Privacy Policy & Cookies Policy

Gambling.com Group Limited

PRIVACY AND COOKIES POLICY

GDC Media Limited operates as a part of the Gambling.com Group Limited (Nasdaq: GAMB), identified herein as \" GAMB \".

The terms \" GDC \", \" we \", \" us \", or \" our \" encompass GAMB and its existing and forthcoming subsidiaries, collectively referred to as \" Group Members \".

GDC Media Limited is responsible for managing the various websites that GDC operates, except for some which are owned by OddsJam, Inc., another member of the group.

Both GDC Media Limited and OddsJam, Inc. have authorized other Group Members to manage select GDC websites in specific geographic regions, including:

• (a) United States-based GDC websites which are managed by GDC America, Inc.;
• (b) GDC websites under OddsJam, Inc., now overseen by GDC Media Limited and OpticOdds, Inc.; and
• (c) Certain GDC websites in the U.S., which are managed by Roto Sports, Inc. under a sub-license from GDC America.

This document, known as the Privacy and Cookies Policy (“ Policy ”), outlines the data handling practices of GDC Media Limited, OddsJam, Inc. and related Group Members that oversee GDC’s websites in various locations, as well as the rights and options available to individuals concerning their personal data.

1. PURPOSE OF THIS POLICY

At GDC, your privacy is taken seriously, and we are dedicated to safeguarding your personal data. Personal data consists of information that can identify you as a specific individual. It does not include data that has been made anonymous, where personal identification is not possible.

This Policy details your rights and options concerning your personal data. It's essential to review it thoroughly. Should you have any questions regarding this Policy or wish to exercise your legal rights, please reach out to us as indicated below.

We reserve the right to modify this Policy periodically, as necessary to align with GDC services or comply with varying local laws and regulations worldwide. This includes offering additional details for users in specific jurisdictions. Note that this Policy is not applicable to how GDC handles personal data related to its own employees or contractors.

We also provide significant supplemental information that is relevant only to users located in (i) Member States of the European Union, countries in the European Economic Area, the United Kingdom, and Switzerland (collectively referred to as “ Europe ” or “ European ”), (ii) Brazil, and (iii) various states in the United States like California, Colorado, Connecticut, and others, (iv) Australia, (v) Canada, and (vi) Mexico.

Our websites may feature links to external sites, plugins, and applications. By clicking on these links or activating these connections, you may allow third-party entities to collect, utilize, or otherwise manage your data. We have no control over these external sites and cannot be held accountable for their privacy practices. When visiting any external website, we encourage you to check their privacy policies.

2. THE PERSONAL DATA WE COLLECT

We gather personal data about users from a variety of resources as described below. If applicable, we will inform you regarding our data usage intentions prior to data collection, enabling you to decide whether to share that information. We categorize the types of personal data we may collect, use, hold, and transfer about you (“ Personal Data ”) as follows:

“ Personal Information ” refers to any details that could identify you, either on its own or when combined with other data. This might include your first name, last name, email address, or phone number. The specific Personal Information collected can differ based on our interactions and relationship with you.

In various privacy laws, Personal Information, also termed as \"personal data\", may carry distinct definitions.

“ Profile Data ” encompasses any identifiers such as usernames (or nicknames), encrypted passwords, login and logout timestamps, as well as profile images that users may upload to one of our websites or apps, alongside comments or content they generate and other information they input into their profiles (e.g., for a 'Freemium' account);

“ Financial Account Data ” includes details from your payment card or bank account;

“ Recruitment Process Data ” consists of an applicant's CV and cover letter, alongside notes collected during the recruitment process concerning job applications and interviews, including additional details provided by candidates, like qualifications, skills, educational and work history.

“ Usage Data ” refers to insights into how you interact with our websites. This may involve information like the IP address of your computer, the type and version of your browser, operating system, the specific pages you visit, time and date of access, duration spent on pages, unique device identifiers, and additional diagnostic data.

When you access our mobile apps, Usage Data may also capture information such as your mobile device's type, unique device ID, IP address, mobile operating system, browser type, and additional diagnostic data.

With your consent, we may utilize and store location-related information (“ Location Data ”). This data allows us to enhance our services and customize offerings for you.

You possess the ability to activate or deactivate location services at any time through your device’s privacy settings while using our services.

We may also gather, utilize, and share “ Aggregated Data ” like statistical or demographic information for varied purposes. Though Aggregated Data may originate from your personal data, it is not classified as personal data legally since it cannot directly or indirectly identify you.

Any voicemail messages you leave for our customer support may be recorded for future reference.

We automatically gather Usage Data during your visits. If you access our site via a mobile device, we acquire data that identifies your device, configurations, and possible operational issues such as application crashes.

We do not gather any information regarding your race, ethnicity, religious beliefs, gender identity, sexual orientation, political views, union membership, health data, or genetic/biometric data. However, for job candidates, we will collect data relating to any criminal records.

3. COLLECTION OF PERSONAL DATA

We might employ various approaches to collect data from you, including the following:

• Direct interactions. You may share your Personal Information, Profile Data, Financial Account Data, and Recruitment Process Data in the following ways: (a) completing a job application form on our Career Page, (b) providing your email for website registration or news updates, (c) leaving comments during your site interactions, or (d) submitting payment details or login credentials through our registration forms.
• Indirect interactions. You may share your Personal Information indirectly by registering with sites or obtaining newsletters from our Media Partners , with whom we collaborate to provide services.
• Automated technologies. While you interact with our websites, we automatically collect Usage Data about your device, browsing habits, and patterns via cookies, server logs, and similar technologies. Third parties or publicly accessed sources. We could collaborate with third parties (like content providers and analytics entities such as Google Analytics and others) to refine our website services and improve user experiences. These firms might gather information from you during your visits. We might utilize third-party service providers to enhance our service development processes.

