Effective Date: March 7, 2022

CliquePrize® respects your privacy. This privacy policy describes what personal information we collect from you, how we use and share it, and your rights and choices regarding your information, including whether or not to share it with us. By accessing the CliquePrize® Mobile App (hereafter referred to as "the App") or ordering or subscribing to our products or services you agree to this privacy policy. It also applies to information we collect on the App, as well as in email, text, and other electronic messages between you and the Cinnamon Entertainment Group LLC (hereafter referred to as "us" or "we"). It does not apply to information collected by us offline or through any other means, including on any other website operated by us or a third party or collected by any third party that may link to or be accessible through the App. If you do not agree to be bound by this policy, you may choose not to access or use the App. Additional specific policies or agreements may apply to certain products and services. If such policies or agreements conflict with this policy, the terms of those policies or agreements will prevail.

Children’s Privacy

The App is not intended for or designed to attract children under the age of 18, and we will not knowingly solicit or collect personal information from children we actually know are under 18.

Links to Third-Party Sites and Features

The App may include links to or direct you to other applications or websites. The App also may allow you to use certain features and plug-ins that integrate third-party social media sites and other third-party features and tools. This Privacy Policy applies to any personal information you provide with purchases and interactions made directly through the App. Once you leave the App and are directed to another site or application, however, this policy and our Terms of Use no longer apply and the terms and policies on such third-party site apply. You have the choice whether to access the links to these sites or activate the features. This privacy policy does not apply to any third-party linked sites, and we are not responsible for the privacy practices or the contents of such external sites. We encourage you to consult the privacy policies of such sites before sharing any personal information through them, initiating your transaction or activating the features.

Third-Party Vendors

We may share your personal information with third-party agents, contractors, service providers, and suppliers who assist in providing support and services to our entities. When we do so, we require those third parties to protect your personal information in accordance with this policy and applicable laws. Once you leave the App and are directed to another site or application, however, this policy and our Terms of Use no longer apply and the terms and policies on such third-party site apply.

Types of Information We Collect

It is your decision whether to provide information that we request. Please know that, if you choose not to do so, we may not be able to provide you with a relevant service or feature of the App.

Below are the types of information we may collect about you.

Personal Information. Personal information is information that identifies or is capable of identifying you as an individual. We collect personal information from you when you voluntarily provide it to us, such as by creating a user account, participating in promotions such as Giveaways (Sweepstakes), Contests, Events, Raffles or Instant Win, signing up for email updates, or responding to surveys, offers, and other communications. We also may collect personal information about you from your use of our products and services or through our partners and other publicly and commercially available sources. Personal information we collect from you may include:

● Contact information such as first and last name, email address, mobile phone number, and zip code;

● Preferences information such as purchase history (Sponsors only) and email marketing preferences;

● Log-in information such as username, personal account number, and password, and log-in information for social media, Google or Apple accounts if you log into the App through such accounts; and

● Other information you choose to provide, such as comments, questions, and requests. You agree not to provide through use of the App any sensitive personal information, including information relating to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or sexuality.

Cookies and Similar Technologies. We and our partners use cookies and similar technologies on the App. Cookies are text files we place on your computer or device browser to store your preferences. Information that may be collected through the use of these technologies includes the Internet Protocol address automatically assigned to your computer, your browser type, the date and time of your visit, the pages you visit and the amount of time spent on each, your device’s operating system, your mobile device identifier, your geographical area, referring URLs, and other information on your interaction with the App. Please see our Cookies Policy to learn how we use cookies, how our partners may use cookies on the App, your choices regarding cookies and further information about cookies. You can modify your cookie settings or turn off all or certain types of cookies by adjusting your browser settings. Please note, however, that if you delete or turn off cookies, you may not have access to some of the features that make your experience on the App, you may not be able to store your preferences, and some of our services may not function properly.

Aggregate and Anonymous Information. Sometimes we use aggregate or anonymous information. Anonymous information is data where all information that enabled you to be identified has been removed. Aggregate information is anonymous data collected about a group of users or other categories. Your personal information is not included in aggregate or anonymous data. We may use this type of information, for example, to help us understand trends and your needs and preferences and to improve our services. This policy does not restrict our use of aggregate and anonymous information.

Email Communications. We may use your email for promotional purposes (e.g., new product offerings, special offers by us or other third parties), newsletter, transactional emails (e.g. forgot password, login or prize notification) or upcoming promotions information. If you send an email to us, we may collect your email address and the full content of your email, including attached files, and other information you provide. You may indicate your preference to opt out of receiving promotional communications by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly using the contact information below. Contestants can also opt-out of emails under Settings > My Lists in the App. You acknowledge that it may take up to 10 days for us to process an opt-out request. Please note, however, that you cannot opt out of receiving transactional emails related to your account with us.

SMS Communications. We may use your mobile number (via Short Message Service aka Text Message) for reasonable similar purposes as Email Communications such as prize notification and delivery status. All rates of your cellular or mobile carrier shall apply for the delivery of such messages.

How We Use Your Information

We may use your information in the following ways:

● To communicate with you regarding your account;

● To respond to your customer service requests;

● To improve the content of the App;

● To customize the App for each individual visitor;

● To notify you about updates to the App;

● To administer a promotion, survey or other app feature;

● To respond to correspondence we receive from you; and

● To serve other purposes for which we provide specific notice at the time of collection, and as otherwise authorized or required by law.

