PRIVACY POLICY

This Privacy Policy posted on this Site was updated and has an effective date of: September 13th, 2018.

Thank you for visiting SQAD, a place in cyberspace where anyone can find cool new content to watch. This Privacy Policy applies to SQADPLAY.com and any other website, mobile application, or other online service by SQAD (collectively, the "Site"). This Privacy Policy does not cover information we collect offline (unless specifically stated). SQAD is referred to in this Privacy Policy as "SQAD," "we" or "us." We provide this Privacy Policy to describe our online information-collection, disclosure, and consent practices.

SQAD, SQADPLAY.com and its services are designed and directed for users ages thirteen (13) and older.

Please review our full privacy policy below, but the following are a summary of key points we thought you would be most interested in:

o The Site does not require users to provide their name, address, or other contact information in order to watch any videos on the Site. However, the Site does collect personal information in limited circumstances including IP addresses and other persistent identifiers for internal operations purposes and email addresses (typically for one-time use of that information, such as to respond to a user's request or allow a user to enter a sweepstakes). The Site also may collect personal information from users 18 and over, such as when a user subscribes to a paid account.

o In order to make portions of the Site available for free, we have advertisements on the Site. We work with ad companies and other partners to facilitate the placement of these advertisements. However, we use only contextual-advertising methods and not "online behavioral" or "targeted" advertising methods.

o The Site, and its third-party service and content providers, may gather IP address, usage data and other information for research, analytical and other internal operations purposes by means of cookies, beacons and other technologies.

o Please review this Privacy Policy carefully. In addition, please review our Terms of Use, http://www.SQADPLAY.com/terms-use, which govern your use of the Site.

o Please feel free to contact us about any privacy related matters at: SQAD, 15315 Magnolia Blvd. Suite 225, Sherman Oaks, CA. 91403, Telephone:(844) 435-2323, Facsimile:(818) 436-7529, Email: info@SQADPLAY.com

1. The Information We Collect and How We Use It

At SQAD, it is our policy to provide content that requires minimum collection of information from our visitors. This section describes the information that the Site collects.

A. Personal Information

"Personal Information" is information that could reasonably be used to contact you or to identify you personally (for example, full name, mailing address, email address, or telephone number). Personal Information also includes your IP address or other unique identifier ("Device Identifier") that is associated, on a persistent or on-going basis, with your computer, mobile phone or other device (any, a "Device") you use to access the Site.

The Site automatically collects the Device Identifier of the Device you use to access the Site. The Site does not generally collect name, address, or other contact information from visitors who play games on the Site. However, we and our third-party service and content providers may collect your Device Identifier when you visit the Site. We, and our third-party service providers, use this information solely to support the Site's internal operations, including providing Site content; maintaining, securing, and analyzing the functioning of the Site; and serving contextual advertisements.

We may also ask users of the Site to provide their email address as part of the registration process. Email addresses collected on the registration form will not be stored in a retrievable form but instead will be immediately and irrevocably ciphered using a "hash" to create a unique code generated from the email address. We will retain the resulting unique code in order to respond to inquiries from the user regarding a lost user name or password.

We may also, on limited occasions, collect from a user name and/or online contact information (typically an email address), solely for the following purposes:

(1) We may collect email address and first name for user-requested activities that require only one-time use of that information, such as to respond to a direct request, to enter a sweepstakes or contest, or when using the Site's forward-to-a-friend function. For example, for sweepstakes and contests, email addresses are collected for the purpose of entering the online sweepstakes or contest on a one-time basis and are used to notify winners of the sweepstakes or contests once by email. Such information collected is used only to fulfill the specific one-time purposes and is deleted immediately thereafter.

(2) For the sole purpose of any of the following: to protect the security or integrity of the Site; to take precautions against liability; to respond to judicial process; and, to the extent permitted under other provisions of law, to provide information to law enforcement agencies or for an investigation on a matter related to public safety.

If a user chooses to create their own video on our Site and use our video upload feature to post it on the Site, we and our third party partners may collect any information that is contained in such video, such as the user's image or voice, for the sole purposes of hosting and exhibiting such video to the public on the Site.

In some cases, we will collect Personal Information from a user, such as in connection with his or her registration for a premium-account subscription with the Site, which requires payment in the form of a credit or debit card. We will use Personal Information collected from adults to process the transaction, to communicate with you regarding your account, and for internal business purposes. We will also use this Personal Information to provide information, products or services that you have agreed to receive or that we otherwise believe will interest you, including information and special offers from us and our third-party business partners. If you do not wish to receive promotional emails from us our third-party partners, please follow the unsubscribe links in such promotional emails.

B. Other Information

Some features on the Site may ask users to provide certain information that is not personally identifiable, such as city or state of residence, date of birth and gender. (Such demographic information is referred to collectively, along with Usage Information (defined below), as "Non-Personal Information.") We may use Non-Personal Information for a variety of purposes, including enhancing or otherwise improving the Site. Non-Personal Information is generally non-identifying, but, if we associate it with you as an identifiable individual, we will treat it as Personal Information.

