Givng Privacy Policy

Effective as of: 14 September 2023

We are Givng. We are gamifying giving, where your kindness earns points that can be redeemed for rewards. Protecting your privacy is really important to us. We only use your information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you play any of our games or use any of our apps, use our websites, buy merchandise from us, or take part in live events and promotions (the "Services").

Our Privacy Policy is designed to give you a comprehensive understanding of the steps that we take to protect the personal information that you share with us, and we would always recommend that you read it in full.

You should also read our Terms of Service which set out the contract between you and Givng when you use our Services.

1. Who decides how your information is used?

Givng, LLC (75 PORTSMOUTH BLVD STE 110, PORTSMOUTH, NH 03801) generally is the data controller responsible for making decisions about how we use your personal information.

If you have any questions or comments on this policy, you can:

Email us at privacy@givng.co

2. The information we collect about you and how we use it

This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").

We need to collect and use certain Personal Data to provide the Services to you and fulfill the promises we make to you in the Terms of Service:

Some of our Services require you to register with us or sign up for an account before you can use them. Where this is the case, you provide us with information including your age and the in-app username that you choose to use on our Services. We collect and use this information in order to authenticate you when you register an account and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services.
You may be required to have an account with a supported external single sign-on service in order to use some of our Services. Where this is the case, the Personal Data we collect also depends on which external accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access Givng.
- If you choose to link your Google account to the Services, we will collect your Google email address and an authentication token provided by Google.
- If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and, if permitted by you, your Facebook registered email address.
- If you choose to link your Apple account to the Services, we will collect your email address on file with your Apple ID account or a private relayed email address if you use the Hide My Email option provided by Apple.
Depending on the particular Service you sign up for, we may support other external single sign-on services and collect additional Personal Data from them. Some external providers may notify you that they make additional information, such as your public profile, available to us when you use their single sign-on services. We do not collect that information from them.
If you elect to use your Givng Profile in connection with a third-party developer service (a “Connected Service“), we may collect the Personal Data outlined above.
We collect and use your device location information as you use our Services (and, if you elect to turn on background location tracking for participating Services, while you are not directly interacting with these Services), including how you move around and events that occur during in app activity or gameplay. Our Services include location based games whose core feature is to provide an experience tied to your real world location, so we need to know where you are to operate these apps and games for you, and to plan the location of in-game resources. We identify your location using a variety of technologies, including GPS, the WiFi points you are accessing the Service through and mobile/cell tower triangulation.
We also collect and use your in-game or in-app actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings, and information about third-party applications or software installed on your device), to operate the Services for you and to personalize your gameplay and user experience. We will also generate an internal account ID when you use certain Services to associate you with an account.
We also use the information above to show in-game sponsored locations that are in your vicinity as part of the gameplay experience.
We further use the information above in order to provide technical and customer support to you.
You also give us Personal Data when you subscribe to our publications, register for a live event, enter a competition, promotion, sweepstakes or survey or communicate with us. Depending on which of these Services you use, that may include your name, mailing address, phone number, country of residency, age, and email address. We use that information to fulfill those Services to you and to provide related customer support to you.

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

Using your IP address, browser type, operating system, the web page you were visiting before accessing our Services, the pages of our Services which you browsed or the features you used, and the time spent on those pages or features, the links on our Services that you click on, device and advertising identifiers, age, gender, as well as actions you take during gameplay, your in-app user settings, preferences (including avatar characteristics), and your in-app purchases to learn about our users, and understand who is using our Services and how.
Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.
Using your internal account ID and in-game username in order to attribute to your account any user content (such as local points of interest) that you elect to submit to Givng through the Services. You can choose to opt out of having your in-game username attributed on the leaderboard by emailing: privacy@givng.co.
Using your email address and device information in order to share updates and news with you either within the apps or by email. You can unsubscribe from these at any time in your device settings or in-app settings.
Analyzing your in-game actions and achievements to show you rewards, promotions, or other offers about our Services that are tailored to your personal user experience. You can choose to opt out of this and certain other processing of your Personal Data by following the steps described in Section 7 (“Your rights and choices”).
To personalize the ads you see in our apps to make them more relevant to you and to show sponsored gifts based on where you are containing messages and/or offers from our advertisers relevant to your vicinity on the game map. You can choose to opt out of receiving sponsored gifts by visiting the in-app settings. You can choose to opt out of personalized advertisements by visiting the settings on your device and turning off “Allow Apps to Request to Track” or activating “Limit Ad Tracking” on Apple devices, or activating “Opt-out of Interest Based Ads” on Android devices.
We collect content you provide such as images, text, and/or video to provide social features within our games and apps so you can interact and play with other players, including storing your communications, content, and other information shared with those players, finding your friends and being found by them, including through imported contacts, and sharing your gameplay or in-app experience and achievements with your friends or other players. You can visit your Givng Profile or in-app settings for opt-out options. We may monitor and moderate content you provide to our Services to protect Givng, or to protect the rights and safety of others.
To improve the features that we offer you through the Services, or to provide you with new or additional features for our Services.
To organize and run live events based on or featuring our games. Note that when you participate in live events your in-game actions and achievements, in-game username and your avatar, team, and other components of your in-game profile will be visible to other event participants and to the public (for example on leaderboards displayed at the event and online).
Using your in-app actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings, and information about third-party applications or software installed on your device), to carry out anti-fraud and anti-cheating measures against behaviors prohibited under our Terms of Service, to prevent abuse, and to provide a fair gaming experience to all players.
To make legal or regulatory disclosures and to establish, exercise, or defend legal claims.

