# Privacy Policy

_Effective date: September 29, 2023_

At Play, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. **By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.**

Remember that your use of Play's Services is at all times subject to our [Terms of Use](https://createwithplay.com/terms-and-conditions), which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the Play website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

## Privacy Policy Table of Contents
- What this Privacy Policy Covers
- Personal Data
  - Categories of Personal Data We Collect
  - Categories of Sources of Personal Data
  - Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
- How We Disclose Your Personal Data
- Tracking Tools and Opt-Out
- Data Security
- Personal Data of Children
- California Resident Rights
- Virginia Resident Rights
- Exercising Your Rights under CCPA and VCDPA
- Other State Law Privacy Rights
- European Union and United Kingdom Data Subject Rights
- Contact Information

## What this Privacy Policy Covers
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

### Personal Data

#### Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

| Category of Personal Data | Examples of Personal Data We Collect | Categories of Third Parties With Whom We Share this Personal Data | 
|-------------------------|---------------------------------|----------------------------------------------------| 
| Profile or Contact Data | First and last name, Email, Unique identifiers such as passwords | Service Providers, Analytics Partners, Parties You Authorize, Access or Authenticate | 
| Payment Data           | Payment card type, Last 4 digits of payment card, Billing address, phone number, and email | Service Providers (specifically our payment processing partner, currently Stripe, Inc.) | 
| Commercial Data        | Purchase history | Service Providers, Analytics Partners | 
| Device/IP Data        | IP address, Device ID, Type of device/operating system/browser used to access the Services | Service Providers, Analytics Partners | 
| Web Analytics         | Web page interactions, Referring webpage/source through which you accessed the Services | Service Providers, Analytics Partners | 
| Social Network Data    | Email, Unique identifiers such as passwords | Service Providers, Analytics Partners, Parties You Authorize, Access or Authenticate | 
| Professional or Employment-Related Data | Resume, Company name, Job title, Job history, Team size | Service Providers, Analytics Partners | 
| Geolocation Data      | IP-address-based location information, GPS data | Service Providers, Analytics Partners | 
| Photos, Videos and Recordings | Photos, videos or recordings of your environment | Service Providers, Analytics Partners | 
| Other Identifying Information that You Voluntarily Choose to Provide | Identifying information in emails or letters from users | Service Providers |

#### Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:

- **You**  
  * When you provide such information directly to us.
    * When you create an account or use our interactive tools and Services.
    * When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
    * When you send us an email or otherwise contact us.  
  * When you use the Services and such information is collected automatically.
    * Through Cookies.
    * If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
    * If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services.
- **Third Parties**  
  * Vendors.  
  * Social Networks.

#### Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
- Providing, Customizing and Improving the Services  
- Marketing the Services  
- Corresponding with You  
- Meeting Legal Requirements and Enforcing Legal Terms

## How We Disclose Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data.

- **Service Providers.** These parties help us provide the Services or perform business functions on our behalf.
- **Analytics Partners.** These parties provide analytics on web traffic or usage of the Services.
- **Parties You Authorize, Access or Authenticate**

## Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms.”

## Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business.

## Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect.

## Tracking Tools and Opt-Out
The Services use cookies and similar technologies to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services.

## Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data.

## Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16 years of age.

## California Resident Rights
If you are a California resident, you have the rights set forth in this section.

### Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months.

### Deletion
You have the right to request that we delete the Personal Data that we have collected about you.

### Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you.

## Virginia Resident Rights
If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”).

### Access
You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.

### Deletion
You have the right to delete your Personal Data.

## Exercising Your Rights under CCPA and VCDPA
To exercise the rights described in this Privacy Policy, you must send us a request that provides sufficient information to allow us to verify your identity and describes your request.

## Other State Law Privacy Rights
### California Resident Rights  
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties.

### Nevada Resident Rights  
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties.

### European Union and United Kingdom Data Subject Rights
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the GDPR.

## Transfer of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Play and its service providers.

## Contact Information
If you have any questions or comments about this Privacy Policy, please do not hesitate to contact us at:
- [support@createwithplay.com](mailto:support@createwithplay.com)
- 524 Broadway, 11th Fl., New York, NY 10012