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September 20, 2023
Dazzy Inc. (“Dazzy") will collect both personal information and non-personal information (collectively, "Information") and act as the data controller regarding your personal information. We take care of how your Information is processed and used.
This Privacy Policy:
● explains how Dazzy collects, stores, uses and transfers or discloses your Information;
● applies only to those Dazzy websites, products and services (“Properties”) that post, reference, or link to it. Generally, this Privacy Policy applies to Dazzy’s corporate sites, including http://www.activisionblizzard.com/. Other Dazzy Properties (for example, consumer facing websites applicable to a game) will post a different privacy policy applicable to those Properties.
● does not apply to Dazzy Media. The Dazzy Media Privacy Policy is available here.
Dazzy reserves the right to change this Privacy Policy at any time by posting a modified version online at https://www.dazzy.io/legal/privacy-policy, so please review it frequently to ensure you are aware of any changes. If Dazzy makes a material change to this Privacy Policy, we will provide notice to you in our Privacy Policy as posted and on the Dazzy home page.
Please note your use of this Dazzy website, product or service is also subject to the terms of the Terms of Use available here.
1. Scope of Dazzy Privacy Policy
2. ESRB Privacy Certified Program
3. Information We Collect and How We Use It
5. Your Choices
7. Security
8. Accessing Information and Retention Period
10. Users in the US
11. Users in the EEA
12. Disclosure to Users Outside the US and the EEA
13. Cookie Policy
This Privacy Policy applies only to those Dazzy Websites and Properties that post, reference, or link to it.
This Privacy Policy does not apply to third party websites or online properties to which our Properties may link, and you accept that Dazzy is not responsible for the security or privacy practices of any such third party websites or properties. Sometimes we may direct you to a site operated by a vendor or partner. Even though the page where you provide information may have the look and feel of the Properties, a different privacy policy may govern that information collection by our vendor or partner.
This Privacy Policy also does not apply to the websites, products, or services of Dazzy group companies that do not post, reference or link to it. When visiting or using other Dazzy group companies’ websites, products, or services, you will be subject to their Privacy Policies.
This Privacy Policy does not cover Information provided when you apply for a job at Dazzy. Please refer here for more information.
This Privacy Policy and the ESRB certification seals on our Properties confirm that Dazzy is a valid licensee and participating member in the Entertainment Software Rating Board's ("ESRB") Privacy Certified Program. To protect your privacy, we have voluntarily undertaken this privacy initiative and ESRB Privacy Certified has reviewed and certified that we meet established online information collection and use practices on all Dazzy Properties where this Privacy Policy is posted.
Dazzy collects Information about you from you and other sources. As set out below in greater detail, as well as in Section 10 for US residents, we use and in specific cases combine that Information to operate, tailor content, personalize, adjust and improve our Properties, and to send you information about our press releases, SEC filings, events & presentations and stock information, as well as other messages, including for marketing and promotional purposes.
a. Dazzy does not knowingly collect or store any personal information from children under 13 in the US or under the relevant age threshold in other jurisdictions where the child is located. However, we may collect technical information required for delivering the service and for the support of our internal operations from all users of our Properties. If parents believe that we have unintentionally collected their children’s other personal information or otherwise used their children’s personal
information for another purpose, they may contact us via the Contacting Us section below. We recognize a special need to protect the personal information of children. We urge parents to instruct their children to never give out their real names, addresses, phone numbers, or other personal information without parental permission, when online. Dazzy also recommends that parents familiarize themselves with parental controls available on consoles, mobile telephones, tablets and other devices they provide to their child and accompany their child when online. Parents should contact Dazzy immediately if they have any concerns. Please see the Contacting Us section below for further details.
a. You have choices over the Information provided by you and by other sources, and how that Information is used by Dazzy. You can exercise your choices by updating your preferences at any time and also by managing your settings on your devices and third-party accounts.