Typically, our websites can be accessed and utilized without enrolling or supplying Personal Data (including Personal Information, Profile Data, and/or Recruitment Process Data). You can opt in to receive promotional content by subscribing to one or more mailing lists with your email. At any point, you have the option to opt out of such communications by contacting us or utilizing the “unsubscribe” option provided in our emails. If you choose to contact us through email or other means, we may preserve a record of that correspondence. We will not distribute your Personal Data to third parties for marketing unless you expressly consent to it and/or, concerning our Media Partners, you have agreed to receive marketing content from them. If you wish to withdraw your consent regarding the Media Partners, you must contact them directly. Withdrawal of consent concerning our Media Partners cannot be done through Group Members.

4. USE OF PERSONAL DATA

We may utilize your Personal Data for the following purposes:

Delivering our services, which may encompass:

• Overseeing the operation, assessment, upkeep, enhancement, and delivery of our service capabilities;
• Informing you about any updates or modifications to our services;
• Processing payment transactions that you initiate; and conversing with you about your account status if you have one, which includes sending service-related communications, such as verification messages, updates on service features, technical alerts, subscription notifications, including reminders for expiration and renewal, instructional emails, and responses to your queries.
• Customizing how we deliver our services to you;
• Managing and safeguarding our business operations;
• Keeping you informed about news, promotional offers, and general information related to other products, services, and events that we provide, which are similar to what you have previously bought or expressed interest in, unless you have chosen not to receive such communications;
• Tracking the way our services are utilized;
• Identifying, preventing, and resolving technical issues;
• Offering support and ongoing maintenance for our services, which includes addressing your inquiries, requests, and feedback regarding our services.

For research and development

The information we gather is utilized for our internal research and development efforts, which comprise:

• Enhancing or refining our services;
• Creating analytical tools and corresponding reports.

Marketing

We might analyze your Personal Data to understand better what services might appeal to you or what could be of interest to you.

If you have shown interest in our services or have used them and have not opted out, we may reach out to you with promotional materials using the Personal Data you've provided, as permitted by the applicable laws.

At any time, you can request us to cease sending you marketing communications by contacting us through the provided details or using the opt-out link that is included in every promotional message.

If you decide to withdraw your consent for marketing messages, we will still carry out relevant activities using your Personal Data, including sending you non-promotional communications.

Overseeing our recruitment and processing of job applications

We handle Personal Data, like information provided in job applications, to aid in our hiring processes and manage employment applications, which involves evaluating candidates and tracking recruitment metrics.

Complying with law

We utilize your Personal Data as we find necessary and suitable to adhere to applicable legislation, legitimate requests, and legal protocols, which include responding to subpoenas or inquiries from governmental bodies.

Adherence, fraud prevention, and safety

We use your Personal Data when we find it essential or suitable to (a) uphold the terms and conditions governing our services; (b) safeguard our own rights, privacy, safety, or property, as well as those of others; and (c) protect, investigate, and prevent fraudulent, harmful, unauthorized, unethical, or illegal actions.

With your consent

In some regions, the law may mandate us to obtain your consent for utilizing your Personal Data under certain circumstances, such as for sending specific marketing communications. If we seek your consent to process your Personal Data, you can withdraw it anytime through the method specified at the time of requesting consent or by reaching out to us. If you've consented to receive marketing materials from our partners, including those in media, you can retract that consent directly through them (and not by contacting us).

To create anonymous data

We may generate anonymized data from your Personal Data along with that of others whose data we collect. This allows us to remove identifiers to make the data non-personal and to use this anonymized information for our legitimate business activities.

5. TO WHOM DO WE PROVIDE PERSONAL DATA

There may be circumstances where we need to disclose your information to the following entities:

Group Members

We may share your Personal Data with other members of our Group for purposes that align with this Policy.

Service providers

We may engage third-party service providers to administer and deliver services on our behalf (e.g., customer support, hosting, development, and IT management services), and facilitate payments. These entities are authorized to use your data only according to our instructions and in compliance with this Policy. They are prohibited from using your information for any unrelated purposes.

Entities involved in transaction processing

We may share your Personal Data with companies involved in the processing of transactions, such as merchants, banks, card issuers, card associations, debit network operators, and their associated members.

Business Transaction

In the event of a merger, acquisition, or sale of assets involving GDC and any Group Member, your Personal Data may be transferred.

Professional advisors

We may share your Personal Data with professional advisors, including attorneys, financial institutions, auditors, and insurers, in the course of their professional relationships with us.

Transfers to third parties

We may provide your Personal Data to third parties, including our Media Partners and other business collaborators, to facilitate our services. When we engage in data sharing with third parties, we ensure appropriate contractual agreements are in place, secure transfer of information, and that only the essential amount of your data is shared. We will never sell your information to any other entities.

When a third party acts as a data controller, they are obligated to uphold the same data protection responsibilities as we do.

When working with data processors, we require them to provide sufficient assurances that they have implemented necessary safeguards and protocols to protect your data rights and freedoms.

Compliance with Laws and Law Enforcement; Safety and Protection

GDC may be required to provide information about you to government or law enforcement entities or private individuals in compliance with legal demands, and may disclose and utilize such information as we assess necessary or suitable to (a) adhere to relevant laws and lawful requests and legal proceedings, such as responding to subpoenas from government agencies; (b) enforce our service terms and conditions; (c) safeguard our rights, privacy, safety, or property, as well as that of others; and (d) protect, investigate, and prevent fraudulent, harmful, unauthorized, unethical, or illegal actions. Additionally, GDC may disclose Personal Data in relation to any complaints concerning your use of our platforms, for instance, in response to a grievance or legal action arising from a posted comment or content.

