Privacy Policy

1.1 Who We Are. The Company operates the Platform and is responsible for the personal information described in this Policy. The Company’s address is 4 West 4th Avenue, 6th Floor, San Mateo, California 94402, and you may contact the Company about this Policy at privacy@versezero.com.

1.2 Whom This Policy Covers. This Policy covers (1) players who play without an account (“Guests”), (2) players who hold an Account (“Account Holders”), (3) developers who register under the Developer Terms (“Developers”), and (4) anyone else who visits the Platform or contacts the Company. The Policy describes Guests, Account Holders and Developers separately, because the Company collects different information from each.

1.3 What This Policy Does Not Cover. This Policy does not cover websites or services the Platform links to, the services of an advertising network to the extent it acts on its own behalf, or the services of the provider of a Connected Model Account (as defined in the Developer Terms). Each of those is governed by its own privacy policy.

1.4 Relationship to the Terms. Where the User Terms or the Developer Terms refer to this Policy for a choice, control or commitment made available to you, that part of this Policy forms part of those terms.

1.5 One Standard Everywhere. The Company gives the rights and protections described in this Policy to everyone, wherever they live. A few statements in this Policy are required by the law of one place only, and each of them says where it applies. This Policy is written to meet the privacy laws of the United States, including the California Consumer Privacy Act, as amended, and its regulations (together, the “CCPA”); the General Data Protection Regulation (EU) 2016/679 and the United Kingdom General Data Protection Regulation and Data Protection Act 2018 (together, the “GDPR”), under which the Company is the controller of your personal data; and the Personal Information Protection and Electronic Documents Act of Canada and, for Quebec, the Act respecting the protection of personal information in the private sector. In this Policy, “personal information” includes personal data within the meaning of the GDPR.

2.1 What We Collect. When you play as a Guest, the Company collects:

(a) a random guest identifier and a random security code that works like a password, so that only your browser can use that identifier, stored in cookies that the Platform sets when you open a game and that let the Platform recognize your browser as the same Guest for up to thirty (30) days, as described in the Company’s cookie policy, available at www.versezero.com/cookies (the “Cookie Policy”). The Company stores the security code only in a protected, hashed form;

(b) information about how you use the Platform and each game, including the games you are shown and whether you open, skip, like or share them, how long you play each game and when you leave it, the text you enter in the search box, any feedback you give and, where the Company records it, what you do, type, select or say within a game, including your control inputs and recordings of your gameplay (“Gameplay Data”);

(c) information your browser sends when it connects to the Platform, including your internet protocol address and browser type, which the Company’s hosting and security providers use to deliver and secure the Platform, and from which the Company may derive your country to apply the parts of this Policy that depend on location. The Company does not store the internet protocol address or browser details of a Guest in its own database. Where the Platform asks you to show that you are a person and not an automated program, such as by completing a challenge (a “Human Verification”), the provider of the Human Verification receives your internet protocol address and information about your device, which it uses to tell people from automated programs and to improve its service for doing so;

(d) basic usage statistics and error reports, including before you answer the cookie banner, as described in the Cookie Policy; and

(e) a record of the version of the User Terms and this Policy displayed when you first started a game, and again after any change to either of them, and of the choices you made in the cookie banner.

2.2 What We Do Not Collect. The Company does not ask a Guest for an email address, telephone number or date of birth, asks a Guest for a name only to join a friend party as described in Section 3.5 (Friend Parties and Voice), does not link a Guest’s activity to an Account, and does not use a Guest’s information for personalized advertising.

2.3 Advertising Shown to Guests. Advertising shown to Guests is contextual, as described in Section 9.2 (Contextual Advertising).

2.4 If You Create an Account. If you create an Account, the Company does not link the Gameplay Data recorded under your guest identifier to your Account. That Gameplay Data remains linked only to the guest identifier and is deleted as described in Section 2.5 (Deleting Guest Data).