As set out with greater detail below, and in Section 10 for US residents, Dazzy shares Information:
a. With the various Dazzy group companies for the purposes described in this Privacy Policy;
b. with vendors and partners engaged by Dazzy to provide you with goods or services you have requested or online advertising selected by us;
c. if required to do so by applicable law, regulation or legal process;
d. if necessary to exercise, establish or defend our legal rights;
e. if necessary to protect the rights, property or safety of any person; and
f. in connection with the sale of our business or assets.Any information, including personal information that you reveal in a bulletin board, message board, chat room or other public forum is publicly viewable.
a. Dazzy takes a range of security measures -- as set out in detail below -- designed to help protect your Information. However, complete online and offline security can never be guaranteed, so you should always take care when sharing your information online.
a. If for any reason you are concerned with the way we are using your personal information, or would like to correct or request that we delete such personal information, you can send your request to us using the contact details set out in the
Contacting Us section below.
i. We delete your personal information which we process for the performance of the contract or based on your consent in case you terminate your contract with us, withdraw your consent or where you request us to delete your personal information in accordance with this Privacy Policy. As an exception, we will not delete your personal information where we still have a legitimate interest to use your personal information. For example, we may still retain your Information to resolve disputes, enforce our Terms of Use or other user agreements, or comply with legal requirements; in this case, your personal
information will be blocked from use for any other purpose. In any case, we will not retain or use your personal information longer than necessary for the purposes outlined in this Privacy Policy. Due to technical reasons, residual copies of Information that has been removed from your account and/or the Properties may remain in our backup systems for approximately one month.
a. To contact us, you can send us an email at privacy@dazzy.io, or write to us at: Dazzy, Inc., 14 NE 1st Ave, Miami, Florida 33132, ATTN: Privacy Team/Privacy Policy. You may also contact ESRB Privacy Certified if you have a question or complaint that has not been resolved to your satisfaction. Please see the ESRB
Privacy Certified Program section at the top of this Privacy Policy for further details
a. In addition to the information provided throughout this privacy policy, state privacy laws in the United States require that we disclose to consumers in those states
additional information about the processing of their personal information. Below we describe the purposes for which we use and disclose personal information and for each purpose, the categories of personal information we use and disclose and the categories of third parties to whom we disclose the personal information.
i. Service functionality: We use certain personal information to provide you with our Properties, products, and services, including to take steps to enter a contract with you, send service communications, provide Investor Relations functions, send you investor-related communications (such as financial
information, press releases, SEC filings and more), and conduct general business operations, such as accounting, recordkeeping, and audits, analyzing our performance, and meeting our legal obligations.
ii. Service improvement: To grow and improve our Properties, including to verify and maintain the quality of our services, develop new products and services, and understand how our Properties are being used, our user base, and the effectiveness of our marketing,
iii. Personalization: To offer you recommendations and tailor the Properties to your preferences.The personal information we collect and use for these purposes includes:
1. Personal information provided by you:
2. Contact information, including name and email address
3. Demographic information, including your gender, age, and country
4. Information contained in your communications to us, including when you contact Investor Relations
5. Any information that you provide by interacting with our Properties (please note that some comments or information may also be visible to other users of our Properties)
6. Information about your interests in and use of various products, programs, and services
iv. Personal information automatically collected:
1. Websites visited before and after you use a Property
2. Browser type and language
3. IP address
4. Coarse geolocation information
5. Hardware and software information
6. Purchase histories
7. Communications
8. Usage data
9. Social Media data
v. We disclose this personal information to:
1. Various Dazzy group companies
2. Service providers, vendors, and business partners, including media partners, investor relations support, consultancies, information technology providers, cybersecurity providers, accounting and auditing firms
b. Advertising and marketing: To send you marketing communications and newsletters, personalize the advertisements you see on our Properties and third-party online properties, and measure the effectiveness of our advertising.