6. INTERNATIONAL TRANSFERS OF DATA

GAMB is established in Jersey, and GDC operates worldwide, primarily out of offices in the United States and Ireland. Our main executive office is located at 22 Greenville St., St. Helier, Channel Island of Jersey JE4 8PX. Your personal data may be transferred to locations outside your region, province, country, or governmental area, where we, our third-party partners, including our Media Partners, or service providers maintain operations, and where privacy regulations may not offer the same level of protection as those in your jurisdiction. In such instances, we will ensure that recipients of your personal data provide data security and protections as mandated by applicable laws; and we will undertake reasonable measures to guarantee your data is secured and processed in accordance with this Privacy Policy, ensuring that your Personal Data is not transferred to any organization or country without adequate safeguards being in place.

Users in Europe should review the critical information provided below in Section 10 concerning the transfer of personal data outside their region or country.

7. DATA SECURITY AND DATA RETENTION

We have established appropriate security precautions to reasonably protect your Personal Data from accidental loss, unauthorized access, misuse, alteration, or disclosure. Additionally, we restrict access to your Personal Data only to those employees, agents, contractors, subsidiaries, affiliates, and other third parties who need to know it for business purposes. They can only process your Personal Data under our direction and must uphold confidentiality. We've implemented reasonable commercial procedures to handle any potential Personal Data breaches and will notify you and any relevant regulators of a breach when we are legally required to do so.

While we endeavor to employ adequate physical, electronic, and procedural safeguards to protect Personal Data in our organization against loss, theft, undue access, disclosure, or modification, we recognize that no data transmission over the internet can be entirely secure. Therefore, although we make every effort to ensure the safety of your information, we cannot guarantee it entirely.

We will handle and retain the relevant Personal Data only for as long as necessary to fulfill the purposes stated in this Privacy Policy or as required for our legal, contractual, or statutory obligations and/or for the establishment, exercise, or defense of legal claims.

Moreover, we will retain Usage Data for internal analytical objectives. Typically, Usage Data is kept for a shorter duration, unless it is utilized to enhance security or improve the features of our services, or unless we are legally bound to retain it for a more extended period.

When you leave comments on our website during your visits, we will maintain a record of all of your commenting activities. Any personal information obtained from your comments will be stored for as long as the article you commented on remains available online.

8. YOUR RIGHTS AND CHOICES

This section outlines the rights and options available to all users. If you reside in Europe or Brazil, it's important that you review the additional details about your rights that can be found in paragraph 10 below. Similarly, users based in California, Virginia, and other states in the US should consult the relevant paragraphs below for specific information regarding their rights, while users from Australia, Canada, and Mexico should refer to paragraphs 14, 15, and 16 respectively for more context.

Marketing communications

At any point, you may request that we stop sending you promotional communications by reaching out to us or by clicking the unsubscribe link included in every marketing email. However, please note that you may still receive messages related to services and other non-promotional communications.

Opting out of providing Personal Data

If we ask you for your Personal Data directly, you are under no obligation to provide it. If you choose to withhold the requested details, there may be situations where we cannot deliver certain services to you. For instance, this could prevent us from processing your order.

Your rights regarding access, modification, or deletion of your information

In some areas, local laws may grant you the right to access, change, or erase your Personal Data. You can directly reach out to GDC to request access, modifications, or deletions of your information. However, we may not always be able to fulfill these requests, depending on the circumstances.

Complaints

If you have any dissatisfaction regarding how we manage your Personal Data, you can reach out to our data protection officer through the contact information provided below. Complaints must be submitted in writing, and we encourage you to include as many details as possible to aid us in our investigation. We will assess your complaint and decide the appropriate course of action, which may involve discussions with relevant teams. Furthermore, we may reach out for additional information or clarification if needed and will inform you of the outcome of your complaint. You also have the right to file a complaint with a regulatory body at either the national or local level.

9. PAYMENTS

We offer certain products and services that may require payment. In these cases, we utilize third-party services for handling payment transactions (such as payment processors).

We will not retain or gather your credit card information. Such details are passed directly to our third-party payment processors, who manage your personal information in accordance with their own Privacy Policies. These payment processors comply with the standards established by PCI-DSS as overseen by the PCI Security Standards Council, which involves collaboration from brands such as Visa, Mastercard, American Express, and Discover. The PCI-DSS requirements are in place to ensure that payment information is securely handled.

Some of the payment processors we may collaborate with include:

Apple Store In-App Payments:
You can review their Privacy Policy at the following link: https://www.apple.com/legal/privacy/en-ww/ / https://support.apple.com/en-us/HT203027

Google Play In-App Payments:
You can review their Privacy Policy at the following link: https://policies.google.com/privacy?hl=en≷=us / https://payments.google.com/payments/apissecure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en

Stripe:
You can review their Privacy Policy at the following link: https://stripe.com/us/privacy

Authorize.net:
You can review their Privacy Policy at the following link: https://www.authorize.net/about-us/privacy/

10. ADDITIONAL INFORMATION FOR USERS IN EUROPE AND BRAZIL

Data Controller

GDC serves as the data controller in accordance with the General Data Protection Regulation (‘ GDPR ’) and other applicable data protection regulations. This indicates that GDC is primarily accountable for responsibly managing your Personal Data, and this Policy defines the methods and purposes related to the processing of your Personal Data.

