PowerPlay Strategies Corp, on behalf of its subsidiaries and divisions (collectively, “PowerPlay,” “us,” “we,” or “our”) is committed to building user trust and confidence by promoting, and complying with, business practices that help protect the privacy of our customer and user data.  This Privacy Policy covers all information collected through our PowerPlay Strategies Corp., VIPAwards Platform, and PowerPlay Events businesses, and their parents, subsidiaries and divisions.

PowerPlay has prepared this Privacy Policy to describe to you, or if you represent an entity or other organization, that entity or organization, (in either case, “you,” “your,” or “User”) our practices regarding the personal information that PowerPlay collects, uses, and shares regarding our online platforms (the “Platform”), and any other websites operated by PowerPlay or its subsidiaries and divisions (each, a “Site”) or using mobile applications provided by and on behalf of PowerPlay or its subsidiaries and divisions (each, an “Application,” and each Site and Application treated as a part of the “Platform” for purposes of this Privacy Policy). 

PowerPlay reserves the right, at any time, to modify this Privacy Policy.  If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy.  You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices.  We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy.  

Please read this Privacy Policy carefully to understand PowerPlay’s views and practices regarding your personal information and how we will treat it.  By visiting this Platform, you are freely accepting and consenting to the practices in this Privacy Policy.  You may withdraw your consent at any time and for any reason with effect to future data processing by contacting us at the address listed below in the Section titled “Communications”.  Without your consent, PowerPlay will use personal information, only insofar as such processing is permitted by applicable law (e.g., for the performance of a contract or agreement between PowerPlay and you) or where such processing is necessary for compliance with a legal obligation to which PowerPlay is subject.

COLLECTION OF PERSONAL INFORMATION

Through your interactions with the Platform, PowerPlay collects “personal information,” which is information that identifies an individual or relates to an identified individual.  Non-personal information means information that does not directly identify an individual.  We collect both types of information about you. 

The following provides some examples of the type of data that we collect from you:

Context	Types of Data and Purpose for Collection
Registration Information	When you create an Account, we may collect your name, contact information, and other Registration Information. Such information shall be associated with your Account, and you may update such information by editing the information associated with your Account.
Cookies	We may use cookies and clear GIFs.“Cookies” are small pieces of information that a website sends to your device while you are viewing a website.Among other things, cookies allow us to provide you with a more personal and interactive experience and to improve our marketing efforts.If you choose to disable cookies some areas or features of our websites may not work properly.
Demographic Information	We may collect personal information from you, such as your age, photo, or location.
Digital Fingerprinting	We may from time to time use digital fingerprinting technologies in an effort to protect and ensure the integrity of our Platform. In general, digital fingerprinting technologies assign a unique identifier or “Machine-ID” to a user’s computer to identify and track the computer’s survey activity. PowerPlay will not use digital fingerprinting technology to collect personal information, or track the online activities of the user of a computer, and will not disrupt or interfere with the use or control of a computer or alter, modify or change the settings or functionality of a computer. The technology will analyze publicly available information and data obtained from the computer’s web browser and from other publicly available data points, including without limitation the technical settings of the computer, the characteristics of the computer, and the computer’s IP address, to create a unique identifier assigned to the computer. The unique identifiers are typically alpha-numeric IDs and after creating the unique identifier, PowerPlay does not retain the information analyzed by the technology to create the unique identifier.
Geo-Location Information	When you use one of our Applications or a badge or device provided by PowerPlay, we may collect your location using GPS, Wi-Fi, cellular technology, Radio-frequency identification (RFID), Bluetooth Low Energy (BLE) beacon technology, or other similar location-tracking technologies. PowerPlay may capture proximity and duration information for providing personalized products and services, demographic analysis, or behavioral analysis. Such information, and any derived information, may be shared with third parties that have a relationship with PowerPlay.
Email Interconnectivity	If you receive email from us, we may use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.
Employment	If you apply for a job posting, or become an employee, we may collect personal information necessary to process your application. This may include, among other things, your Social Security Number or tax identification number.
Feedback/Support	If you provide us feedback or contact us for support we will collect your name and e-mail address and possibly other personal information, as well as any other content that you send to us in order to reply.
Mailing List	When you sign up for one of our mailing lists we may collect your email address or postal address.
Market Research Studies	We perform marketing research studies to collect data for research purposes. The information you provide is used for research analysis and we analyze the answers in aggregate. Information you provide in response to or in connection with a market research study is and will be provided to our clients or other entities or the public as part of cumulative market research information or statistical data in the ordinary course, but without identifying you individually, directly or indirectly.
Mobile Devices	We may collect information from your mobile device such as unique identifying information broadcast from your device or hardware and software specifications.
Order Placement	We may collect your name, billing address, shipping address, e-mail address, phone number, shipping preferences, and credit card number when you place an order.
Partner Promotion	We may collect information that you provide as part of a co-branded or sponsored promotion with another company or sponsor. Such information may be shared with the promotion partner or sponsor.
Sensitive Personal Data	We may collect a subset of personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. PowerPlay will collect sensitive personal data with your express consent or as otherwise permitted by applicable law.
Surveys	When you participate in a survey we may collect additional information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.
Third Party Tracking	We participate in behavior-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our websites, or on other websites.
Web logs	We may collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet), domain name, click-activity, referring website, or a date/time stamp for your visit. In addition to information stored by our servers, we may also use cookies and clear GIFs.

