This Privacy Policy explains how CCRA Capital LLC ("CCRA Capital," "Playvo," "we," "our," or "us") collects, uses, discloses, and protects personal information when you access or use our websites, mobile experiences, dashboards, applications, challenges, promotions, sweepstakes-style offerings, and related services, including playvo.us, app.playvo.us, and any pages or experiences that link to this Privacy Policy (collectively, the "Platform").
This Privacy Policy is intended to align with the Platform's dual-currency promotional model, including Gold Coins, PlayVo Cash, challenge participation, promotional offers, mail-in entries where offered, payment processing, identity verification, redemption processing, fraud prevention, and related customer communications.By accessing or using the Platform, you acknowledge that you have read this Privacy Policy. If you do not agree with our practices, do not use the Platform.
1. Scope and Eligibility
The Platform is intended for users who are at least 18 years old, or older where required by applicable law, and who are located in jurisdictions where the Platform is offered. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from an individual under 18, we will take reasonable steps to delete that information and close the associated account.
2. Personal Information We Collect
We collect personal information from the following categories: Identifiers and Contact Information — Name, email address, phone number, postal address, username, account ID.Account and Profile Information — Login credentials, referral information, preferences, challenge history, account status, support history. Transaction and Promotional Information — Gold Coin package purchases, associated bonus PlayVo Cash, redemption requests, refunds, chargeback history, promotional eligibility, sweepstakes or AMOE submissions.Identity, Eligibility, and Compliance Information — Date of birth, government identification details, verification records, residency information, sanctions screening results, fraud indicators, and geolocation or location-confirmation data.Device, Internet, and Usage Information — IP address, browser type, device identifiers, operating system, app and website activity, page views, clicks, session logs, and approximate location derived from technical data. Marketing and Communications Data — Email and SMS consent status, campaign engagement, customer service records, survey responses, and promotional preferences. Tax and Payout Information — Information needed to process redemptions or payouts and satisfy tax, accounting, or reporting obligations, which may include taxpayer identification information where required by law. We collect this information in three ways: (a) directly from you, (b) automatically through your use of the Platform, and (c) from service providers, payment processors, verification vendors, analytics providers, advertising partners, referral partners, or other third parties that support our operations. This Privacy Policy applies to personal information we collect online and offline in connection with the Platform, including when you create an account, participate in a promotion or challenge, purchase Gold Coin packages, receive or use PlayVo Cash, request a redemption, submit an alternative method of entry, communicate with support, receive marketing communications, or otherwise interact with us.
3. How We Use Personal Information
We use personal information for the following business and commercial purposes: We may use your information to create and manage your account; authenticate users; provide access to the Platform; administer Gold Coins, PlayVo Cash, challenges, promotions, and AMOE processing; process payments and redemption requests; verify age, identity, residency, and location; detect and prevent fraud, abuse, bonus manipulation, and chargebacks; enforce our Terms and Promotion Rules; communicate with you about your account, purchases, redemptions, promotions, and support requests; send marketing communications where permitted by law and consistent with your preferences; maintain records for accounting, tax, and compliance purposes; improve the Platform, user experience, customer support, and product performance; conduct analytics, testing, and service monitoring; comply with law, legal process, law enforcement requests, and regulatory obligations; and protect our rights, users, personnel, and the public.
4. Cookies, Analytics, and Similar Technologies
We and our service providers may use cookies, pixels, SDKs, tags, local storage, log files, and similar technologies to operate the Platform, remember preferences, analyze traffic, understand campaign performance, maintain security, and improve user experience. You can control certain cookie settings through your browser or device settings. Blocking some technologies may affect Platform functionality. Where required by law, we will honor applicable consent requirements for non-essential cookies or similar technologies.
5. How We Disclose Personal Information
We do not sell, rent, or lease personal information for money. We also do not disclose personal information to third parties for their own independent direct marketing use except as described in this Privacy Policy or with your consent.
We may disclose personal information in the following circumstances:
1. Service providers and processors. We disclose information to vendors that help us host and operate the Platform, process payments, provide cloud storage, customer support, communications, analytics, fraud prevention, geolocation, age and identity verification, sanctions screening, tax reporting, redemptions, or similar business functions.
2. Corporate affiliates and transaction counterparties. We may disclose information within our corporate group or in connection with a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar corporate event, subject to customary confidentiality and transition protections.
3. Legal, regulatory, and safety disclosures. We may disclose information if required by law, subpoena, court order, regulatory request, law enforcement request, or where we believe disclosure is reasonably necessary to protect the rights, property, or safety of CCRA Capital, our users, or others.
4. Promotion, referral, and marketing support. We may disclose limited information to promotional, advertising, analytics, and attribution partners to measure campaigns, prevent fraud, support referral tracking, or deliver Platform-related marketing, subject to applicable law and your choices.