2.5 Deleting Guest Data. The “Delete guest data from this browser” button on the Privacy page of the Platform deletes at once the guest identifier and the Gameplay Data and other records held for your browser. Otherwise, the Company deletes them automatically after thirty (30) days. The records described in Section 2.1(e) (What We Collect) are kept as described in Section 12.1 (Retention Periods).

3.1 Information You Give Us. When you create an Account, the Company collects your email address, a password (which the Company’s login provider stores only in a protected, hashed form), the display name you choose, if any, and your date of birth. The Company’s login provider records the internet protocol address and browser used to sign in, which the Company uses only to keep the Platform secure and to comply with law. Account confirmation and password reset emails are sent through an email delivery provider. Signing up, signing in, resetting a password and deleting an Account may each require a Human Verification.

3.2 Your Profile. Your profile consists of the display name you choose, if any, and the games you have liked. Your display name is shown on your Account page and to the other members of any friend party you join. Section 11 (Profiles and Social Features) of the User Terms describes what other players can see.

3.3 Activity Tied to Your Account. The Company collects the information described in Section 2.1 (What We Collect) in respect of your play, and associates it with your Account through an account identifier and a login cookie set when you sign in. That information includes the games you have liked and played, how often and for how long you play them, and your feedback. Scores and settings that an individual game saves are stored only on your device and are not sent to the Company.

3.4 Your Date of Birth. The Company uses your date of birth to apply the minimum age in the User Terms, to make sure that Account Holders under 18 years of age receive contextual advertising only and are not offered features unavailable to them, and for no other purpose. If the date of birth you enter shows that you are below the minimum age, the Company does not create an Account, does not keep the date of birth entered, and deletes the guest data held for your browser.

3.5 Friend Parties and Voice. When you start or join a friend party, the Company records who is in the party, the games played and the results of each match played together. The names of members, being your display name or the name a Guest enters, are not stored after the party ends. Party records are deleted when the party ends, and in any event within four (4) hours after it starts. The Company may make voice communication available within a friend party. Where it does, voice is transmitted in real time between the members of the party and is not recorded, retained, used to train any model or licensed to anyone. Voice communication is available only to Account Holders 18 years of age or over.

3.6 Communications. If you contact the Company, the Company keeps a record of your communication and the Company’s response. If you send feedback about a game, the Company keeps your comments, and any image you attach, with the game and version details. An image attached to feedback is kept while the Account from which the feedback was sent is open, and is deleted with that Account. An automated tool may summarize feedback, with a link to any image attached, in the Company’s internal issue tracker, which a third-party provider hosts.

4.1 Registration. When you register as a Developer, the Company collects your name, email address, country of residence, the developer name you choose and, where you register on behalf of an organization, the name and country of that organization and your role in it.

4.2 Payment, Tax and Verification. Payments to Developers are made through a third-party payout provider (the “Payout Provider”), which collects your payment details and tax documentation directly and verifies your identity and screens you against sanctions lists. The Company receives from the Payout Provider your payout status, your country, your tax classification, the outcome of verification and screening, and a record of each payment, and does not itself receive your bank account details or tax identification number.

4.3 Connected Model Accounts. If you connect a Connected Model Account, such as by signing in to your account with the provider of a model, the Company receives from the provider of that account the information it makes available to the Company, which ordinarily consists of your name, email address and profile picture, together with a token that allows the Company to use the account on your behalf. The Company does not receive your password for that account.

4.4 Your Games and the Creation Tools. The Company collects the Developer Games and Game Information you submit, your answers to the Developer Questionnaire, your Inputs to the Creation Tools and the Generation Records described in the Developer Terms. When you use the Creation Tools through a Connected Model Account, your Inputs are sent to the provider of that account and are processed by it under its own terms and your settings with it. The Company treats your Inputs and Generation Records in the same way as Gameplay Data, as described in Section 7 (Gameplay Data, Our Games and Our Models). The Creation Tools are available only to Developers.

4.5 Performance and Payment Records. The Company records the performance of your Developer Games, the Net Advertising Revenue attributed to them, the revenue share paid and any question you raise about a statement.