We will only use your Personal Data to do the following if we have your consent:

If you elect to import your device’s address book contacts to find out which of your contacts uses our Services and to send them Friend requests, or invite them to join you in our games, apps or other aspects of our Services, we will periodically sync your contacts’ information, including phone number, and email, to our servers. You are responsible for ensuring your collection and sharing with us of your contacts’ information is compliant with applicable laws. This may require you to obtain your contacts’ permission. We may also get information about you from other Givng users importing or entering their contacts. We use and may store this contact information to help you and your contacts connect through our Services. You can change your mind and turn off Givng access to your contacts at any time in your device settings.
If you elect to upload content, such as photos or videos from your mobile device, into our Services, we will, with your permission, access your device’s media storage. You can change your mind and disable access to your media storage at any time in your device settings.
Send you marketing materials by email or via in-app notifications. You can unsubscribe from these at any time in your device settings or in-app settings.

We also rely on your consent where we use cookies or similar technologies. Please see our Cookie Policy below for more information about how we use them. Insofar as cookies collect Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a pseudonym.

While you may disable the usage of cookies through your browser settings, Givng currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to the lack of industry standard on how to interpret that signal.

3. Who we share information with

We will not share any Personal Data that we have collected from or about you except as described below:

Information Shared with Our Service Providers. We engage external Service Providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These external Service Providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The Service Providers we use help us to:

run, operate, and maintain our Services through third-party platform and software tools;
perform content moderation and crash analytics;
run email and mobile messaging campaigns;
perform game, app, and marketing analytics;
to provide measurement services and target 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 players, managing check-in and attendance, verifying eligibility and prize fulfillment;
provide payment attribution;
provide technical and customer support; and
process payments for live events ticketing or other purchases.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) as a Third-Party Service in accordance with their own privacy policy. Such external Third-Party Service does not share your financial information, like credit card number, with Givng, but it may share limited information with us related to your purchase, like your zip or postal code.

Information Shared with Other Players or Users. When you use the Services, and in particular when you play our games, use social features within those games (including cross-game features), or take part in live events, we will share certain Personal Data with other players or users. This Personal Data includes your in-game or in-app profile (such as your username, your avatar, your online status, and your team), your in-game or in-app actions and achievements, real-world locations associated with your gameplay, or which gameplay resources you interacted with when playing the game , and your in-game messages and related content you share with other players or users. Additionally, certain games or apps link to third-party sharing features on your device that you can use to disclose Personal Data to others outside the Services; Givng does not control and is not responsible for the practices of these third-party sharing features.

Information Shared Publicly: When you use the Services, and in particular when you play our games, use competitive features, or participate in our forums, the following information about you may be shared on web pages accessible to the public and therefore become publicly available: your username, in-game or in-app profile, achievements, and public messages.

Information Shared with Third Parties. We share Anonymous Data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with any other third parties for their direct marketing purposes.

Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; or (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third-party acquirer in connection with the transaction.

4. How your Personal Data is transferred

Givng operates its Services across the globe. Your Personal Data will likely be transferred and stored in a country outside of your home country, including in the USA, for the purposes outlined in this Privacy Policy to the extent permitted by applicable laws. The data protection laws in these countries may not be the same as in your home country.