While we may collect the birth dates of users of the Site, we use that information only for our own internal purposes and it is not associated with Personal Information. Additionally, we do not use the collection of birthdates to "age gate" the service or block portions of the Site from users who identify themselves as children.

When visitors come to our Site, we and our third-party service providers also may automatically collect some non-personally identifiable information such as the type of computer operating system you are using (e.g., Microsoft Windows or Mac OS), the type of browser you are using (e.g., Internet Explorer, Firefox), the domain name of the Internet service provider you are using (e.g., Verizon), your activity while visiting our Site (e.g., which of our pages you have viewed, the shows viewed, and the advertisements you have been shown) ("Usage Information"). We use Usage Information in order to optimize or improve our products, services and operations.

Devices and device system software provide certain opt-out choices that you can control. For example, Apple iOS and Google Play Services provide an opt-out choice that you can use to control in-app advertisements, and mobile device operating systems provide opt-out choices for push notifications or alerts and collection of location information. If you previously chose to receive push notifications on your mobile device from us but no longer wish to receive them, you can manage your preferences either through your device or app settings, depending on the type of device. Please consult your device settings for more information or to opt out using these mechanisms.

C. Collection Methods/Tracking Technologies

Our Site may use software technology such as "cookies," "flash cookies," "web beacons," "embedded scripts," or other similar technologies (collectively referred to as "Tracking Technologies"). These Tracking Technologies are used to help tailor our content, allow visitors to move between associated websites without logging into each site, and other purposes related to our management of the Site.

Cookies are small text files stored locally on your Device that help store user preferences. Flash cookies are data files placed on your Device via the Adobe Flash plugin, which may be built into or downloaded by you to your computer or other device. Flash cookies may be used for various purposes, such as enabling a Flash feature and remembering your preferences. Web beacons or "clear gifs" are small pieces of code placed on websites used to collect advertising metrics, such as counting page views, promotion views or advertising responses. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

We may use Tracking Technologies to determine the number of visitors to the Site, the frequency of such visits and to certain sections, and to improve or customize the content, offerings and advertisements on our Site. For example, we may use cookies to personalize your experience at our Site, such as to recognize you by your user name and when you return to our Site, and save your password and password-protective areas.

We, our third-party service providers and/or partners may also use Tracking Technologies, such as cookies, to manage and measure the performance of advertisements displayed on or delivered by or through the Site. Moreover, we, our third-party service providers and/or our partners may use Tracking Technologies to monitor the behavior and collect data about the visitors viewing a web page.

In addition to the Tracking Technologies, log data collected on our web servers supply us with aggregate Usage Information about the number of visits to different pages on our site. We use such aggregate Usage Information to improve access to content based on our visitors' browsers and operating system types to make our content available to as many users as possible.

By agreeing to this Privacy Policy, you are consenting to the use of Tracking Technologies as set forth in this Privacy Policy.

You can change your privacy preferences regarding the use of cookies and similar technologies through your browser by consulting the "Help" section of your browser for more information. To learn more about Flash and the privacy choices Adobe offers, please visit http://www.adobe.com/privacy/opt-out.html

Please be aware, however, that blocking cookies and other Tracking Technologies will affect your online experience and may prevent you from enjoying the full features offered at our Site. Please know that certain areas and features of the Site can only be accessed in conjunction with cookies, Flash cookies, or other similar devices and you should be aware that disabling cookies or similar devices may prevent you from accessing some of our content.

2. Third-Party Ad Servers and Service Providers

We may use third parties to serve or present the ads that appear on our Site, to conduct research about the advertisements, to provide content or facilitate the operation of the Site, and to provide us with information regarding traffic to and use of the Site. We use only contextual-advertising methods and not "online behavioral" or "targeted" advertising methods. These third parties may view, edit or set their own Tracking Technologies to help present content and advertisements, to measure and research the advertisements' effectiveness, and to gather Usage Information and other information about the functioning of the Site. As a result, these third parties may have access to Non-Personal Information, such as Usage Information, and your Device Identifier (but Device Identifier will be used only to support internal operations).

3. Disclosure of Information

SQAD does not disclose the Device Identifiers or other Personal Information collected from children to third parties, except with regard to the safety and security of the Site as discussed above, and to service providers who provide support for the internal operations of the Site and who do not disclose or use the Personal Information for any other purpose. These service providers may provide support services such as hosting the Site, designing and/or operating the Site's features, or performing other administrative services. SQAD may provide these companies with access to Personal Information in order for them to carry out the services they are performing on SQAD' behalf. We require these service providers to keep the information confidential and to use it only for the specific services they are performing.