Legal bases for processing

We must inform you of the legal justifications for our processing of your Personal Data, which are detailed in the table below. If you have any inquiries regarding the legal basis under which we process your information, please get in touch with us at [email protected] .

Use for new purposes

We may utilize your Personal Data for purposes not explicitly mentioned in this Policy when permitted by law, provided that the new purpose is compatible with the reason we originally collected your data.

Duration of Personal Data Usage

We will retain your Personal Data for as long as it remains necessary based on the reasons we collected it and its intended use. This may also extend to fulfilling any legal, regulatory, accounting, or reporting obligations.

To establish an appropriate retention period for your Personal Data, we factor in the volume, nature, and sensitivity of that data, any potential risks associated with unauthorized use or disclosure, the objectives of our data processing, and whether those objectives could be attained through alternative means, alongside existing legal stipulations.

Generally speaking, your Personal Data will be held for the duration of your engagement with us and for a reasonable period following that engagement. Certain types of information must also be retained for a specified duration as mandated by law.

Your individual legal rights

You possess the right to request access to, modification of, deletion of, restriction of, portability of your Personal Data, and to object to its processing, as detailed below:

• Access . You have the entitlement to inquire whether we are processing your Personal Data, and if we are, you can request a copy of the information we hold about you, along with certain other details regarding our processing practices.
• Correction . If you find that any Personal Data we hold about you is either incomplete or incorrect, you are entitled to ask us to correct it; however, we might need to verify the accuracy of the new information you provide.
• Erasure . This grants you the ability to request that we delete or remove your Personal Data when there is no valid reason for us to keep processing it. You may also ask us to erase your data if you have successfully asserted your right to object to our processing (as explained below), if we have unlawfully processed your information, or when we must erase your Personal Data to comply with local regulations. If you are in Brazil, you may also request that we anonymize or block personal data deemed excessive, unnecessary, or unlawfully processed.
• Object . If our grounds for processing your Personal Data relate to legitimate interests, you have the right to object if you believe it infringes upon your fundamental rights and freedoms. You can also object to the processing of your Personal Data for purposes of direct marketing.
• Restriction . You may request that we pause our usage of your Personal Data in the following situations:
  • if you wish us to verify the accuracy of the data;
  • if our processing of your Personal Data is unlawful but you do not wish for it to be erased;
  • if you require us to keep your data longer than our normal retention period, as you need it for establishing, exercising, or defending legal claims; or
  • if you have contested our use of your data, but we need to establish whether we have overriding legitimate grounds to process it.
• Transfer . Where feasible, we will provide your Personal Data to you or a third party of your choosing in a structured, commonly used, machine-readable format. Please note that this entitlement is only applicable to Personal Data you provided and that we initially received your consent to process or utilized to fulfill a contract with you.
• Withdraw consent . If your Personal Data processing is based on your consent, you may withdraw that consent at any time. Should you revoke your consent, certain services may no longer be available to you, and we will inform you if this scenario arises upon your withdrawal.
• Automated decision making . You have the right not to be subjected to automated decision-making processes (such as profiling) that significantly affect you. However, this right may not be applicable in the following circumstances:
  • The automated decision is necessary to enter into or complete a contract with you.
  • We have obtained your explicit consent to make such a decision.
  • The automated decision is authorized by local laws of an EU member state.

Nevertheless, in the first two situations mentioned above, you still retain the right to seek human intervention regarding the decision, to present your viewpoint, and to challenge that decision.

Should you have any inquiries about this Policy or wish to exercise any of the rights outlined above, please connect with us at [email protected] .

To help us verify your identity and ensure your eligibility to exercise a right concerning your Personal Data, we may need to request specific information from you. This is a precautionary measure to prevent unauthorized access to your Personal Data. Additionally, we might reach out for further details related to your request to expedite our response.

There could be legal or other factors that inhibit our ability to fulfill a request pertaining to your rights. We will employ any applicable lawful exemptions regarding your individual rights as necessary. If we decline your request, we will inform you of the reasons behind that decision, respecting any relevant legal constraints.

You have the option to file a complaint to a regulatory body at any time if you feel it necessary (for further details, refer to https://edpb.europa.eu/about-edpb/board/members_en ). For individuals in the UK, you also have the ability to lodge a complaint with the Information Commissioner’s Office (ICO).

International transfers of data

We may send the Personal Data we gather about you to entities located in nations apart from yours, including the United States. These nations might not offer the same level of data protection as your home country. When transferring your Personal Data internationally, we commit to safeguarding that information according to the guidelines laid out in this Policy, or as previously communicated to you.

We follow all relevant legal obligations when moving Personal Data to other nations outside your location. If you are based in the EEA, UK, or Switzerland, we will ensure your Personal Information is transferred according to adequacy determinations, standard contractual clauses, and other approved data transfer methods.

Refer to the compilation of countries that have received an adequacy decision from the European Commission. here .

Refer to the compilation of countries that have gained an adequacy decision from the UK government. here .

11. DETAILS FOR RESIDENTS OF CALIFORNIA

A) Your Rights Regarding Data Protection under the California Consumer Privacy Act

In accordance with the California Consumer Privacy Act of 2018, updated by the California Privacy Rights Act of 2020 (CPRA), (“ CCPA ”), we are obligated to inform California residents about how we gather, utilize, and share their Personal Data, as well as the rights and options available to them concerning the management of their Personal Data.

Your California privacy rights

As someone residing in California, you possess the rights enumerated below. It is important to note, however, that these rights have limitations, and we reserve the right to deny requests as allowed by the CCPA.