6.1 Purposes. The Company uses the information described in this Policy to:

(a) provide the Platform and the games, including remembering your progress and settings and operating your Account or developer account;

(b) generate the content of games, including the responses of characters within a game, as described in Section 7 (Gameplay Data, Our Games and Our Models);

(c) design, generate, improve and recommend games, and understand how the Platform is used;

(d) develop, train, test, validate and fine tune artificial intelligence models used by the Company, as described in Section 7.3 (Training and Improving Our Own Models);

(e) serve, cap the frequency of, measure and protect advertising, as described in Section 9 (Advertising);

(f) calculate, pay and report revenue share and administer any Incentive Program for Developers;

(g) keep the Platform secure, detect and prevent fraud, invalid traffic, cheating and abuse, and debug errors;

(h) moderate content, handle reports and complaints, give statements of reasons and apply the User Terms and the Developer Terms;

(i) apply the minimum age and the protections for players under 18 years of age;

(j) communicate with you about the Platform, your Account or developer account, and changes to the terms or to this Policy;

(k) comply with law, including tax, sanctions and record-keeping obligations, and respond to lawful requests from authorities; and

(l) establish, exercise or defend legal claims, including by keeping records of acceptance of the terms and of consent.

6.2 No Other Purposes Without Notice. The Company does not use personal information for a purpose materially different from those described in this Policy without telling you first and, where the law requires it, obtaining your consent.

6.3 Legal Bases Under the GDPR. Where the GDPR applies, the Company relies on the following legal bases:

(a) performance of a contract, being the User Terms or the Developer Terms, to provide the Platform and the games, generate game content, operate Accounts and developer accounts, and calculate and pay revenue share (Section 6.1(a), (b) and (f));

(b) legitimate interests, being the Company’s interests in improving and recommending games, developing, training and improving the artificial intelligence models on which its games are built, creating De-identified Information, understanding how the Platform is used, including through the usage statistics and error reports described in the Cookie Policy, keeping the Platform secure, preventing fraud and abuse, moderating content and defending legal claims, which the Company has balanced against your rights, taking into account the safeguards in Section 7.4 (Your Right to Object to Training) and Section 8.3 (Our Commitment Not to Re-identify) (Section 6.1(c), (d), (g), (h) and (l)); you may obtain information about that balancing by contacting the Company;

(c) consent, for non-essential cookies and the processing that depends on them, including analytics and the delivery and measurement of advertising, and for promotional emails (Section 6.1(e) and (j)); and

(d) compliance with a legal obligation, including obligations under Regulation (EU) 2022/2065 and the Online Safety Act 2023, tax and sanctions law, and record-keeping obligations (Section 6.1(h), (i) and (k)).

6.4 Automated Decisions. The Company does not make decisions based solely on automated processing that produce legal effects concerning you or that similarly significantly affect you. Some decisions to remove content or to restrict, suspend or close an Account may be taken by automated tools, as described in Section 25.1 (How the Company Moderates Content) of the User Terms. You may complain about any such decision under Section 25.4 (Complaints) of the User Terms, and a person considers each complaint.

6.5 Consent Under Canadian Law. In Canada, the Company relies on your consent to the collection, use and disclosure of your personal information described in this Policy, which you give by using the Platform after this Policy has been made available to you. You may withdraw consent at any time, subject to legal and contractual restrictions, though doing so may mean that the Company cannot provide some or all of the Platform.

7.1 Why Gameplay Data Matters. The Platform is built on the idea that games improve by learning what players enjoy. Gameplay Data shows the Company which games are played, how they are played, and where players lose interest, and the Company uses this information to design and generate better games and to recommend games to players.

7.2 Models Provided by Third Parties. The Company uses artificial intelligence models provided by third parties in two ways. First, the Company uses those models to design and build the games it publishes, and Developers may use them through the Creation Tools as described in Section 4.4 (Your Games and the Creation Tools). Second, some games may use a model while you play to generate content, such as the responses of a character, from what you type, select or say. When that happens, your input and the context of the game are sent to the provider of the model, directly or through a service that routes requests to that provider, to produce the response. The Company uses those providers, and any such routing service, only under terms under which they do not use your inputs, or the content generated from them, to train their own models.