With regard to parents or other adults who have provided information, we may disclose such information, including Personal Information, in response to legal process, or in response to a law enforcement agency's request, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, a situation involving potential threats to the physical safety of any person, violations of our terms of use, to verify or enforce compliance of the policies governing our Site and applicable laws, or as otherwise required or permitted by law or consistent with legal requirements. In addition, we may transfer Personal Information about you if we are or one of our business units is acquired by, sold to, or merged with another entity.

4. Links to Other Sites

Our Site may contain links to other websites, including those of advertisers, whose information practices may be different from ours. We do not control these third-party websites and are not responsible for the privacy or data-collection practices of any third party.

5. International Transfer

SQAD operates globally so it may be necessary to transfer any information provided to the Site to a jurisdiction other than the one in which you reside. In particular, the information provided will likely be transferred to and processed in the United States where many of our central databases operate. The data protection and other laws of the United States or other countries in which your data may be stored or processed may not be as comprehensive as those in your own country. By using this Site, you fully understand and unambiguously consent to your information being transferred, processed, and stored as set forth in this Privacy Policy.

6. Security

We have put in place commercially reasonable physical, electronic, and managerial procedures in an effort to safeguard and help prevent unauthorized access, maintain data security, and use the information we collect online. However, no data transmission over the Internet, wireless transmission, or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information we collect. To help protect your information, you should not share your account information or password, reuse your password on other websites, or use a password you have used on other websites. You use our Site and provide us with your information at your own risk.

7. Contact Us

SQAD is the operator of the Site. If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please contact us at the following email address, mailing address and telephone number:

SQAD 
15315 Magnolia Blvd. Suite 225
Sherman Oaks, CA. 91403
Telephone: (844) 435-2323
Facsimile: 818-436-7529
Email: info@sqadplay.com

9. Updates to Privacy Policy

From time to time, we may update this Privacy Policy. We will notify you about material changes in the way we treat personally identifiable information by placing a notice on our Site or, for users who have registered for a premium account, we may notify you of changes by sending an email to the address associated with your account at that time. Any changes will become effective immediately upon posting, unless the updated policy expressly states otherwise. We encourage you to periodically check back and review this Privacy Policy so that you always will know what information we collect, how we use it and to whom we disclose it.

INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA

This section of the Privacy Policy applies only if you use our Sites covered by the Privacy Policy from a country in the European Union or another member state of the European Economic Area ("EEA"), and it supplements the information in the Privacy Policy.

SQAD is the data controller for processing of information defined as personal data under applicable data protection law ("Personal Data").

LEGAL BASIS FOR DATA PROCESSING

We process Personal Data for the purposes set out in the Privacy Policy. Our legal bases to process Personal Data include processing that is necessary for the performance of a contract between us; in the case of subscription users (for example, to provide you with services you request and to identify and authenticate you so you may use the website); necessary to comply with legal requirements and applicable accounting standards and to make mandatory disclosures to law enforcement and regulatory authorities; necessary for our legitimate interests (for example, to manage our relationship with you, to improve the website and our services, to protect our property and safeguard against fraud and malware, to make or defend legal claims); and based on consent by our customers (for example, to communicate with you about our products and services and provide you with marketing information). Where we process your Personal Data with your consent, you may subsequently withdraw consent at any time by contacting us (using the contact instructions below), without affecting the lawfulness of processing based on consent before its withdrawal.

EU DATA SUBJECT RIGHTS

The EU General Data Protection Regulation (GDPR) and other applicable data protection laws provide certain rights for individual data subjects ("EU Data Subject Rights"). You may decline to share certain Personal Data with us, in which case we may not be able to provide some of the features and functionality of our services. These rights include, in accordance with applicable law, the rights to access or rectify Personal Data, object to or restrict further processing, or request the erasure of Personal Data or, where feasible, to have it moved to a new service provider ("data portability"). You must be 16 years or older to make a request or else have your parent contact us on your behalf.

Normally, we can respond to requests for access within 48 hours. If we cannot honor your request concerning Data Subject Rights within 30 days, we will inform you and provide an explanation. When technically feasible, at your request, we will provide your Personal Data to you or transmit it directly to another controller.

We retain your Personal Data while you have an account with us and while you are using our services or continuing to visit our Site. We will retain your Personal Data for as long as it is reasonably necessary for the purposes set out in the Privacy Policy, considering the time period reasonably necessary to: provide the services to you; exercise the choices and rights you have requested; comply with our contractual obligations; enforce our terms for use of the services; and comply with legal and regulatory requirements.

If you have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the relevant national data protection supervisory authority and lodge a complaint.

CHILDREN

This Site and services are not designed for or directed to children under thirteen (13) years of age and the Site will not intentionally collect or maintain information about anyone under thirteen (13) years of age.

CONTACT US

For all EU Data Subject Rights requests, please contact us at info@SQADPLAY.com You must put the statement "Your EU Data Subject Rights" in the subject field of your request and include in the request the name of the Services with respect to which you are requesting the information, as well as your contact information.