• Access and portability of data. You may be entitled to request a copy of the Personal Data we have collected regarding you. Additionally, you might seek disclosure about how we have handled your personal data over the last year, including: (a) the types and specific data points we have collected; (b) the sources from which we gathered your personal data; (c) the business or commercial reasons for our collection, sale, or sharing of that data; (d) the third parties to whom we have disclosed personal data; and (e) the types of personal data shared for business reasons and details about the third parties to whom such data was sold or shared. Please note that access requests may only be made to us twice in a twelve-month span.
• Deletion. You might have the right to ask us to erase certain personal data we’ve collected from you. However, this is contingent on our ability to retain your personal data for specific purposes allowed under CCPA. If we cannot fulfill such a request, we will inform you.
• Correction. You may also request that we amend any inaccuracies in the personal data we have related to you.
• Limiting the use and disclosure of sensitive personal data. The CCPA grants you the ability to instruct businesses to restrict their use or sharing of your sensitive personal information solely to the extent necessary for delivering the services or goods you reasonably expect while using those goods or services, as well as to engage in certain activities permitted by the CCPA. We do not gather, utilize, or disclose sensitive personal data beyond what is essential to provide the relevant services or as allowed by the CCPA.
• Opt-out option. You may have the right to express that you do not want your personal data shared (as defined previously) with third parties.
• Non-discrimination. You have the right to exercise the aforementioned rights without facing discrimination. This means we will not impose penalties for asserting your rights, such as denying you goods or services, raising service or product costs, diminishing service quality, or indicating that exercising your rights might lead to punishment. However, the CCPA does permit us to offer different prices or service quality if such variations are reasonably connected to the value of the Personal Data we cannot utilize.

How to exercise your rights

You can assert your privacy rights in California through the following avenues:

Your rights regarding information, access, and deletion

To exercise your rights related to information, access, and deletion, you can:

• Contacting us at [email protected]
• Identity verification. In accordance with the CCPA, we must validate the identity of the individual making the request before proceeding with a detailed response. Requests should be supplied with ample information to enable us to comprehend, evaluate, and react. The individual making the request must provide enough data to allow reasonable verification of their identity. A request may also be submitted on behalf of a child under the age of 13.
• Authorized agents. Residents of California can designate an ‘authorized agent’ to submit requests on their behalf. We will require proper written consent to establish this authority.

Sale or Sharing of Personal Information for cross-context advertising means

Our online platforms and those of our Media Partners might utilize analytics and advertising mechanisms that allow both us and our analytics and marketing collaborators to gather and reveal information about your internet or other electronic activities based on your interactions across our services and websites as well as the sites of our Media Partners. This process includes analyzing your service usage and that of our Media Partners, and showing advertisements tailored to your interests (collectively referred to as 'cross-context behavioral advertising'). However, it is crucial to understand that we do not knowingly sell or disclose the Personal Information of individuals below the age of 16 without receiving parental consent.

Personal information that we collect, use, and share

The table below provides an overview of the data we may collect or have possibly collected from California residents in the year preceding this Policy’s effective date.

It is important to bear in mind that the categories and examples listed below are those defined by the CCPA. This does not imply that all examples within a specific category of personal data were actually collected by us, but we maintain in good faith that some information from the relevant category could have been and may have been gathered. For instance, certain types of personal information will only be gathered if provided directly by you to us.

B) Your Rights Regarding Data Protection under the California Privacy Protection Act (CalOPPA)

CalOPPA stands as the first state law in the U.S. mandating commercial websites and online services to publicize a privacy policy. The law’s scope extends well beyond California, requiring individuals or companies in the U.S. that maintain websites collecting personally identifiable information from California consumers to display a clear privacy policy on their sites, detailing precisely what information is being gathered and with whom it is being shared, along with the obligation to adhere to this policy. – For more information, see: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacyprotection-act-caloppa-3/

In accordance with CalOPPA, we agree to the following stipulations:

(a) users have the ability to browse our site without revealing their identity;
(b) our Privacy Policy link includes the word 'Privacy,' ensuring it is easily accessible on the page.
As stated previously on the homepage of our site;
(c) users will be informed about any modifications to our privacy policy on the dedicated Privacy Policy page;
(d) if users wish to update their personal details, they can reach out to us via email at [email protected] .

12. INFORMATION FOR VIRGINIA RESIDENTS

According to the Virginia Consumer Data Protection Act, residents of Virginia have specific rights regarding the collection, usage, and sharing of their personal data by GDC. For clarity in exercising the rights outlined in this section, the meanings of the terms used are defined below:

Definitions:

• Profiling refers to any automated processing that assesses, analyzes, or forecasts personal elements related to an individual's financial conditions, health status, personal preferences, interests, dependability, behavior patterns, geographic location, or movements.
• The term 'Sale of personal data' signifies the interchange of personal information for monetary gain.
• 'Targeted advertising' encompasses showing promotions to a consumer based on personal information obtained from that user's past activities across unrelated websites or online applications, with the aim of gauging the user's interests or preferences.

If you reside in Virginia, you are entitled to the rights highlighted below.

• Right of access. You might possess the right to verify if we are processing your personal information and to obtain access to that information.
• Right of data portability. You may be able to request a copy of the personal data you have previously provided to GDC.
• Right to correction. You may have the option to ask us to amend any inaccuracies in the personal data we hold about you.
• Right to deletion. You may also request the removal of certain personal information that we have collected about you. This request will be honored as long as we can maintain your personal data for legally appropriate reasons in accordance with state laws. If we cannot fulfill such a request, we will inform you.
• Right to opt-out. You might have the right to request that your personal data is neither sold to third parties nor utilized for targeted advertising or profiling, especially in ways that could result in legal or similarly impactful consequences for you.
• Appeal. If GDC denies any of the aforementioned rights, you have the right to contest that denial. You can do this by replying to the message in which GDC communicated its denial and stating your desire to appeal.

