Privacy Policy

This Privacy Policy (this “Policy”) applies to Trugamer Services, and any sites, mobile apps or products that display or link to this Policy. It does not apply to any website, mobile app, service, or product that does not display or link to this Policy or that contains its own privacy policy. When the Services receive or collect information, that information is being received and collected, and will be owned, by Trugamer.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. BY USING THE SERVICES, YOU ACKNOWLEDGE YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY AND THAT WE WILL COLLECT, USE AND SHARE YOUR INFORMATION AS SET FORTH BELOW.

1. PERSONAL INFORMATION WE COLLECT

The following personal information is collected by or on behalf of Trugamer:

• Identifiers, such as your name, alias, phone number, mailing and email addresses, IP address, account name or other similar identifiers, account credentials, address book entries, birth date, and ZIP code.
• Information you share during communications and interactions with us, which may include the content of email messages, chat sessions, text messages, and phone calls.
• Demographic information, which may include age or birth date, gender, ZIP code, your status as a user, and other information about you.
• User-generated content, including, without limitation, photos, videos, audio, and other information you may submit to us, such as ratings/reviews or comments on our forums.
• Device-specific information, including hardware model, operating system version, unique device identifiers, and mobile network information.

2. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information using both direct and indirect means. For example, when you email our customer care team, fill out a form on our Site, or otherwise provide information to Trugamer, we collect your information directly from you. We may also collect your personal information indirectly through automated means, for example, when you interact with our Site, we may use technologies to collect information about how you use the Site. We may also receive information about you from third parties including from our affiliates and subsidiaries, social media platforms or from our advertising partners.

Personal Information Directly from You

We may collect personal information directly from you or your device as follows:

• When you register for a Trugamer account, it is necessary for you to provide personal information that includes your name and email address. You may choose to provide us with additional personal information, including billing, mailing, and shipping addresses, phone number, and a payment method (e.g., credit card). If you make purchases through the Site, you will also create a username and password, information that on subsequent visits helps us confirm your identity and makes it easier for you to make purchases on our Site.
• When you interact with Trugamer, including with a member of our team, contact our customer service team, respond to a survey, or engage in a promotional activity.
• When you sign up to receive emails, including marketing communications.

Personal Information from Third-Party Sources

To better understand your preferences, operate our business, and provide you with products and services, we may receive your personal information from the following third parties:

• Online social networks if you follow Trugamer on social media sites, e.g., Facebook, Instagram, Twitter, LinkedIn, TikTok. We may collect personal information when you communicate with us within the social media sites or use functionalities, plugins, widgets, or tools from social media platforms or networks in connection with our Site (e.g., to log into an account, or to share content with your friends and followers on social media) or when you click "Share This" or "Like" buttons. We think it is important to point out that if you make a post on a social media site, such as on Facebook or Instagram, or identify us in your social media feed by tagging us using a hashtag (#) or "at" (@), your personal information may be publicly available and is subject to the privacy policies of those social media sites. We recommend you review the privacy policies of any third-party sites you visit to understand the data collection and practices of those third parties.
• Third-party service providers that support our business, including companies that help with our marketing efforts, analytics providers, advertising networks and cooperatives, third parties that share information with us about the different devices you use online, reviews you have posted on third-party sites about products we offer, and other third parties that we collaborate or work with. Personal Information using Automated Technologies Personal information is also collected through automated technologies and shared with us when you visit our Site, open an email, or click on one of our advertisements.

Personal Information using Automated Technologies

Personal information is also collected through automated technologies and shared with us when you visit our Site, open an email, or click on one of our advertisements.

We automatically create website and mobile application log files, which are created when you access our Site. In addition, automated data collection technologies—such as cookies, beacons, tags, and scripts—are used by us to analyze trends, administer the Site, and track users' movements around the Site. We, and our third-party service providers, also use these technologies to gather demographic information about our user base as individuals and in the aggregate.

A "cookie" is a small text file that is stored on an individual's computer and downloaded to the computer or mobile device when they visit a website. Cookies then send information back to the originating website on each subsequent visit, or to another website that recognizes that same cookie. We use the following types of cookies:

• Essential Cookies are required to make our Site function properly and cannot be turned off in our systems. If you block these cookies, portions of our Site may not function properly.
• Performance and Functional Cookies allow us to count visits and sources of traffic on our Site so we can measure and improve performance and functionality. By means of example, they help us know which features of the Site are used most and how visitors move around the Site.
• Targeted Advertising Cookies may be used to analyze how you use this website, store your preferences, and provide the content and advertisements that are relevant to you.
• Social Media Cookies allow you to share information using social media sharing buttons on social networks like Facebook, Instagram, LinkedIn, or Twitter. This information may then be used by the social media network to deliver targeted advertising to you.

We may combine information collected automatically (as described above) from your interactions with our Services and your activity on third-party sites with other data (including personal information).

If you wish to opt out of allowing certain cookies, you may submit a request to support@trugamer.com. Please note that if you delete, block, or otherwise restrict cookies, or use a different computer or Internet browser, you will need to renew your cookie management choices.

If you, or someone acting on your behalf, would like to request that we do not sell your personal information, you can send an email to support@trugamer.com.