i. The personal information we collect and use for this purpose includes:
1. Personal information provided by you
2. Contact information, including name and email address
3. Demographic information including your gender, age, and country
4. Any information that you provide by interacting with our Properties (please note that some comments or information may also be visible to other users of our Properties)
5. Information about your interests in and use of various products, programs, and services
6. Marketing preferences
7. Personal information automatically collected:
a. Websites visited before and after you use a Property
b. Browser type and language
c. IP address
d. Coarse geolocation information
e. Hardware and software information
f. Communications
g. Usage data
h. Purchase histories
8. We disclose this personal information to:
a. Various Dazzy group companies
b. Service providers, vendors, and business partners, such as online advertising partners, including partners who use
Cookies to personalize, retarget, and measure the effectiveness of advertising
c. These partners may combine this personal information with information that they have collected about you when you use their services (or the websites and services of third parties) to serve you more relevant ads or to improve the accuracy of their targeting and measurement systems
d. In some situations, we may disclose information to business partners for their direct marketing purposes only with your consent to the disclosure
ii. Security: To protect and secure our Properties, assets, network, and business operations; and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal; or when necessary to protect our property or rights or the safety of our employees, customers or other individuals. The personal information we collect and use for this purpose includes:
1. Personal information provided by you:
a. Contact information, including name and email address
b. Any information that you provide by interacting with our
Properties (please note that some comments or information may also be visible to other users of our Properties)
c. Personal information automatically collected, including by monitoring and recording on your device:
d. Websites visited before and after you use a Property.
e. Browser type and language.
f. IP address
g. Coarse geolocation information
h. Hardware and software information
i. Communications
j. Usage data
k. Purchase histories
l. We may disclose this personal information to:
m. Various Dazzy group companies, which may use the personal information for the purposes listed above
● Service providers, vendors, and business partners, such as cybersecurity providers, and information technology providers
● Other entities when we believe that this is necessary to protect the rights, property, or safety of any person
● Regulatory or law enforcement agencies.
n. Legal compliance: To comply with legal process, such as warrants, subpoenas, and court orders; to respond to lawful regulatory or law enforcement requests, such as when we have a good-faith belief that we must do so by law, including but not limited to disclosure to law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability; to exercise, establish, or defend our legal rights; to protect the vital interests of any person; and to comply with applicable legal requirements. Such personal information includes:
o. Any information requested through legal process or that we believe in good faith is necessary to respond to lawful regulatory or law enforcement requests for the purposes listed above.
p. We may disclose this personal information to
● Regulatory or law enforcement agencies, including jurisdictions outside of the United States where we
have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
● Our legal advisors or consultants.
● Corporate change: We may disclose any personal information that we have collected about you in connection with the sale of our business or assets in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event.
q. Dazzy is not responsible for the privacy practices of Dazzy group companies and the use of your personal information by the Dazzy group companies will be governed by those specific companies’ privacy policies, which you may find on each company’s website.
r. Your US Privacy Rights: Residents of some states have certain rights in relation to their personal information. We describe below the rights that may be available to you, depending on your state of residence.
s. Right to Request Access to Your Personal Information:
You may have the right to request, up to two times in a
12-month period, access to the personal information we have collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers to whom we sell, share, or disclose it. Please note that certain information may be exempt from such requests under law.
t. Right to Request Correction of Your Personal Information
You may have the right to request that in certain circumstances we correct personal information that we have collected about you. Some information may be exempt from such requests under law.
u. Right to Request Deletion of Your Personal Information: You may also have the right to request that we delete personal information that we have collected from or about you. Some personal information may be exempt from such requests under law. For example, we need certain types of personal information so that we can provide our Properties to you. If you ask us to delete it, you may no longer be able to access or use our Properties.
v. Limit Use of Your Sensitive Personal Information:
California residents have the right to limit our use of their sensitive personal information if we use such personal
information to infer characteristics about them. We do not currently use sensitive personal information for such purposes. In some states, we may be required to obtain your consent before collecting your sensitive personal information.
