LFCarry Privacy Policy
Last Updated: October 28, 2021
This Privacy Policy applies to the information Digital Companion Services Pte. Ltd. (hereinafter – Lfcarry) , collects from and about you in the course of providing our services, including through Lfcarry websites and online forums, mobile applications, services, and other online or offline offerings operated by or on behalf of Lfcarry that link or refer to this Privacy Policy. We refer to these products, services, and offerings collectively as the "Services."

We encourage you to read this Privacy Policy to understand the information we collect, how we use it, and the choices available to you. By using the Services, you agree to this Privacy Policy and that we may process, transfer, and store your information in the United States and other jurisdictions that may have different privacy laws than those in your jurisdiction of residence.

This Privacy Policy contains the following sections:

  1. The information we collect
  2. Cookies and similar technologies
  3. Online analytics and advertising
  4. How we use your information
  5. How we share and disclose your information
  6. Children's privacy
  7. Security and retention of your information
  8. Your controls and choices
  9. Additional information for certain jurisdictions
  10. Changes to our Privacy Policy
  11. Lfcarry contact information
1. The information we collect
The information we collect about you depends on the Services you use, how you use them, and the information you provide to us. We collect information in three main ways: (1) information you choose to provide to us; (2) information we collect automatically through technology when you use the Services; and (3) information we collect from other sources.

Information you choose to provide to us

When you use our Services, you may choose to provide certain information to us. For example, we collect information directly from you when you register for and use the Services, apply to become a Pro player, participate in Lfcarry surveys or research, or otherwise communicate and interact with us. The information we collect includes:

  • Contact information (e.g., name, email, address, phone number)
  • Account identifiers (e.g., account name, log-in details, unique account identifiers)
  • Billing information if you purchase services from us (e.g., billing address, financial account
    details), which is also collected by our payment processor on our behalf
  • Country of residence information, to appropriately match you to eligible Pro coaches
  • From our Pros, information needed to determine eligibility to be a PRO player (e.g., age,
    employment history, statistics on play with certain titles, background check information, educational background, and information needed to make payments for your Pro services to you (e.g., government-issued IDs and bank account information)
  • User-generated content (e.g., profile photos, profile information, information published in public forums/discussion boards, gameplay data)

Information we collect automatically through technology when you use the Services

When you use our Services, we may automatically collect certain information about how you use the Services and the devices you use to access the Services. We use a variety of third-party technologies, including cookies and similar tools, to assist in collecting this information. Please refer to the "Cookies and similar technologies" and "Online analytics and advertising" sections below for further information.

Some of the information we automatically collect when you use our Services includes:

  • Information about your access to and use of Lfcarry Services and emails, such as your IP address, browser language, the state or country from which you accessed the Services, software and hardware attributes (including device IDs, operating system, and browser type), referring and exit URLs, the links you click and files you download, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on the Services, the date and time you accessed our Services or opened our emails, and other similar information.
  • Information about the devices and network you connect to the Services, such as your Internet connection type and service provider, IP address, wireless connection quality/signal strength, error logs, unique identifiers associated with the computer, tablet, gaming system, or mobile device used with your Lfcarry product or software, and its device operating system and browser type.
  • Information about the services and content you access via the Services, such as media, external sources, and third-party services you connect to the Services, user IDs, service tokens that allow you to access and sync to your third-party accounts, and content accessed via the Services.
  • Location information. In addition to general location information (e.g., city/state) which may be collected or derived from your IP address, our Services may request your precise location information via GPS-based functionality to allow certain features to work. We will always ask your permission in accordance with your mobile device settings before we collect or use precise location information

Information we collect from other sources

We may receive information about you from other sources, such as business partners, marketers, researchers, analysts, social network services, and other parties to help us supplement our records. If you access our Services through a third-party website, application, or social media platform (such as Google or Discord), we may receive information about you from that third-party site, application, or platform, depending on the third-party's data practices and your settings (for example, your name, user name, email address, and comments or content you post). Lfcarry is not responsible for the content or practices of third-party websites, applications, or platforms. We urge you to read the privacy and security policies of any third-party websites, applications, or social media platforms you choose to use.

