).Â
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Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, data analysis and help us show Advertisements and provide us with marketing services.Â
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Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.Â
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Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation. Â
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Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements. Â
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Other Uses or Transfer of Your Personal Data. We may receive information (including Personal Data) about you from Twitch. Please note that Twitch’s terms privacy policies will govern this sharing of Personal Data.Â
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International Transfer.Â
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We use subcontractors and service providers and have affiliates who are located in countries other than your own, such as Israel and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Notice, including appropriate remedies in the event of the violation of your data protection rights in such third country. Â
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Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (“EEA“) and when required under applicable law, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:Â Â
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We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. Â
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Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA. Â
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Please contact us at coo@show.gg if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA. Â
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Security. We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:Â
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Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, firewalls, antivirus, and SSL encryption of data. Â
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Access Control – We dedicate efforts for a proper management of system entries and limit access only to authorized personnel on a need to know basis of least privilege rules, review permissions quarterly, and revoke access immediately after employee termination. Â
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Internal Policies – We maintain and regularly review and update our privacy related and information security policies. Â
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Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice. Â
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Encryption – Data is SSL encrypted in transit. Â
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Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel. Â
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However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.Â
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As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information. Â
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Your Rights – How to Access and Limit Our Use of Certain Personal Data. Subject to applicable law and certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:Â
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Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.Â
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Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format. Â
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Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data. Â
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Deletion of Personal Data (“Right to Be Forgotten”). If you are an EU Individual, you have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (v) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should terminate your account with us. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law. Â
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Right to Restrict Processing. If you are an EU Individual, you can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.Â
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Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us at coo@show.gg. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.Â
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Right to Object. If you are an EU Individual, you can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.Â
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Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent. This will not affect the lawfulness of any processing prior to such withdrawal. Â
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Right to Lodge a Complaint with Your Local Supervisory Authority. If you are an EU Individual, you may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first.Â
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Data Retention.  Â
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Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor’s retention policy. Â
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In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.Â
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Please contact us at coo@show.gg if you would like details regarding the retention periods for different types of your Personal Data. Â
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Third-Party Applications and Services. All use of third-party applications or services is at your own risk and subject to such third party’s terms and privacy policies. Â
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Communications. We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account. Â
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Children. We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately. Â
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Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on the Platform or via email. Â
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Comments and Questions. If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at coo@show.gg. Â
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Last updated: September 2022Â
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Supplemental Privacy Notice for California Residents Â
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This Supplemental Privacy Notice for California Residents (“CA Supplement“) supplements and forms an integral part of our general privacy notice, available above (“Privacy Notice“). This CA Supplement describes how we collect, share, and store personal information about California residents who use our Platform and/or Services, as well as the rights they have with respect to that information. If not otherwise defined herein, capitalized terms have the meaning given to them in our Privacy Notice. Please read the Privacy Notice for additional terms that may apply to you.Â
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“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise may be defined by applicable law. Â
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Depending on your usage, we collect different types of information and we and any of our third-party sub-contractors and service providers use the information we collect for different purposes, as specified below. Â
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This CA Supplement will cover the following topics:Â
Categories of Personal Information We CollectÂ
How We Share Your Personal InformationÂ
Your Rights – How to Access and Limit Our Use of Certain Personal Information Â
How to Contact UsÂ
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Categories of Personal Information We Collect. In the past twelve months, we have collected the following Personal Information from Streamers who are using our Platform and/or Services. This Personal Data is used for the purposes described in the Privacy Notice.Â