w. Sale and Sharing of Personal Information; Targeted Advertising : Under the laws of some states, consumers have the right to opt out of the sale of their personal information or the sharing of their personal information with third parties for targeted advertising (also known as cross-context behavioral advertising or interest-based advertising). We may allow third-party companies to collect information about your activity on our website, for example, through cookies, pixels, web beacons and social network plugins. These advertising entities use Information they collect to help us provide more relevant advertisements and for other purposes described in our Privacy Policy. You can control the sharing of your personal information for targeted advertising through our websites in the following ways:
● To set up cookie controls and opt-out of advertising cookies, including third-party advertising cookies, click here.
● You can also set up cookie controls through many browser settings and you can use industry-wide opt outs to control the use of cookies for interest-based advertising purposes.
x. The personal information collected through these methods is associated with your browser or device, so if you would like to opt out for this information you will need to disable cookies or trackers as described above. Because your opt-out preference is stored in a cookie, if you clear your cookies then we will not recognize your device or your choices, so you must opt out again. You may also disable non-advertising cookies through your browser or device settings.
y. In applicable states, where required, Dazzy recognizes Do Not Track settings and the Global Privacy Control.
z. In addition to the opt-outs related to advertising above, we support the applicable state laws by allowing residents to opt out of the sale or sharing of their personal information for targeted advertising by clicking here.
aa. How to Exercise Your Access, Correction, and Deletion Rights
You may exercise any privacy rights to which you are entitled by submitting your request to us at privacyrequests@dazzy.io.
bb. For security purposes, we will verify your identity – and may request information from you to do so – when you request to exercise your privacy rights.
cc. Some states permit you to designate an agent to make requests to exercise your rights as described above. We will take steps to both verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
dd. Once we have verified your identity (and your authorized agent, as applicable), we will respond to your request as appropriate. If we are unable to complete your requests, we will provide you information about the reasons that we could not comply with your request, as required by applicable law.
ee. Profiling
● We do not engage in “profiling” in furtherance of decisions that produce legal or similarly significant effects.
ff. Right to Nondiscrimination
● We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights, unless allowed under applicable law.
gg. Appeals
● Some state laws allow residents who are not satisfied with our response to their requests to appeal our decision by contacting us as described in the written notice we will provide to you.
hh. Additional Privacy Information for California Residents
ii. Notice of Privacy Practices for California Residents:
Depending on how you interact with us, Dazzy may collect the following categories of personal information about you. For information about the purposes for which we use and disclose information, and additional potential disclosures of personal information, please see Users in the US section above.
● Identifiers, collected from you, our social media pages, or third-party subscription service providers, may be disclosed to our service providers and may be sold to or shared with business partners.
● Protected classifications and other sensitive data, collected from you, may be disclosed to our service providers. We do not sell or share protected classifications and other sensitive data
● Commercial information, collected from you, may be shared with our service providers. We do not sell or share commercial information.
● Geolocation information, collected from you and our analytics and advertising partners, may be shared with our service providers. We may sell or share coarse location information to our advertising
partners; we do not sell or share precise geolocation information.
● Internet or electronic network activity information, collected from you and our analytics and advertising partners, may be shared with our service providers and may be sold to our advertising partners.
● Audio, electronic, visual, thermal, olfactory, or similar information, collected from you, may be shared with our service providers. We do not sell or share such
information.
● Inferences drawn about you, collected from you and our advertising and analytics partners, may be shared with our service providers. We may sell or share such information with our advertising partners.
● Content of communications, collected from you, may be shared with our service providers. We do not sell or share content of communications.