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

USE OF PERSONAL INFORMATION

In addition to the uses described above, PowerPlay uses the personal information collected in an effort to improve your experience on the Platform, to provide services to you, and to communicate with you about information that you request.  PowerPlay may also use personal information to help target specific offers to you and to help PowerPlay develop and improve its services.  Additionally, PowerPlay may use your personal information:

• To identify you when you access and use any Sites or Applications.
• To administer Accounts.
• To provide services and content to our clients, which may include your employer.
• To provide you with products and services you request, or that maybe be of interest to you.
• To improve our services and product offerings.
• To streamline your checkout process.
• To send marketing and promotional materials, including information relating to products, services, sales, or promotions.
• To respond to your inquiries related to support, employment opportunities, or other requests. 
• To conduct research and analysis.
• For internal administrative purposes, as well as to manage our relationship with you.

SHARING OF PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, PowerPlay may disclose personal information in the following situations:

• Subsidiaries and Acquisitions. We may share your personal information with our corporate subsidiaries and divisions (g., affiliates, parent company, sister companies, joint ventures, or other companies under common control).  If another company acquires any PowerPlay subsidiary, division, solutions, or our assets, we will also share your personal information with that company. 
• Other Disclosures with Your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy, and we may do so with your consent.
• Other Disclosures without Your Consent. We may disclose personal information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws.  We may also share your personal information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our Terms of Use, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
• Public.  Some of our Sites or Applications provide the opportunity to post comments, or reviews, in a public forum.  If you decide to submit information at these locations, that information may be publicly available.
• Partner or Client Promotions and Offerings.  We may offer events, contests, sweepstakes, promotions, or any other offerings with third party partners or our clients, which may be your employer.  The personal information that you submit through an event, contest, sweepstakes, promotion, or other offering may be combined and transmitted with the Registration Information related to your Account.  Third-party partners may collection information directly from you, which may be combined with personal information disclosed by PowerPlay.  This information may be collected through the Platform or during a PowerPlay Event.  If you decide to enter into or participate in an event, contest, sweepstakes, promotion, or other offering that is offered by PowerPlay, or a third-party partner or client, the information that you provide may be shared with us and with them.  Third party partners and clients that use PowerPlay products and services to collect personal information must agree to abide by the same principles followed by PowerPlay. 
• Service Providers. We may share your personal information with service providers.  Among other things service providers may help us to administer our website, plan or facilitate events or travel, conduct surveys, provide technical support, or sending marketing, promotions, and communications related to our business, payment processing, and for other legitimate purposes permitted by law. 

SECURITY OF PERSONAL INFORMATION

PowerPlay has implemented reasonable and appropriate security measures to help protect the personal information PowerPlay collects from loss, misuse, unauthorized access, disclosure, alteration, and destruction.  Although PowerPlay attempts to protect the personal information in its possession, no security system is perfect, and PowerPlay cannot promise that your personal information will remain absolutely secure in all circumstances.

RETENTION OF PERSONAL INFORMATION  

PowerPlay will retain your personal information as needed to fulfill the purposes for which it was collected.   PowerPlay will retain and use your personal information as necessary to comply with PowerPlay’s business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

DATA INTEGRITY AND PURPOSE LIMITATION

PowerPlay limits the use of personal information to ways that are compatible and relevant to the purposes for which the personal information was collected or subsequently authorized or for which consent was obtained.  PowerPlay will take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete, and current.

YOUR CHOICES

You can make the following choices regarding your personal information:

• Promotional Emails.  You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties or PowerPlay’s clients.  You can stop receiving promotional emails by submitting a request at the contact in the “Communications” section below or following the unsubscribe instructions in e-mails that you receive.  Clicking on an unsubscribe link will take you to a webpage where you can complete the opt-out process.  Certain programs will provide a contact for support or other means to remove your name to remove your name from our contact list.  If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your Account, to fulfill orders you have made, to ask you to rate a product you purchased, event you attended, or other service-related communications.
• Changes to Your Personal Information.  We rely on you to update and correct your personal information.  Note that we may keep historical information in our backup files as permitted by law.  All requests to correct your information must be directed to the contact in the “Communications” section below.  
• Access to Your Personal Information.  If required by law (for example, the EU General Data Protection Regulation), upon request, we will grant reasonable access to the personal information that we hold about a User.  All requests must be directed to the contact in the “Communications” section below.
• Deletion of Your Personal Information.  Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.  Some Users may have the legal right (for example, under the EU General Data Protection Regulation) to request that we delete their personal information.  All deletion requests must be directed to the contact in the “Communications” section below.  We may also decide to delete your personal information if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other individuals or third parties.  When we delete personal information it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it.  In addition, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any of our agreements.
• Revocation of Consent.  We rely on the processing of personal information that you have provided.  If you revoke your consent for the processing of personal information, then we may no longer be able to provide you services.  In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity.
• Online Tracking.  We do not currently recognize browser signals of tracking preferences, which may include “Do Not Track” instructions.
• California Residents.  California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing.  If you are a California resident and would like a copy of such notice, please submit a written request to us using the information in the “Communications” section below. 
• European Economic Area Citizens.  Where you believe that we have not processed your personal information in accordance with the applicable provisions of the EU General Data Protection Regulation, you may lodge a complaint with the respective EU data protection authority (DPA).

COMMUNICATIONS

Questions, concerns, or complaints should be directed to our privacy agent as follows:

By phone: 703.644.4656 

By Email: info@powerplaycorp.com

Through Mail:
Attn: Angie Garrison, Administration Manager
PowerPlay Strategies Corp
7641 Long Pine Drive

Springfield, VA 22151

If PowerPlay is required to contact you about your personal information we may do so by mail, phone, or email.

Effective as of 7/9/2020.