7.3 Training and Improving Our Own Models. The Company may use Gameplay Data, Contributions, Generated Content, and, for Developers, Developer Games, Inputs and Generation Records, to develop, train, test, validate and fine tune artificial intelligence models used by the Company, including models that design games and models that recommend games to players.

7.4 Your Right to Object to Training. You may object at any time to the use of your information for the purposes in Section 7.3 (Training and Improving Our Own Models), through the setting in your Account or the setting on the Privacy page of the Platform, which a Guest may use without an Account, where those settings are available, or by email to privacy@versezero.com. The Company then stops using your information for those purposes, except that the Company is not required to alter a model already trained before your objection. The Company does not use the information of players it knows to be under 18 years of age for those purposes.

7.5 What Is Not Used. The Company does not use voice communication between players, the audio of anything you say to a game, the content of messages between friends, payment or tax information, or dates of birth to train any model.

7.6 Speaking to a Game. The Company may offer games that let you speak to a character or to the game instead of typing. Where a game does so, the microphone is used only after you switch it on in that game, and the game tells you that your speech is converted to text by a third-party service provider. The audio is sent to that provider to be converted to text and is not kept by the Company, and the Company does not permit the provider to keep the audio or to use it to train its models. The text is Gameplay Data. Neither the Company nor the provider uses your speech to identify or recognize you by your voice.

8.1 What It Is. The Company creates information that does not identify, and cannot reasonably be used to identify or be linked to, any individual or device, from Gameplay Data and other information described in this Policy (“De-identified Information”), including statistics that combine the information of many players.

8.2 How It Is Used and Shared. The Company may use and disclose De-identified Information for any purpose, including to improve the Platform, to develop games, for research, and to license or provide it to third parties, including developers of artificial intelligence models, for the development, training, testing and evaluation of their models.

8.3 Our Commitment Not to Re-identify. The Company maintains and uses De-identified Information only in de-identified form, does not attempt to re-identify it, except to test whether its de-identification processes are effective where the law permits that, takes reasonable measures to ensure that it cannot be associated with an individual or household, and contractually requires every recipient of De-identified Information to comply with the same obligations and not to attempt to re-identify it. This commitment is made publicly to everyone, including for the purposes of California Civil Code section 1798.140(m).

9.1 Advertising. The games are free, and the Company may fund the Platform through advertising served by third-party advertising networks engaged by the Company. This Section 9 describes how advertising works when the Company shows it.

9.2 Contextual Advertising. Guests, players located outside the United States and Account Holders under 18 years of age see only contextual advertising. Contextual advertising is selected from the content of the page or game being played and does not draw on a profile of you or on your activity over time or across other websites or services. To deliver it, the advertising network receives the information a browser ordinarily sends to display content, such as your internet protocol address, browser type and approximate location, and the Company requires the network by contract to use that information only to deliver, measure, cap the frequency of and protect the advertisement, and not to build a profile of you.

9.3 Personalized Advertising for Adults in the United States. Where you are an Account Holder located in the United States and 18 years of age or over, advertising shown to you may be personalized, meaning that it is selected using information about you, including your activity on the Platform and identifiers associated with your browser or device. To serve personalized advertising, the Company makes identifiers and information about your activity available to advertising networks, which may combine it with information they hold from other websites and services. Under the laws of California and several other states this may be a “sale” of personal information or “sharing” for cross-context behavioral advertising, or “targeted advertising”, and you have the right to opt out of it as described in Section 9.5 (Turning Off Personalized Advertising).

9.4 Players Under 18. The Company does not serve personalized advertising to anyone it knows to be under 18 years of age, and does not sell or share the personal information of anyone it knows to be under 18 years of age.