If we transfer your Personal Data from the UK or the EEA to other countries, including the USA, we ensure that a similar degree of protection is provided to your Personal Data as within the UK or the EEA, as applicable, by ensuring that at least one of the following safeguards is implemented:

The country that your Personal Data is transferred to is a country that the European Commission (or the UK Government, if you are based in the UK) has deemed to provide an adequate level of protection for Personal Data as the UK or the EEA, as applicable.
We use specific contracts approved by the European Commission (or the UK Information Commissioner’s Office, if you are based in the UK), which give Personal Data the same protection as it has in the UK or the EEA, as applicable, when we engage with service providers.

5. How we keep your Personal Data safe

We have appropriate legal, organizational and technical security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. How long we will keep your Personal Data

We keep your Personal Data for as long as we need to provide the Services to you and fulfill the purposes set out in this Privacy Policy. This is also the case for anyone that we share your information with and who carry out services on our behalf.

When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it so that it can no longer be associated with you. When removing Personal Data, we will take commercially reasonable and technically feasible measures to make said Personal Data irrecoverable or irreproducible.

7. Your rights and choices

You have certain rights in relation to your Personal Data. This means you can:

Request access to the Personal Data we hold on you by emailing privacy@givng.co.
Delete or correct your Personal Data. The easiest way to update your account information is via your in-app settings. You can also submit a customer support request through our support support@givng.co or email us at privacy@givng.co.
Ask us to stop processing your Personal Data, including for direct marketing and promotional purposes such as tailored rewards, promotions, and other offers, by emailing privacy@givng.co. But be aware that sometimes we need to use your Personal Data in order to provide the Services to you.
Have your Personal Data transferred to another organization (where it is technically feasible).
Complain to a regulator. We'd appreciate the chance to deal with your concerns directly so we'd prefer you to contact us first. However, if you're based in the UK or the EEA and believe that we have not complied with data protection laws, you can complain to your local supervisory authority.
If you’re based in the EEA, you can also contact our EU Representative, EDPO. EDPO can be contacted:
- by using EDPO’s online request form: https://edpo.com/gdpr-data-request/
- by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

The law provides exceptions to these rights in certain circumstances. Where you cannot exercise one of these rights due to such an exception, we will explain to you why.

We offer you choices regarding the collection, use, and sharing of your Personal Data and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.

After you contact us, you may receive an email in order to verify your request. We aim to provide the information or complete the outcome you request within 30 days, or such shorter time period as provided by laws of your jurisdiction.

8. Children

Unless stated otherwise for a particular Service, children are not allowed to use the Services, and we do not knowingly collect Personal Data from them. We define “children” as follows:

Residents of the UK: anyone under 13 years old.
Residents of the EEA: anyone under 16 years old, or the age needed to consent to the processing of personal data in your country of residence.
Residents of the Republic of Korea, anyone under 14 years old.
Residents of other regions: anyone under 13 years old or the age needed to consent to the processing of personal data in that region.

For Services that do permit Child participation, parents or legal guardians ("Parents") must provide verified consent. Verifiable parental consent is required for the collection, use, or disclosure of a child's Personal Data. Givng will not collect, use, or disclose any Personal Data from a child if their parent or guardian does not provide such consent. We may ask a Child to provide a Parent’s email address in order to request this consent, and the Parent’s email address will be deleted if consent is not provided within a reasonable time.

9. Changes to this Privacy Policy

Any Personal Data that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may make changes to this Privacy Policy from time to time. You will be given reasonable notice of any material change.

10. Third Parties

In using our Services you may access links to websites and services that are owned or operated by third parties (each, a “Third-Party Service“). Any information that you provide on or to a Third-Party Service or that is collected by a Third-Party Service is provided directly to the owner or operator of the Third-Party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third-Party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-Party Services that you access.

11. Disclosures Specific to California Residents

California law requires that we make certain disclosures about your data. The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (“CCPA”).

Collection and Use of Personal Data

In the preceding 12 months, we have collected the following categories of Personal Data: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information. To learn more about the specific information we collect, the sources and purposes of such collection, please see Section 2 (“The information we collect about you and how we use it”).

Sale or Sharing of Personal Data

We do not sell or share your Personal Data as those terms are defined under the CCPA. Givng has no actual knowledge of selling or sharing the personal information of minors under 16 years of age.

Disclosure of Personal Data for a Business Purpose

In the preceding 12 months, we have disclosed for a business purpose the following categories of Personal Data: identifiers, commercial information, Internet or other electronic network activity information, geolocation data, and visual information. To learn more about the disclosure of your Personal Data, please see Section 3 (“With whom we share information”).

