NumberRoyale (NR) Privacy Policy

OUR APPROACH TO PRIVACY
Vel Micro Works Incorporated ("NumberRoyale", "we", "our", or "us") is committed to protecting and respecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies.
NumberRoyale operates a service that allows you to play live math game shows using our app (the "Service").
This privacy policy applies to our Service. Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this privacy policy.
Vel Micro Works Incorporated is the data controller of the personal information we hold about you.
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, fill in a form on our Service, create or edit your user profile on the Service, correspond with us by phone, SMS, e-mail or otherwise, respond to math questions, post comments using the chat function on our Service, or use some other feature of our Service. We may also collect personal information from third parties, such as social networks.
We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.
The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.
We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.
The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.
We may anonymize and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features. We may also share such anonymized information with others.
We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.
RECIPIENTS OF PERSONAL INFORMATION
We may share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2):
Service providers and advisors: we may share your personal information with third-party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, web hosting, or providing analytic services.
Social media: where you have connected a social media account with our Service, we may post your comments and opinions to our social media pages and tag you in those posts.
Purchasers and third parties in connection with a business transaction:
your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.
Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of NumberRoyale, its users or others.
STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
Security. We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. All electronic transactions entered into via our website will be protected by TLS encryption technology. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
International Transfers of your Personal Information. As we are located in the USA, any information we collect from you will initially be collected and stored in the USA. If you are in the EU or EEA, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy.
YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:
Right of access. You have the right to obtain:
confirmation of whether, and where, we are processing your personal information;
information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
Information about the categories of recipients with whom we may share your personal information; and
a copy of the personal information we hold about you.
Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person
Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified
Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit the personal information you have submitted to us by logging into your account on the app.
You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
LINKS TO THIRD-PARTY SITES
Our Service may, from time to time, contain links to and from third-party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
OUR POLICY TOWARDS CHILDREN
Our Service is not directed at persons under 18 and we do not knowingly collect personal information from children under 18. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
CHANGES TO THIS POLICY
We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.
NOTICE TO YOU
If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.
CONTACTING US
Please contact help@NumberRoyale.com if you have any questions, comments and requests regarding this Privacy Policy.
This privacy policy was last modified on July 1, 2019.

Category of personal information	How we may use it	Legal basis for the processing
Contact information such as your name, phone number, address and e-mail address.	Contact information such as your name, phone number, address and e-mail address.	The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
	We may use this information to communicate with you, including sending service-related communications, such as notifying you when you have won a match.	The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
	We use this information to deal with enquiries and complaints made by or about you relating to the Service.	The processing is necessary for our legitimate interests, namely administering the Service, and for communicating with you effectively to respond to your queries or complaints.
Profile information, such as your username, profile picture and other users you have invited to use our Service.	We use this information to operate, maintain and provide to you the features and functionality of the Service.	The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
	We use this information to promote our Service, such as inviting new users to our Service or tagging you in comments on our social media pages.	The processing is necessary for our legitimate interests, namely promoting our Service.
Tax number or other government identifier. We may collect numbers assigned to you by tax authorities in your jurisdiction, such as your social security number or national insurance number.	We use this information to comply with our reporting obligations to tax authorities in the event that you win a prize while using our Service.	The processing is necessary for your legitimate interests, namely compliance with your legal obligations to report winnings to tax authorities.
Chat, comments and opinions. When you contact us directly, e.g. by email, phone, or when you participate in a chat on our Service, we will record your comments and opinions.	We use this information to operate, maintain and provide to you the features and functionality of the Service.	The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
	We use this information to address your questions, issues and concerns.	The processing is necessary for our legitimate interests, namely communicating with users and responding to queries, complaints and concerns.
	We use this information to develop new products and features available through our Service or otherwise improve our Service.	The processing is necessary for our legitimate interests, namely developing and improving our Service.
Information about your use of our Service, such as the number of matches you have participated in on our Service, your replies to the math questions on our Service and the prize money you have won when using the Service.	We use this information to operate, maintain and provide to you the features and functionality of the Service, including paying you any prize money you may win when you use the Service.	The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
	We use this information to develop new products and features available through our Service or otherwise improve our Service.	The processing is necessary for our legitimate interests, namely developing and improving our Service or certain features of our Service.
Address book contacts. Where you give us permission to do so, we may collect the phone numbers and names of the contacts on your device.	We use this information to connect you with people in your address book that are using our Service and to allow you to invite other people in your address book to our Service.	We will only process this information to the extent you have given us consent to do so.
Information received from third parties, such as social networks. If you connect a social network to our Service, or interact with our Service through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social network.	We use this information to allow you to log in to the Service.	The processing is necessary for the performance of a contract and to take steps prior to entering into a contract.
	We use this information to tailor how the Service is presented to you.	The processing is necessary for our legitimate interests, namely tailoring our Service to the user.
	We use this information to promote our Service, such as tagging you in comments on our social media pages.	The processing is necessary for our legitimate interests, namely promoting our Service.
Precise location information. When you use certain functionalities of the Service, we may ask you to provide your precise location.	We use this information to provide you certain functionalities of the Service, such as the ability to interact with people using our Service near you.	We will only process this information to the extent you have given us consent to do so.
Approximate location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location.	We use information you provide to us about your location to inform and plan our marketing strategy.	The processing is necessary for our legitimate interest, namely informing our direct marketing strategy.
All personal information set out above.	We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Service, to communicate with you, to monitor and improve our Service and business, and to help us develop new products and services.	The processing is necessary for our legitimate interests, namely to administer and improve the Service.

Category of personal information	How we use it	Legal basis for the processing
Information about how you access and use the Service. For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Service, the time you access our Service and how long you use it for, the approximate location that you access the Service from, whether you access the Service from multiple devices, and other actions you take on the Service.	We use information about how you use and connect to our Service to present our Service to you on your device.	The processing is necessary for our legitimate interests, namely to tailor our Service to the user.
	We use this information to determine products and services that may be of interest to you for marketing purposes	The processing is necessary for our legitimate interests, namely to inform our direct marketing.
	We use this information to monitor and improve our Service and business, resolve issues and to inform the development of new products and services.	The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally.
Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Service. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Service through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).	We use information about how you use and connect to our Service to present our Service to you on your device.	The processing is necessary for our legitimate interests, namely to tailor our Service to the user.
	We use this information to determine products and services that may be of interest to you for marketing purposes	The processing is necessary for our legitimate interests, namely to inform our direct marketing.
	We use this information to monitor and improve our Service and business, resolve issues and to inform the development of new products and services.	The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Service and to improve our Service generally.