9.5 Turning Off Personalized Advertising. You may opt out of personalized advertising, and of any sale or sharing of your personal information, by (1) selecting the “Do Not Sell or Share My Personal Information” link in the footer of the Platform, (2) changing the advertising setting in your Account, or (3) sending a Global Privacy Control signal from your browser, which the Company treats as a valid opt-out as described in Section 17 (Do Not Track and Global Privacy Control). The Company applies your opt-out to your browser and to your Account, and displays confirmation that it has been processed. After you opt out, you continue to see advertising, but it is contextual.

10.1 Recipients. The Company discloses personal information to the following categories of recipients:

(a) providers of cloud hosting, database and login services, content delivery, storage, security and Human Verification, email delivery, issue tracking, customer support, artificial intelligence tools used to review feedback and investigate faults and other technology services, located in the United States, who process it on the Company’s behalf;

(b) providers of the artificial intelligence models used to generate content within games, and services that route requests to them, as described in Section 7.2 (Models Provided by Third Parties);

(c) advertising networks, exchanges and measurement and fraud prevention providers, as described in Section 9 (Advertising);

(d) providers of product analytics and error monitoring, as described in the Cookie Policy;

(e) for Developers, the Payout Provider and providers that verify identity and screen against sanctions lists, and tax authorities where the law requires it;

(f) other players, including the members of a friend party you join, who can see your display name, or the name you enter to join a party, as described in Section 11 (Profiles and Social Features) of the User Terms, and players who can see the developer name displayed with a Developer Game;

(g) Developers, who receive only aggregated statistics about how their Developer Games are played and no personal information about players;

(h) courts, regulators, law enforcement and other authorities, and the National Center for Missing & Exploited Children, where the Company is required by law to disclose information, including to report apparent child sexual abuse material, where disclosure is needed to protect the safety of any person, including under Section 25.6 (Serious Threats) of the User Terms, or to establish, exercise or defend legal claims;

(i) a buyer, successor or other party in connection with a merger, acquisition, reorganization or sale of all or part of the Company’s business, subject to this Policy; and

(j) anyone else with your consent or at your direction.

10.2 De-identified Information. Section 8 (De-identified and Aggregated Information) governs De-identified Information, which is not personal information.

10.3 No Sale for Money. The Company does not sell personal information for money. The only disclosure that may be a sale or sharing under state law is the disclosure for personalized advertising described in Section 9.3 (Personalized Advertising for Adults in the United States). The Company does not disclose personal information to third parties for their own direct marketing purposes.

10.4 Categories of Personal Information. This Section 10.4 is the Company’s notice at collection under the CCPA. Using the categories in the CCPA, the Company collects the personal information listed below, from the sources described in Sections 2 (When You Play as a Guest) to 5 (Information from Other Sources), for the purposes described in Section 6 (How We Use Information), which include running and securing the Platform, making and recommending games, showing advertising and training the Company’s own artificial intelligence models, to which you may object under Section 7.4 (Your Right to Object to Training). The Company discloses each category for a business purpose to the recipients described in Section 10.1 (Recipients). For each category, the list states whether it may be sold or shared and how long it is kept:

(a) identifiers, such as a guest identifier, account identifier, analytics identifier, display name, email address, internet protocol address and device identifiers: may be sold or shared to advertising networks, if the Company serves personalized advertising, only for Account Holders in the United States 18 years of age or over who have not opted out; kept for thirty (30) days for a Guest, for as long as the Account is open for an Account Holder, and for approximately thirty (30) days in request logs;

(b) personal information described in California Civil Code section 1798.80(e), such as a name and email address, and for Developers, records of payments: not sold or shared; kept for as long as the Account or developer account is open and, for Developer payment records, for seven (7) years after the last payment;

(c) characteristics of protected classifications, limited to date of birth and age: not sold or shared; kept for as long as the Account is open;

(d) internet or other electronic network activity information, including Gameplay Data: may be sold or shared to advertising networks, if the Company serves personalized advertising, only for Account Holders in the United States 18 years of age or over who have not opted out; kept for thirty (30) days for a Guest and for as long as the Account is open for an Account Holder, and, as statistics recorded under a random analytics identifier, for up to seven (7) years;