5. With your direction or consent. We may disclose information where you direct us to do so or otherwise consent.
6. SMS, Email, and Marketing Communications
If you opt in, we may send transactional or promotional emails, SMS messages, push notifications, or similar communications relating to your account, challenges, promotions, offers, and Platform updates.Transactional messages may still be sent when necessary to service your account, such as purchase confirmations, verification notices, security alerts, material policy updates, or redemption-status messages.You may unsubscribe from marketing emails by using the unsubscribe link in the message. You may opt out of marketing SMS by replying STOP, where applicable. Your mobile carrier's message and data rates may apply. Opting out of marketing communications does not affect transactional or service-related communications.
7. Identity Verification, Geolocation, Fraud Prevention, and Compliance
Because the Platform offers promotions and redemption features only in eligible jurisdictions and only to eligible users, we may use identity verification, age verification, residency checks, device intelligence, sanctions screening, and geolocation tools. We may also use manual review and automated signals to detect fraud, multi-accounting, payment abuse, bonus abuse, promotion manipulation, or other violations of our Terms or Promotion Rules.If we cannot verify your eligibility, identity, location, payment integrity, or compliance status, we may restrict account functionality, deny a redemption, reverse promotional credits where permitted, or suspend or terminate the account, consistent with our Terms and applicable law.
8. Payment Processing and Redemptions
Payment card and similar payment information is generally processed by third-party payment processors and is not stored by us except as necessary for transaction records, reconciliation, dispute handling, chargeback response, and related business purposes.When you request a redemption or payout, we and our service providers may collect and use information needed to verify eligibility, prevent fraud, complete the transaction, maintain accounting records, and satisfy tax and legal requirements.
9. Data Retention
We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Platform, administer promotions, maintain business and financial records, comply with tax and legal obligations, resolve disputes, enforce agreements, prevent fraud, and protect our legitimate interests. Retention periods may vary based on the type of information, the sensitivity of the data, the nature of the relationship, legal requirements, and whether the account is active, restricted, or closed.
10. Security
We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
11. Your Choices and Rights
Depending on where you live, you may have rights to request access to, correction of, deletion of, or a portable copy of certain personal information, as well as rights to opt out of certain targeted advertising, profiling, or disclosures treated as a sale or sharing under applicable law.You may also update certain account information by logging into your account, where available, or by contacting us. We may need to verify your identity before acting on a privacy request, and we may deny or limit requests where permitted by law.If you are an authorized agent submitting a request on behalf of another person, we may require proof of your authority and verification of the underlying consumer's identity.
12. State Privacy Disclosures
If you are a resident of a state with a comprehensive privacy law, you may have additional rights and disclosures available under that state's law. Subject to applicable exemptions and verification requirements, we will process qualifying requests in accordance with applicable law.We do not knowingly collect or process sensitive personal information for the purpose of inferring characteristics about individuals. Where we process sensitive information such as precise geolocation, government-issued identification, or financial information, we do so for account administration, verification, security, fraud prevention, redemption processing, legal compliance, and related business purposes.If applicable law treats certain analytics, advertising, or attribution activities as a sale, sharing, or targeted advertising, you may exercise any available opt-out rights by contacting us at the address below or through any rights-management tools we make available on the Platform.
13. Third-Party Services and Links
The Platform may contain links to third-party websites, applications, payment tools, social media services, embedded content, or referral destinations. We are not responsible for the privacy practices of those third parties. Their collection and use of information is governed by their own policies and terms.
14. International Users
The Platform is intended for users located in the United States in jurisdictions where the Platform is offered. If you access the Platform from outside the United States, you understand that your information may be transferred to and processed in the United States and other jurisdictions where our service providers operate.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will post the revised version on the Platform and update the Last Updated date above. Your continued use of the Platform after the updated Privacy Policy becomes effective constitutes your acknowledgment of the changes to the extent permitted by law.
16. Contact Information and Privacy Requests
For questions about this Privacy Policy or to submit a privacy request, contact:
CCRA Capital LLC
Attn: Privacy
Email: support@playvo.us
If you use a dedicated privacy-request email or webform, that contact information should be inserted here before publication.
17. Supplemental Notice for California and Similar State Laws
To the extent applicable law requires category-based disclosures for the preceding twelve (12) months, we may have collected, used, and disclosed the categories of personal information listed in Section 2 for the business and commercial purposes listed in Sections 3 through 8. Categories of recipients may include service providers, payment processors, verification vendors, analytics and advertising providers, professional advisers, corporate affiliates, regulators, law enforcement, and other parties described in Section 5. We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law, including providing the Platform, performing services, verifying eligibility, preventing fraud, completing transactions, maintaining security, and complying with legal obligations. Residents of California and certain other states may have the right to know, access, correct, delete, or obtain a copy of certain personal information, and may have a right to opt out of certain disclosures or targeted advertising activities where applicable. We will not discriminate against you for exercising a valid privacy right.If applicable law requires a separate Notice at Collection or a stand-alone Do Not Sell or Share My Personal Information link, those items should be implemented in the Platform UX and linked here before deployment.
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