How to exercise your rights

As a Virginia resident, you can exercise your rights by contacting us at [email protected]

13. OTHER STATES OF THE UNITED STATES PRIVACY RIGHTS

Residents of Colorado, Connecticut, Florida, and Utah are granted rights by their respective state laws, which include the ability to:

• Confirm whether we are processing their personal information.
• Access, modify, and delete certain personal information.
• Data portability.
• Opt-out of having their personal information processed for targeted advertising and sales.

Additionally, residents in Colorado and Connecticut are also provided with rights to:

• Request corrections to inaccuracies within their personal information, considering the nature and intended use of the information.
• Choose to opt-out of profiling that leads to decisions with legal or similarly important repercussions.

If you live in one of these states, you can exercise these rights by getting in touch with us. [email protected] .

The State of Nevada grants its residents a limited right to opt-out of certain sales of personal information. Those wishing to utilize this opt-out feature can send a request to the following designated address: [email protected] . However, we want to clarify that we are not currently engaged in selling data that would trigger the requirements to opt-out under this statute.

The State of Iowa provides its residents with rights to:

• Access rights. In accordance with applicable law, you can submit a verifiable request to access the personal information we have collected about you, as well as more details on our data handling practices. For additional information on how we collect, utilize, and share personal data for business purposes, please refer to our Global Privacy Policy.
• Deletion rights. In line with applicable law, you can submit a request to remove your personal information.
• Data portability rights. Under applicable law, you have the right to obtain a copy of the personal data you provided to us, unless the data is protected due to security concerns, or you have previously provided it in a format that enables seamless transfer to another entity without obstacles, where processing is automated.
• Appeal process for consumer rights requests. To challenge a refusal regarding your request, please refer to the instructions in our response or submit your appeal in writing by contacting [email protected] with the subject line “Appeal of Consumer Rights Request.”

Residents of Delaware, Montana, New Hampshire, New Jersey, Oregon, and Tennessee have the following rights:

• Right to Access. Consistent with applicable law, you may submit a verifiable request to access the personal data we hold about you, along with further details regarding our data practices. For more insight into how we collect, utilize, and share personal information for business purposes, please examine our Global Privacy Policy.
• Right to Correct. In accordance with applicable law, you may submit a verified request to rectify inaccuracies in the personal information we have about you.
• Right to Delete. Consistent with applicable law, you may submit a verifiable request asking for the deletion of your personal information.
• Appeal of Consumer Rights Requests. To challenge a refusal regarding your request, please follow the guidelines provided in our response to your request or send your appeal in writing by reaching out to [email protected] with the subject “Appeal of Consumer Rights Request.”
• Personalized Advertising Opt-Out. Although we do not sell personal information, we may process such data for the purpose of delivering ads that are selected based on users’ online behaviors across various platforms. In compliance with applicable laws, you can opt out of this kind of processing by contacting us. We do our best to respect opt-out preferences as mandated by law. Such preferences are signaled through a third-party source that we do not manage.

Residents of the State of Washington have the following rights:

• Right to Access. In line with applicable law, you may make a request to access the personal information we have gathered about you, in addition to further details regarding our data practices. To learn more about our collection, use, and disclosure of personal information for business purposes, please consult our Global Privacy Policy.
• Right to Correct. In accordance with applicable law, you can submit a request to rectify inaccuracies in your personal information held by GDC.
• Right to Delete. Under applicable law, you may request for your personal information to be erased.
• Right to data portability. Consistent with applicable laws, you have the entitlement to obtain a copy of the personal data that you provided to the controller.
• Right to Opt Out. In accordance with applicable laws, you have the ability to opt out of particular data processing activities, such as those related to targeted advertising, data sales, and profiling.
• Appeal process for consumer rights requests. To challenge a refusal regarding your request, please refer to the instructions in our response or submit your appeal in writing by contacting [email protected] with the subject line “Appeal of Consumer Rights Request.”

Please be aware that if you submit requests regarding data subject rights, you may need to confirm your identity before any further steps are taken. This process may involve providing personal details, including your name, state of residence, phone number, and email associated with your account, if applicable. Additionally, you may appoint an authorized agent to make a request on your behalf.

14. INFORMATION FOR AUSTRALIA RESIDENTS

GDC is furnishing the following extra information for individuals from whom we collect or maintain personal data, when the collecting or maintaining entity is deemed to have an 'Australian link' as per the Australian Privacy Law.

If you qualify as such an individual, you can lodge a complaint with us regarding any breaches of the Australian Privacy Principles by contacting us at [email protected] .

We will thoroughly examine your complaint and strive to rectify any issues to your satisfaction. If we do not sufficiently address your concerns, you reserve the right to officially complain in writing to the Office of the Australian Information Commissioner. here .

Should you desire to know the personal information we have about you, you may request access to your records by reaching out to us, and we will respond within a reasonable timeframe following the receipt of your application.

If you want to update personal information that is incorrect or outdated, please reach out to us and we will adjust the record. If you would like your personal data to be eliminated, please inform us, and we will take reasonable measures to delete it, unless retention is required for legal or regulatory reasons.

15. INFORMATION FOR CANADA RESIDENTS

We may gather, utilize, and share Personal Data for the reasons identified in this Privacy Policy, as well as for any additional objectives mandated by law, with a notification to you and your explicit or implied consent.