(e) geolocation data, limited to the country derived from an internet protocol address and not precise geolocation: not sold or shared, except as part of the information in clause (a) used for personalized advertising; kept with the information in clause (a);

(f) professional information, limited to the organization and role of a Developer: not sold or shared; kept for as long as the developer account is open;

(g) inferences drawn from the information above to describe a player’s game preferences: may be sold or shared to advertising networks, if the Company serves personalized advertising, only for Account Holders in the United States 18 years of age or over who have not opted out; kept for as long as the Account is open; and

(h) sensitive personal information, as described in Section 10.5 (Sensitive Personal Information): not sold or shared; kept for as long as the Account or developer account is open.

Records of acceptance of the terms and of consent choices, which include identifiers, are kept for four (4) years after the last use of the Platform, and Section 12 (How Long We Keep Information) sets out the other periods that apply. You may opt out of any sale or sharing through the “Do Not Sell or Share My Personal Information” link, as described in Section 9.5 (Turning Off Personalized Advertising).

10.5 Sensitive Personal Information. The Company collects Account log-in credentials and the personal information of players it knows to be under 16 years of age, each of which is sensitive personal information under the CCPA. The Company uses and discloses sensitive personal information only for the purposes the CCPA permits without a right to limit, including providing the Platform, security, fraud prevention and compliance with law, and does not use it to infer characteristics about you. The Company therefore does not offer a right to limit the use of sensitive personal information.

12.1 Retention Periods. The Company keeps personal information for the following periods, after which it is deleted or converted to De-identified Information:

(a) cookies: the periods stated in the cookie list described in the Cookie Policy;

(b) Gameplay Data and other information linked to a guest identifier: thirty (30) days, or less where you use the button described in Section 2.5 (Deleting Guest Data);

(c) Account information and the activity tied to an Account: for so long as the Account is open. When an Account is deleted, the Company deletes the activity tied to the Account at once, and the login provider deletes the login details. The login provider keeps its log of sign-ins, which records the internet protocol address and browser used, for seven (7) days, and the record of each login session until you sign out, the session has gone unused for thirty (30) days or the Account is deleted;

(d) request logs kept by the Company’s hosting provider, which include internet protocol addresses and browser details and may include the text entered in the search box: approximately thirty (30) days, except where needed longer to investigate a security incident or fraud;

(e) statistics recorded under a random analytics identifier, whether held by the Company or by its analytics provider, including play statistics, records of the games shown and opened, and feedback comments: up to seven (7) years. Deleting your Account or your guest data removes the only link between that identifier and you, after which those statistics are De-identified Information;

(f) records of friend parties: until the party ends, and in any event no more than four (4) hours after it starts;

(g) records of acceptance of the terms and of consent choices: four (4) years after the last use of the Platform by the browser or Account concerned, including after the guest data or the Account concerned is deleted;

(h) Developer registration, performance and payment records: for so long as the developer account is open, and for seven (7) years after the last payment, to meet tax and accounting obligations;

(i) Inputs and Generation Records: for so long as the Tool-Built Game concerned is published, and for three (3) years afterwards, to establish its origin if a claim is made;

(j) reports, complaints, statements of reasons and moderation decisions: three (3) years after the decision;

(k) error reports: ninety (90) days; and

(l) images attached to feedback: for so long as the Account from which the feedback was sent is open.

12.2 Longer Retention. The Company may keep information for longer where the law requires it, or while it is needed to resolve a dispute, enforce the terms or respond to a legal claim or a request from an authority. Where the Company reports apparent child sexual abuse material to the National Center for Missing & Exploited Children, the Company preserves the contents of the report for one (1) year after the report, as United States law requires.

15.1 Minimum Age. The Platform is a general audience service and is not directed to children under 13 years of age. Players must be at least 13 years of age, and at least 16 years of age in the European Economic Area and the United Kingdom, as described in Section 3 (Eligibility and Age) of the User Terms. The Company does not knowingly collect personal information from a child under 13 years of age.