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Registration Information. In order to use our Services as a Streamer, you will be required to register and provide us with the following identifiers directly: your email address. If you use the Services by logging in through your Twitch account, we also receive certain identifiers about you indirectly as provided by such third-party service, such as your profile information and emails. When registering for the Services on behalf of an Advertiser, we will receive the following identifiers of the Advertiser’s contact person indirectly, as provided by the Advertiser: name and email address.Â
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Payment Information. We may collect your bank information in order to allow us to transfer payments to you. Additionally, you may be directed to a third-party payment processor in order to make payments to us, in which case, we receive certain identifiers from such payment processor, such as the last four digits of your credit card numberÂ
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Contact Information. If you contact us, we collect certain identifiers directly from you, such as your name, email address, and the content of your message.Â
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Video Information. We automatically collect records of the videos that you stream.Â
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How We Share Your Personal Information. Â
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Sharing for Business Purposes. In the past 12 months, we have disclosed the following categories of Personal Information for the following business or purpose in the preceding 12 months: we have shared your personal identifiers and internet or other electronic network activity with data analytics providers, Advertisers, operating systems, and other third parties that assist us in providing you with the Services, including providing us with IT and system administration services, data backup, security, and storage services.Â
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Additional Sharing Activities.Â
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Affiliates. We share information, including your Personal Information, with our affiliated company, Show Advertising Ltd., where this is necessary to provide you with the Platform and Services, and for the purpose of management of our business.Â
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Business Transfers: Your Personal Information may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such a case, your Personal Information shall continue being subject to the provisions of this CA Supplement.Â
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Law Enforcement Related Disclosure: We may share your Personal Information with third parties: (i) if we believe in good faith that such disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement of the Terms, the Privacy Notice, and this CA Supplement); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation. Â
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Other Uses or Transfer of Your Personal Information: If you use our Services together with or through a third-party service, site and/or mobile application, we may receive information (including Personal Information) about you from those third parties. Please note that when you use third parties outside of our Platform or Services, their own terms and privacy policies will govern your use of those services.Â
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Your Rights – How to Access and Limit Our Use of Certain Personal Information. Subject to certain exemptions, you have certain rights in relation to the Personal Information that we have collected about you, as detailed below. In accordance with applicable law, we may ask for reasonable evidence to verify your identity before we comply with certain of your requests, as detailed below. Â
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Your RightsÂ
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Right of Access. You have the right to request that we disclose to you any or all of the following in respect of the 12-month period preceding your request:Â Â
The specific Personal Information we have collected about you. Â
The categories of Personal Information we have collected about you. Â
The categories of sources from which we collected the Personal Information about you. Â
The categories of third parties with whom we share Personal Information about you. Â
The categories of Personal Information about you we have sold and the categories of third parties to whom we have sold such Personal Information.Â
The categories of Personal Information about you we have disclosed for a business purpose and the categories of third parties to whom we have disclosed such Personal Information. Â
Our business or commercial purpose(s) for collecting or selling your Personal Information. Â
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Right to Delete. Subject to certain exceptions, you have the right to request that we and any of our service providers delete your Personal Information.Â
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Right to Correct. If you find that any of the we’ve collected about you is inaccurate, you have the right to correct such information.Â
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Right to Opt-Out of the Sale of Personal Information. If you are 16 years of age or older or have opted-in to the sale of your Personal Information, you have the right to direct us to not sell your Personal Information at any time. You may change your mind and opt back into the sale of your Personal Information at any time by contacting us at the address above. We may deny any request to opt-out of the sale of Personal Information that we deem in our good-faith, reasonable and documented belief is fraudulent.Â
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Right to Non-Discrimination for Exercising your Consumer Privacy Rights. You have the right not to be discriminated against for exercising any of your consumer privacy rights, such as, not being denied any goods or services or charged different prices or rates. Â
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How to Exercise your California Privacy RightsÂ
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Contact Information. To exercise any of the rights detailed above, please submit a verifiable request to us by contacting us at privacy@show.gg    . You may only request to exercise your right of access twice within a 12-month period.Â
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Submitting a Verifiable Request: In order to exercise your right to know or right to delete you must submit a request containing sufficient information that allows us to reasonably verify you are the person about whom we collected the applicable Personal Information or an authorized agent of such person, which may include details relating to your account. Any requests made through your password protected account will be verified through our existing authentication procedures for such account. Â
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Submitting Requests through an Authorized Agent: An authorized agent may exercise requests on your behalf. In order to exercise your right to know or right to delete through an agent, we may ask for reasonable evidence to verify your identity and the agent’s identity, and written authorization permitting the agent to act on your behalf before complying with your request. In order to submit a request to opt-out of the sale of your Personal Information through an agent, we may ask for written authorization permitting the authorized agent to act on your behalf before complying with your request. We reserve the right to deny the request of any agent that does not provide proof that they have been authorized to act on behalf of the applicable consumer in accordance with applicable law. Â
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Children. We do not knowingly sell the Personal Information of California residents under 16 years of age.Â
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How to Contact Us. If you have any comments or questions about this CA Supplement or our privacy practices, or if you wish to exercise any of your legal rights as set out herein, please contact us at privacy@show.gg.Â
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Last updated: September 2022Â
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