You might be able to utilize the tool created by the Digital Advertising Alliance of Canada to decline third-party advertising. Where applicable, this tool provides a compilation of parties that could target advertisements based on your online browsing activities and offers the option to decline their use of your data for such advertising. To access this tool, visit https://youradchoices.ca .

Should you have any inquiries or complaints regarding our management of your personal information, please contact us at [email protected] . We will address your complaint within a reasonable time frame. If you are not satisfied with our resolution, you may reach out to the Office of the Privacy Commissioner.

16. INFORMATION FOR MEXICO

Below, you will find details concerning GDC's privacy protocols in relation to Mexico's Federal Law for the Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares).

You possess specific ARCO rights in regards to how GDC manages your personal information. These rights encompass your ability to access your personal data and seek clarifications about GDC's usage of this data, the ability to amend any inaccurate or incomplete information, the authority to request the deletion of your data if you suspect it is not being handled per the principles, responsibilities, and obligations as stipulated in Mexican data protection law, and the right to challenge GDC's processing of your data for particular intentions. Collectively, these rights are referred to as the 'ARCO rights' under Mexican legislation. To initiate your request concerning ARCO rights, please direct it to [email protected] At the start of your request, kindly specify 'Exercise of ARCO rights/Mexico'.

Please be aware that as a data controller, GDC has the right to decline your request to exercise ARCO rights in situations allowed by relevant legislation, and you will be notified of such outcomes. If a refusal occurs, it may be partial, and in that case, GDC will proceed to address the access, correction, cancellation, or objection in the applicable parts.

Regarding Data Transfers, GDC, in its capacity as a data controller, will ensure that any third parties receiving the data adhere to the principles and responsibilities required by the Federal Law for the Protection of Personal Data Held by Private Parties.

Should there be a data breach affecting personal data, GDC, as the data controller, will inform you, as the impacted individual, as well as the National Institute for Transparency, Access to Information, and Personal Data Protection (INAI).

17. LINKS TO OTHER WEBSITES

While providing our services through our websites and those of our Media Partners, we may include links to external websites, mobile applications, and additional content from third parties. GDC cannot be held liable for the privacy practices of these external parties, and this Policy does not extend to their websites, applications, or other provided content. GDC does not guarantee, endorse, or approve the information, materials, services, or products found on or accessible via any linked third-party sites.

18. COOKIES, PIXEL AND TRACKING INFORMATION

Cookies are tiny data files placed on your computer that remember your selections while you surf a website. For further details on cookies and their functionality, please visit: www.aboutcookies.org .

We deploy cookies, pixels, and analogous technologies to enhance our service and improve your experience. For instance, they help present you with the most pertinent information when you revisit our site.

In using cookies, pixels, and similar technologies, we generally do not handle any information that personally identifies an individual. By browsing our websites, you consent to our use of cookies. You have the option to manage cookie use, disable, or remove cookies at any time using your browser settings. The help section of your browser should offer guidance on this.

Similar to many digital service providers, we utilize services from Google, Meta, among others, which use tracking technologies. These services aim to deliver interest-based advertisements tailored for effectiveness derived from inferences made about you. Your options regarding modifying your preferences for interest-based ads or opting out of the processing of your personal information by these entities include:

• Blocking cookies via your browser. Most browsers allow the removal or rejection of cookies, including those designated for interest-based advertising. To do this, follow the guidelines provided in your browser settings. Typically, browsers accept cookies by default until you modify these settings. For comprehensive information about cookies, including how to view which cookies are present on your device and how to manage and delete them, please refer to allaboutcookies.org.
• Employing privacy-enhancing plugins or browsers. You can prevent our websites from placing interest-based ad cookies by utilizing browsers with built-in privacy features such as Brave or by installing plugins like Privacy Badger, Ghostery, or uBlock Origin and setting them up to block third-party cookies and trackers.
• Opting out through platforms. The advertising partners listed below offer opt-out functionalities allowing you to refuse the use of your information for interest-based advertising:
  • Google: https://adssettings.google.com
  • Facebook: https://www.facebook.com/about/ads
  • Criteo: https://www.criteo.com/privacy/disable-criteo-services-on-internet-browsers/
  • Bounce Exchange: https://www.bouncex.com/privacy/your-ad-choices/
• Advertising industry opt-out tools. Some of our business collaborators, who gather information about user activities, may belong to organizations or initiatives that present individuals with choices regarding how their browsing activity or mobile app use is leveraged for targeted advertising. You can utilize the following opt-out options to restrict the use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance: http://optout.aboutads.info
  • Network Advertising Initiative: http://optout.networkadvertising.org/?c=1
  • Residents of Europe may opt-out from receiving targeted ads on websites through members of the European Interactive Digital Advertising Alliance by clicking here, selecting their country, and then selecting 'Choices' (or a similarly titled link).
  • We may partner with other companies offering their own opt-out methods, which may not align with the opt-out mechanisms previously linked.

As mentioned, if you choose to decline targeted advertisements, you will still encounter advertisements online; however, they may lack relevance to you. Even with an opt-out choice, not all companies participating in online behavioral advertising are included in this listing, which means you might still receive specific cookies and personalized ads from companies not represented.

Further guidance on how to disable or eliminate cookies can be discovered below as well as on https://www.aboutcookies.org/cookie-faq /.

Some browsers offer practical cookie insights:

• Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies
• Firefox: http://support.mozilla.org/en-US/kb/Cookies
• Internet Explorer: http://support.microsoft.com/kb/278835
• Safari 5 for Mac: https://support.apple.com/e
• Opera: http://help.opera.com/Linux/10.50/en/cookies.html

Additionally, Google Analytics provides its own options for opting out:

• http://tools.google.com/dlpage/gaoptout

When it comes to mobile devices, consulting the user manual may be necessary to effectively manage cookies. Limiting cookies might affect the functionality of our websites.