15.2 If We Learn a Player Is Under the Minimum Age. If the Company learns that it has collected personal information from a player under the applicable minimum age, the Company closes any Account held by that player and deletes that information, except to the extent the law requires the Company to retain it. A parent or guardian who believes that a child has used the Platform may contact the Company at the address in Section 19 (Contact Us).

15.3 Protections for Players Under 18. For an Account Holder the Company knows to be under 18 years of age, the Company serves contextual advertising only, does not sell or share personal information, does not offer voice communication, keeps that player’s settings at high privacy by default, does not make that player’s profile public, does not use that player’s approximate location except to apply this Policy, and uses that player’s personal information for profiling only to the extent necessary to provide the games the player chooses to play.

15.4 Removal of Content. A registered player under 18 years of age who resides in California may request the removal of content that player has posted on the Platform, as described in Section 24.9 (Removal of Content Posted by a Player Under 18) of the User Terms.

16.1 Choices Available to Everyone. Wherever you live, you may (1) refuse or withdraw consent to non-essential cookies through the cookie settings link, (2) opt out of personalized advertising under Section 9.5 (Turning Off Personalized Advertising), (3) opt out of promotional emails using the link in each email, (4) update your Account or developer account information, (5) close your Account under Section 16.1 (Ending the Terms) of the User Terms, and (6) as a Guest, delete the guest data held for your browser as described in Section 2.5 (Deleting Guest Data).

16.2 Your Rights. Wherever you live, you may ask the Company: (1) to confirm whether it holds personal information about you, and to tell you the categories and specific pieces of personal information it holds, the categories of sources, the purposes and the categories of recipients to whom it has been disclosed, sold or shared; (2) for a copy of your personal information in a structured, commonly used and machine-readable format; (3) to correct inaccurate personal information; (4) to delete your personal information; (5) to restrict the processing of your personal information while a request or objection is considered; (6) to stop processing your personal information on the basis of the Company’s legitimate interests, including for training under Section 7.4 (Your Right to Object to Training), which the Company will do unless it has compelling legitimate grounds; (7) to withdraw any consent you have given, without affecting processing before the withdrawal; (8) to opt out of the sale and sharing of your personal information and of targeted advertising, as described in Section 9.5 (Turning Off Personalized Advertising); and (9) to be told the information used to make a decision about you based solely on automated processing, and to have a person review that decision, as described in Section 6.4 (Automated Decisions). The Company does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects. These rights are subject to the exceptions the law allows, such as where the Company must keep information to comply with law.

16.3 How to Make a Request. You may make a request by email to privacy@versezero.com. A Guest may delete the guest data held for the Guest’s browser at any time, without contacting the Company, as described in Section 2.5 (Deleting Guest Data). Because the only information that links guest data to a Guest is the guest identifier stored in the Guest’s browser, the Company asks a Guest to make any other request through the controls on the Privacy page of the Platform, where available, from the browser used to play, so that the Company can match the request to the guest data. Where those controls are not available, a Guest may make a request by email, although the Company may be unable to match it to any guest data. The Company verifies each request by matching the information you provide with information the Company holds, and may ask for more information for that purpose, but does not collect more than it needs to verify the request. If the Company cannot match a request to information it holds, the Company will tell you. An authorized agent may make a request on your behalf where the law permits.

16.4 Responses, Appeals and Complaints. The Company responds to a request within four (4) weeks, which may be extended by up to a further four (4) weeks where reasonably necessary, in which case the Company tells you. If the Company declines a request, you may appeal by replying to the Company’s decision or by email to privacy@versezero.com with the subject line “Privacy Appeal”, and the Company tells you the outcome of the appeal, and the reasons for it, in writing within forty-five (45) days. You may also complain to the privacy regulator where you live, such as the attorney general of your state in the United States, the data protection supervisory authority of the country in which you live or work in the European Economic Area, the Information Commissioner’s Office in the United Kingdom, the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d’accès à l’information.

16.5 No Discrimination. The Company does not deny you service, charge you a different price or provide a different quality of service because you exercise a privacy right, except that the Platform cannot offer Account features after an Account is deleted.