Your CCPA Rights

Right to Know and Access Personal Information

You have the right to request the categories and specific pieces of personal information we have collected about you.

Right to Delete Personal Information

You have the right to request the deletion of your personal information, subject to certain exceptions.

Right to Correct Inaccurate Personal Information

You have the right to request the correction of any inaccurate personal information that we maintain about you.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not collect or process sensitive personal information for the purpose of inferring characteristics about you. We also do not disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the California Privacy Rights Act regulations promulgated by the California Privacy Protection Agency. Therefore, we do not offer you the option to limit the use of your sensitive personal information.

Right to Opt Out of Sale or Sharing

Under California law, consumers have the right to opt out of the sale or sharing of their personal information. Because we do not sell or share data for this purpose, we do not offer this opt out.

Right of Non-Discrimination

You have the right to exercise the privacy rights conferred to you under the CCPA without receiving discriminatory treatment. We do not discriminate against you for exercising the privacy rights conferred to you under the CCPA.

12. Exercising Your Rights

You may exercise these rights by reviewing Section 7 (“Your rights and choices”) of this Privacy Policy.

If you authorize another person to submit a request to know, correct, or delete on your behalf, we may ask you to verify your identity or to confirm that you authorized another person to make such request on your behalf. Separately, such other person may have to submit proof that they are authorized to make a request on your behalf.

Givng Cookies Policy

Effective as of: October 14, 2019

We are Givng, Inc. Our games and websites (“Services”) use cookies, which are small text files that are placed on your computer or device by a Web server when you access our Services. We may place and access cookies and similar technologies on your computer or device, which are known as “first party cookies”. Cookies may also be placed and accessed by third parties, which are known as “third party cookies” and are described below.

We use cookies and local storage to monitor aggregate usage and web traffic of our Services, customise and improve our Services, help you navigate our Services, deliver content specific to your interests and deliver advertisements to you.

We also use “web beacons” (also known as web bugs, pixel tags, or clear GIFS) which are small graphics with a unique identifier that may be included on our Services for example to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on a user’s hard drive or device, web beacons are typically embedded invisibly on web pages (or in an email).

Types of Cookies

We use the following types of cookies:

Strictly Necessary Cookies: These are cookies that are essential to enable you to use the Services, for example moving around our websites and using their features (e.g. cookies that enable you to log into the Services).
Performance Cookies: These are cookies which collect information about how and when you and other visitors interact with our Services (e.g. pages viewed most often) and the information collected by these cookies is used to improve how our Services work.
Functionality Cookies: These are cookies that allow our Services to remember choices you have made (such as your login information) and provide you with content and features which are customised to you. For example, providing you with relevant content by using a cookie to remember which region you are in.
Advertising Cookies: These are cookies which are used to deliver adverts to you which are more relevant to you and your interests. We may also share this type of information with third parties for these purposes.

The types of cookies described above may be “session cookies” or “persistent cookies”. Session cookies are only stored on your device whilst you are using the Services, and are deleted when you log off from the Services or close your browser. Persistent cookies remain on your device for a period of time after you log off from the Services or close your browser.

Third Party Cookies

Some cookies may be placed by third parties when you use the Services as some third party service providers that we engage (including third party advertisers) may place their own cookies on your hard drive or device. These cookies may provide information to those third parties about your browsing habits or may be used for security. Some also help to serve you with advertisements which are more relevant to you.

For example, our websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses non-operational cookies, which are text files placed on your computer to help the website analyse how visitors use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. At our request, Google will use this information for the purpose of evaluating how the website is used, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.

Similarly, we use the Facebook pixel service. The Facebook pixel is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions you take on other websites. We use it to make sure our advertising on Facebook is shown to the right people and is effective. When you visit our websites and take an action, this triggers the pixel which reports this action to Facebook.

By using our websites, you consent to the processing of data about you by Google and Facebook in the manner and for the purposes set out above.

Cookies Placed by Third Parties When You Visit Third Party Websites or Service

We also maintain a presence for Givng and its Services on third party websites and services that are not hosted by Givng. If you visit or use third party websites or services, those third parties may place cookies or similar technologies on your computer or device. For more information about what cookies or similar technologies those third parties use, please review the third party services’ cookie policies.

Cookies Settings

You may decline cookies that are not Strictly Necessary by clicking “Decline” in the cookie banner at the bottom of your screen. Additionally, although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. However, if you don’t accept cookies, you may not be able to access all portions or features of the Services.

If you continue to use the Services, you consent to our use of cookies as described in this Cookies Policy.