● Information of contacts that you supply to us may be shared with our service providers. We do not sell or share such information.
jj. We determine the retention period for each of the categories of personal information listed above based on (1) the length of time we need to retain the information to achieve the business or commercial purpose for which it was obtained, (2) any legal or regulatory requirements applicable to such
information, (3) internal operational needs, and (4) any need for the information based on any actual or anticipated
investigation or litigation.
kk. California residents have the right to opt out of the sale or sharing of their personal information, as explained here.
ll. We may need to collect your personal information in order to offer you the benefits and rewards you request. If we do offer you the chance to participate in such a program, your participation is optional. If you choose to participate, your participation will be subject to the applicable terms or conditions, and you may withdraw at any time. Your
information has no real currency value or its equivalent. mm. California Shine the Light Law: Since 2005, California
Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our customer's personal information with unaffiliated third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please send us an email to privacy@dazzy.io, or write us at: Dazzy, Inc., 14 NE 1st Ave, Ste 906, Miami, Florida 33132, ATTN: Privacy Team/Privacy Policy.
nn. California Privacy Rights for Minor Users: Since January 1, 2015, California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or delete information provided by you or publicly posted by you, by sending us an email asking us to delete certain posted content at privacy@dazzy.io. In the alternative, you may write to us at Dazzy, Inc., 14 NE 1st Ave, Ste 906, Miami, Florida 33132, ATTN: Privacy Team/Privacy Policy. We will be happy to review, update or remove information and/or content as appropriate. Residual copies of information and/or content that have been deleted from your account and/or the Properties may remain in our backup systems for approximately one month. We may still retain your Information to resolve disputes, enforce our user agreement, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose.
oo. Privacy Information for Nevada Residents: Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and services of interest to you and in the other ways described above. We do not believe that our sharing in this
regard would qualify as a sale under Nevada law.
Nonetheless, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to record your preference to opt out by emailing us at privacy@dazzy.io. Please note we may take reasonable steps to verify your identity and the authenticity of the request.
a. As set out in more detail below, we only process or transfer your personal information where we can rely on legal grounds and appropriate safeguards to do so. You also have additional rights regarding your personal information if you are located in the European Economic Area (“EEA”).
a. In addition, if you are a visitor to our websites or other online products and services from outside the U.S. and the EEA, the personal information you provide will be collected, processed and stored directly on, or transferred to, servers in the United States or other countries where Dazzy group companies or our other partners or vendors maintain facilities or business operations.
No matter where the Information is located, Dazzy takes commercially reasonable measures to safeguard your privacy rights in accordance with this Privacy Policy. If you do not agree to the collection, processing, storage and transfer of your Information, please do not provide your Information when requested and stop using our websites and other online products and services.
13. Cookie Policy: Dazzy uses Cookies and/or similar technologies on the Properties. A
"Cookie" is a small bit of record-keeping information that many websites and other online products and services often store on a user's computer or device in order to identify it and associate activity with it. Cookies make the interaction between you and the website faster and easier by letting you navigate between pages efficiently, storing your preferences, and generally improving your experience of a website. For more information about our use of technologies that are similar to Cookies, and your opt-out choices, please see the Flash Cookies, Web Beacons, IP Addresses section under Types of Cookies below. When visiting the Properties you can learn more about the types of Cookies collected and change your Cookie settings at any time by clicking the “Cookie Settings” link in the footer of our websites. We use Cookies to optimize your visit, make your browsing and user experience as effective as possible, and let you know about offers and features that we think will interest you. This means that if you disallow Cookies, your use of the Properties may be impaired. Depending on the Property you are using, and the country you are based in, Cookies may be set on your computer or device by either:
a. Dazzy – to recognize and associate activity with your computer or device when it visits a Property. Dazzy Cookies cannot be used to recognize or associate activity with your computer or device when it visits other, third party websites or online properties.
b. Third Parties – to enable third party features or functionality to be provided on or through our Properties or other online properties (e.g., advertising and analytics). The third parties that set these Cookies may be able to recognize your computer or device both when it visits the Properties or other online properties that use the third party's features and functionality.