3. HOW WE USE YOUR PERSONAL INFORMATION

We may use your information for purposes including:

• Providing services and features
• Customer support
• Research and development
• Communications from Trugamer
• Legal requirements and other legal purposes

4. WHEN WE SHARE YOUR PERSONAL INFORMATION

We may disclose your information to:

• Advertisers, Advertising Networks, and Other Third Parties: We may disclose information about how you use the Services and interact with content or ads to better tailor services, products, marketing and advertising on the Services and on third-party platforms. To enable these purposes, we may share certain demographics and interest information, user-generated content, device information and identifiers, connection and usage data, geolocation data, public and commercial information, and social media information. These third parties may use their own tracking technologies to collect or request information about you.
• Social Networks: We may disclose your information to social media platforms for example, if you click on a Facebook “like” button on the Services, the “like” may appear on your Facebook account. To control this sharing of information, please review and adjust your privacy settings for the relevant social network. Depending on your privacy settings and actions on such network, we may disclose contact information, identification and demographic and interest information, user-generated content, device information and identifiers, connection and usage data, and social media information.
• Service Providers: We engage vendors to perform services for business purposes on our behalf and provide information to them to enable them to provide us with such services, including research and analytics, hosting, transaction and payment processing, promotion administration, fraud prevention, identity management, acquisition and other services. Service providers may use such information for their operational purposes in order to provide their services to us.
• Search Engines: You may be able to engage with other members of the Services or the public. This may make the name and photo associated with your profile and any comments or user-generated content you provide visible to other members of the Services or the general public. If the information is available to the general public, it may also be searchable by search engines.
• Law Enforcement, Regulators, Anti-fraud Coalitions and Other Groups: We disclose any of the categories of information we collect, as appropriate, with these third parties in order to: protect and enforce the legal rights, privacy, and safety of ourselves and our visitors; protect against possible fraud or other illegal activity; respond to requests from government and other authorities; and otherwise comply with legal process.
• Other Sharing: We may provide connection and usage information about you, often along with a hashed or masked identifier (contact information), with third parties such as partners and social networks to inform the advertising and other offers we send you and for advertising measurement or analytics.
• Sale or Transfer of All or Part of Our Business or Assets: In the event that Trugamer is involved in a merger, acquisition, transfer of control, bankruptcy, reorganization or sale of assets, we may sell or transfer the information described in this Privacy Policy as part of that transaction or diligence associated with or in contemplation of such matters.

5. INFORMATION RETENTION AND DELETION

We retain information for as long as you remain a Trugamer user, plus as long as is necessary to protect and preserve our legal interests. Users may request deletion of their accounts at any time.

6. CHILDREN

Trugamer does not knowingly request or collect personal information from anyone younger than 18 years old without prior consent from a parent or legal guardian, and thus Trugamer requests that if you are under 18 we ask that you do not use the Services or provide us with any information. If we discover that we have inadvertently gathered any such information then we will, to the extent required by law, delete such information from our records. Please contact support@trugamer.com if you believe your child under age 18 has submitted personal information to Trugamer without prior parental or legal guardian consent so that we can take steps to delete the information.

7. YOUR RIGHTS

Depending on where you live, you may have certain rights with respect to your information. Upon submittal of a request and confirmation of your identity, we will respond in accordance with and within the time period prescribed by applicable law. We will take reasonable steps to confirm your identity.

Some types of requests you may submit are as follows:

• Request Categories of Information: If you, or someone acting on your behalf, would like to request that we tell you the categories of personal information we collect, the categories of sources from which personal information is collected, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with which the business shares personal information, the categories of information about you that we sell, the categories of third parties to whom the personal information was sold, or the categories of personal information that were disclosed for a business purpose, you or someone acting on your behalf can send an email to support@trugamer.com.
• Request Specific Information: If you, or someone acting on your behalf, would like to request that we tell you about some of the specific personal information that we hold about you, you or someone acting on your behalf can send an email tosupport@trugamer.com.
• Request Correction: If you would like to request that we correct certain personal information that we hold about you, you can send an email to support@trugamer.com.
• Request Deletion: If you, or someone acting on your behalf, would like to request that we delete information that we hold about you, you or someone acting on your behalf can send an email tosupport@trugamer.com. Please note that certain information about you may not be deleted if you request such a deletion, as permitted by law. Also note that we will not be able to provide you with certain Services upon a deletion. You will also need to clear your cookies and re-set your cookie preferences.

8. POLICY UPDATES

Trugamer may make changes to this Policy from time to time and may apply any changes to information previously collected, as permitted by law. Please be sure to check this Policy for updates.

The date of this Privacy Policy indicates the most recent updated version. If Trugamer makes material changes to this Policy, we will notify you, such as by posting the updated Policy on the Websites or Apps, and/or as otherwise required by applicable law.

9. INTERNATIONAL USE

Please be advised that Trugamer is headquartered in the United States and may transfer your information to those parties described in this Privacy Policy outside of your country of residence, including in the United States and other countries. This is necessary to provide the Services and for the purposes outlined in this Privacy Policy. Data privacy laws vary from country to country, and they may not be equivalent to, or as protective as, the laws in your home country. Trugamer, to the best of its ability, will take steps to ensure that reasonable safeguards are in place with an aim to ensure an appropriate level of protection for your information, in accordance with applicable law. By providing us with your information, you acknowledge any such transfer, storage or use.

10. CONTACT US

If you have questions about this Policy or our privacy practices, please contact us at support@trugamer.com.