TYPES OF COOKIES

We utilize cookies for various purposes and with different roles.

Essential cookies are crucial for the effective operation of our websites. They enhance usability by enabling core functions like page navigation and granting access to secure areas of our sites. Such cookies may also serve to safeguard and expedite our websites for security purposes and to identify trusted visitors. They facilitate the filtering of bots to distinguish them from legitimate users, helping to curb spam activities on our platforms.

Preference cookies allow our websites to retain information that alters how they behave or appear. They might also be employed to provide requested services.

Analytics cookies gather data on how our websites are utilized. These cookies can analyze metrics regarding visitor counts, the origins of website traffic, the pages accessed, scrolling behaviors, downloads, user agent information, time spent on our sites, and the approximate geographic location of the device you use to access our websites. We leverage this information to create reports that assist in enhancing our websites.

In scenarios where we permit others to serve cookies via our websites or applications, these are referred to as 'third-party cookies.' Such cookies can serve various functions, including site analytics, advertising, and social media capabilities.

Below is additional information regarding the most common cookies we utilize, their roles, and their storage durations on your computer or device.

The most frequent cookies and other tracking technologies we employ include:

Please be aware that our advertisers might also employ cookies on their platforms, and we are unable to regulate how they are used.

Other Technologies.

We may utilize additional similar technologies to automatically gather information. Other tools we, our vendors, and third parties might use are:

• Server logs are utilized to capture details about your device, as well as the browser, operating system, network, and other resources used to access our digital services.
• Web pixels consist of tiny electronic images embedded in websites and emails to gather data on user interactions with content. Unlike cookies—which are stored on your device's hard drive—pixel tags are invisibly incorporated within web pages or HTML-formatted emails. These tags are employed to verify whether a webpage was accessed or specific content was viewed, primarily for measuring marketing campaign effectiveness and email engagement while compiling usage statistics for site management.

We may additionally engage third-party service providers to display advertisements aimed at you, which assist in funding and maintaining our services:

AdMob by Google

AdMob by Google is a service provided by Google Inc.

If you wish to stop using the AdMob service offered by Google, please follow the steps outlined by Google: https://support.google.com/ads/answer/2662922?hl=en

To find out more about how Google utilizes the information it gathers, we encourage you to check the page titled 'How Google uses data when you use our partners' sites or apps': http://www.google.com/policies/privacy/partners/ You can also view Google's Privacy Policy for additional details: http://www.google.com/policies/privacy/

AdButler

AdButler is an advertising service operated by Sparklit Networks Inc.

For further details regarding AdButler, please refer to their Privacy Policy: https://www.sparklit.com/agreements.spark?agreement=privacy

Unity Ads

Unity Ads is provided by Unity Technologies.

Should you want to discontinue your use of Unity Ads, you can follow the guidelines provided by Unity Technologies on their Privacy Policy page: https://unity3d.com/legal/privacy-policy

To find out more about the privacy practices of Unity Technologies, please consult their Privacy Policy: https://unity3d.com/legal/privacy-policy

If you have any inquiries regarding this Policy or if you wish to exercise any of your rights mentioned above, feel free to reach out to us at [email protected].

We will address all legitimate inquiries swiftly, adhering to any timelines specified by relevant laws. In most cases, we will respond to your questions within one month from when we receive your request. However, if your request is particularly intricate or you have submitted multiple inquiries, it could take us longer. In such situations, we will keep you informed and updated.

19. BEHAVIORAL REMARKETING

We might employ remarketing services to deliver advertisements on third-party websites after you have visited our service. Both we and our external vendors utilize cookies to inform, optimize, and present ads tailored to your previous interactions with our service.

Google Ads (AdWords)

The remarketing service for Google Ads (AdWords) is operated by Google Inc.

If you'd like to opt-out of Google Analytics regarding Display Advertising and personalize the ads on the Google Display Network, you can do so on the Google Ads Settings page: http://www.google.com/settings/ads

Google also suggests that you install the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. This add-on allows users to prevent their information from being collected and utilized by Google Analytics.

To learn more about Google's privacy practices, please visit the Google Privacy Terms webpage: https://policies.google.com/privacy?hl=en

Bing Ads Remarketing

Microsoft Inc. provides the remarketing service for Bing Ads.

You can opt-out of interest-based advertisements on Bing Ads by following their provided guidelines: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

For insights into the privacy practices and policies of Microsoft, please visit their Privacy Policy page: https://privacy.microsoft.com/en-us/PrivacyStatement

Twitter

Twitter Inc. offers the remarketing service through Twitter.

If you'd like to stop seeing interest-based ads from Twitter, you can follow their instructions to opt-out: https://support.twitter.com/articles/20170405

To understand more about Twitter's privacy practices and policies, please navigate to their Privacy Policy page: https://twitter.com/privacy

Pinterest

The remarketing service for Pinterest is offered by Pinterest Inc.

You can choose to opt-out of Pinterest's interest-based ads by activating the 'Do Not Track' feature in your web browser or by following Pinterest's guidelines: http://help.pinterest.com/en/articles/personalization-and-data

To gain knowledge about Pinterest's privacy practices and policies, please refer to their Privacy Policy page: https://about.pinterest.com/en/privacy-policy

20. UPDATES TO THIS POLICY

As updates to this Policy may occur from time to time, you can always access the most recent version of this Policy on our websites.

This Policy was updated as of January 15, 2025.