Disclosure of Your Information

Please note that if you enter a promotion, you are granting to us the right, upon conclusion of the promotion after the prize winner is selected, to disclose and sell to the Sponsor of that particular promotion your first and last name, email address, mobile phone number, and zip code provided upon registration for an App account, subject to the Sponsor’s agreement never to sell the data and to use it solely for purposes of promoting its business related to the promotion, and subject to all applicable laws. In the event you register your account with Apple credentials, your information will remain encrypted per Apple's terms of use and most likely will not be available to the Sponsor for purchase. The Sponsor hereby agrees to provide the Contestant a method to opt-out or unsubscribe to these marketing emails or SMS text messages at any time for any reason. If you do not wish for your information to be potentially shared with the Sponsor, you should not enter any promotion on CliquePrize®. We only share your personal information in accordance with applicable law. In addition to the foregoing, we may share your personal information with others in the following instances:

● When legally required to do so;

● At the request of governmental authorities conducting an investigation;

● To verify or enforce compliance with the policies governing the App and applicable laws or to protect against misuse or unauthorized use of the App; and

● To a successor entity in connection with a corporate merger, consolidation, sale of assets or other corporate change. Should such a sale occur, we will use reasonable efforts to direct the transferee to use your information in a manner that is consistent with our privacy policy.

International Transfers of Personal Information

The App is based in the United States of America and is subject to the laws of the United States. If you are a user outside of the United States, please know that any information you provide on the App may be transferred to the United States, which does not offer an equivalent level of protection to that required in certain other countries. We may transfer your personal information to third parties in other countries for the purposes described in this policy. Some local privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the purposes described in this policy. These countries may not have the same data protection laws as the country in which you initially provided the information. We take steps to ensure that it is adequately protected in compliance with applicable laws, including ensuring appropriate security measures are in place and requiring the third parties to protect your personal information in accordance with this policy, or obtaining your consent where required.

How We Protect Your Information

We implement a variety of security measures when you enter, submit, or access your information to maintain the safety of your personal information. Your personal information is contained behind highly secured networks (Microsoft Azure) and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. You should be aware that such security measures cannot prevent all loss, misuse or alteration of personal information, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions to protect your rights.

How Long We Retain Your Information

We retain your information only as long as necessary to provide our services to you, enhance your user experience, and otherwise as necessary for our operations or as permitted or required by applicable laws.

Legal Basis for Use of Your Personal Information (GDPR)

The General Data Protection Regulation, or GDPR, governs privacy practices involving individuals in the European Union and the European Economic Area and certain other transactions related to those areas. If the GDPR applies to your personal information that we have collected, our legal basis for collecting and using your personal information will depend on the personal information concerned and the context in which it is collected, including legitimate business purposes, as necessary to provide products and services to you or respond to your inquiries and requests, with your consent, to comply with applicable laws, or when there is a legitimate and overriding interest that necessitates the use.

How to Access and Control your Information

You may change your privacy settings at any time by contacting us using the contact information below. You may indicate your options to:

● Modify, update, and delete your user account;

● Opt in or out of subscriptions to newsletters, mailings, and other communications and alerts; Contestants can also manage this under Settings > My Lists inside the App;

● Opt in or out of receiving offers and promotions; and

● Opt in or out of sharing your personal information with others so they can send you offers and promotions, except to the extent you have already entered a promotion. If you enter a promotion, you are granting to us the right, upon conclusion of the promotion after the prize winner is selected, to disclose and sell to the Sponsor of that particular promotion your first and last name, email address, mobile phone number, and zip code provided upon registration for an App account, subject to the Sponsor’s agreement never to sell the data and to use it solely for purposes of promoting its business related to the promotion, and subject to all applicable laws. This shall also include the Sponsor's responsibility to provide the Contestant a method and ability to opt-out of such marketing communications.

In the event a Contestant wins a physical prize of a promotion, this individual shall be required to provide the Sponsor temporary access to that user's mailing address for the delivery of the prize through the App. Once the prize has been delivered and therefore redeemed, the Contestant's address shall no longer be visible or made available to the Sponsor for re-use through the App. CliquePrize® will also delete such mailing address as we only store Contestant physical or mailing addresses temporarily until the prize delivery has been confirmed.

You may contact us to request a copy of the information we have collected about you, request to correct or update any information we have about you, or request deletion of your account or personal information. Following a request for deletion, we will delete your information unless required to retain it by applicable laws, and except to the extent you have already entered a promotion and such information has been disclosed or sold to the particular Sponsor of the promotion with your consent as provided above. We may also retain certain of your information if necessary for safety or security, fraud prevention, quality assurance, or other legitimate business interests, and only in accordance with applicable laws.

You may withdraw any consent you have granted to our collection and use of your personal information at any time, subject to our right to continue to use your personal information as permitted or required under applicable laws. Such withdrawal will not affect the lawfulness of our collection or use of your personal information prior to withdrawal.

Modification of Our Privacy Policy

We may modify our privacy policy from time to time. When we modify our privacy policy, we will notify you by a posting through the App. Any changes will become effective as of the date of posting with respect to information we then collect in the future. We will treat all personal information we collect, however, in accordance with the privacy policy in effect at the time the information is collected. We urge you to review this privacy policy often so you are always fully informed.

How to Contact Us

You can submit questions, comments, and complaints about our privacy policy and practices at the following:

CliquePrize®, a mobile app of the Cinnamon Entertainment Group LLC
Mailing Address: 4112 Nolensville Road #111751, Nashville, TN 37222
Email: contestants(at)cliqueprize.com or sponsors(at)cliqueprize.com

Your Local Data Protection Authority

Under certain local laws, you may have the right to submit a complaint regarding our collection and use of your personal information to your local data protection authority. Please consult this link for further information: https://edpb.europa.eu/about-edpb/board/members_en

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.