Public forums

Certain features of our Services make it possible for you to share comments, photos, or other content publicly with other users, such as a Lfcarry forum or profile, or a social networking site. Any information that you submit through these features is not confidential, and Lfcarry may use it for any purpose (including in testimonials or other marketing materials). For example, if you provide a review about a Pro on the Services, we may display your review (along with the name you provide, if any) on the Services and elsewhere. Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.

De-Identified data

We may de-identify information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified form. Our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation.
2. Cookies and similar technologies
To collect the information in the "Information we collect automatically" section above, we and our service providers use Internet server logs, cookies, tags, tracking pixels, and other similar tracking technologies. We use these technologies to offer you a more tailored experience in the future by understanding and remembering your particular browsing preferences.

  • A web server log is a file where website activity is stored.
  • A cookie is a small text file that is placed on your computer or mobile device when you visit a website, and it enables us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
  • Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads, and/or email that are designed to: (i) collect usage information like ad impressions or clicks and email open rates; (ii) measure popularity of the Services and associated advertising; and (iii) access user cookies.

As we adopt additional technologies, we may also gather information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.
3. Online analytics and advertising

We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

If you receive email from us, we may use certain analytics tools, such as tracking pixels, to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Online Advertising

The Services may allow third-party advertising technologies (e.g., ad networks and ad servers such as Google Adwords or Bing advertising) to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you to assist in the delivery of relevant advertising on the Services, as well as on other websites you visit and other services you use. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. We also sometimes provide our customer information (such as email addresses) to service providers, who may "match" this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.

We neither have access to, nor does this Privacy Policy govern, the cookies or other tracking technologies that may be placed on the device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out link, the Digital Advertising Alliance's Consumer Opt-Out link, or Your Online Choices to opt out of receiving tailored advertising from companies that participate in those programs. To opt-out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page, and to opt out of Bing advertising, please click here. Please note that these opt-outs apply per device, so you will have to opt-out for each device through which you access our Services.
4. How we use your information
Lfcarry may use the information we collect in the following ways:

  • To provide the services you have requested, such as complete a purchase, provide customer support, or integrate with other services you select.
  • To communicate with you, for example, keeping you posted on purchases, product/software updates, and changes to our terms, conditions, and policies.
  • For marketing and advertising purposes, in accordance with applicable legal requirements, including providing you with the latest product announcements, promotions, and information about upcoming events.
  • To personalize your experience and customize the Services, such as delivering relevant content and recommending features through our Services.
  • To improve our Services, including bug detection and error reporting, to understand how users interact with our Services and advertisements, improve usability and effectiveness of our products, perform research and analytics, and to test and create new products, features, and services.
  • For our business operations, including maintaining your account, reviewing and processing Pro applications, and for security, fraud prevention, and legal compliance, such as detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
  • Other purposes for which we seek your consent. We may also use your information for a specific purpose that we communicate to you. We will ask for your consent to process your information for such purpose in accordance with applicable legal requirements.
The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information. Our legal bases for processing your information as described in this Privacy Policy are as follows:

  • Where use of your information is necessary to perform our obligations under a contract or commitment to you. For example, to provide the services you've requested from us, or to comply with our website terms of service.
  • Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Services, operate our business and our Services, make and receive payments, defend our legal rights, and prevent fraud.
  • Where we use your information to comply with applicable legal obligations. For example, keeping track of purchases for tax and auditing purposes, and to apportion fees to Pros.
  • Where you have consented to our processing of your information for a particular purpose.

For the purposes discussed in this Privacy Policy, we may combine the information that we collect
through the Services with information that we receive from other sources, both online and offline,
and use such combined information in accordance with this Privacy Policy.
5. How we share and disclose your information
Lfcarry may share your information in the following ways:

  • Affiliated entities. We may share information within the Lfcarry family of companies to deliver the Services, operate our business, and enhance our Services and your customer experience.
  • Service providers. We use third-party vendors to help us provide our Services and operate our business, and we may provide access to or share your information with these vendors. They provide a variety of services to us, including customer service, payment processing, product design and development, data storage, security, fraud prevention, research, and legal services. These service providers are permitted to access and use your information for purposes of performing services for Lfcarry or to comply with applicable legal requirements.
  • Third-party platforms, websites, applications, and services. When you initiate a connection with a third-party platform, website, application, or service through our Services (e.g., Discord, Google Maps), we will share information about you that is required to enable delivery of the third-party content or service. If you choose to initiate these connections, you agree that the third-party's policies and terms, and not Lfcarry's, govern your use of those third-party platforms, websites, applications, and services. We urge you to read the privacy and security policies of these third parties.
  • Protection of Lfcarry and others. We may disclose the information we collect about you if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (for example, a subpoena or court order); (b) enforce our terms of service, this Privacy Policy, or other contracts with you, including investigation of potential violations; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Lfcarry or others.
  • Business transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, including in contemplation of such transactions, your information may be among the transferred assets. If a portion or all of Lfcarry's assets are sold or transferred to a third party, we may share or transfer your information as part of the transaction.
6. Children's privacy
Our Services are intended for audiences aged 18 and older and are not directed at children. If we become aware that we have collected data without legally valid parental consent from children under an age where such consent is required, we will take reasonable steps to delete it as soon as possible.
7. Security and retention of your information
We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information.

When creating a Lfcarry account, it's important that you select a strong password and do not share it with others. Alert us immediately using the contact information below if you have any concerns about unauthorized use of your account.

Retention of your information. We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Policy. We will delete or de-identify information when it is no longer needed to fulfill these purposes, unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing your information.
8. Your controls and choices.
We provide you with the ability to exercise certain controls and choices regarding our collection, use, and sharing of your information. Your legal rights to exercise such controls and choices vary based on the laws of your jurisdiction.

You may request the following by contacting us as detailed in the "Lfcarry contact information" section below:

  • Access to, or a copy of, your information
  • More information about the information we collect and process
  • Correction or amendment of your information
  • Deletion of your information
  • Transfer of your information to a third party
  • Restriction or objection to certain uses of your information

We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests.
9. Additional information for certain jurisdictions
Information for California Residents

If you are a California resident, California law requires us to provide you with the following additional information about the purpose for which we use each category of "personal information" (as defined in the California Consumer Privacy Act ("CCPA")) we collect. For more information about each category and purpose of use, please see "The information we collect" and "How we use your information" sections above.

The CCPA sets forth certain obligations for businesses that "sell" personal information to third parties. Based on the definition of sell under the CCPA and under current regulatory guidance, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy.

To exercise any rights you may have with respect to your personal information under California law, please see the "Your controls and choices" section above. We will not discriminate against you for exercising these rights.

Notice concerning Do Not Track

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Some web browsers offer users a "Do Not Track" privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals. Learn more about Do Not Track.

California "Shine the Light" disclosure

The California "Shine the Light" law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such sharing. We do not currently share your personal information with third parties for their own direct marketing purposes.

Information for Nevada residents

Under Nevada law, certain Nevada consumers may opt out of the sale of "personally identifiable information" for "monetary consideration" (as such terms are defined under Nevada law) to a person for that person to license or sell such information to others. We do not engage in such activity; however, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of any future sales under Nevada law by contacting us as detailed in the "Lfcarry contact information" section below. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

Information for international users

We operate globally and may transfer, store, and/or process your information to or with other entities within the Lfcarry family of companies or other third parties such as trusted service providers and partners in locations around the world (including the United States) for the purposes described in this Privacy Policy. Wherever your information is transferred, stored, or processed by us, we take reasonable steps to protect your information in accordance with this Privacy Policy and applicable laws. These measures may include implementing Standard Contractual Clauses to govern the transfer of your information, or other means recognized by applicable laws. By providing us with your information, you acknowledge any such transfer, storage, or processing.

If you have any concerns or complaints about our data processing activities, we urge you to first try to resolve such issues directly with us. However, if applicable, you may make a complaint to the data protection supervisory authority in the country where you are based, or seek a remedy through local courts if you believe your rights have been breached.
10. Changes to our Privacy Policy
From time to time we may change or update this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. You should review the Privacy Policy periodically, and you can know if the Privacy Policy has changed since the last time you reviewed it by checking the "Last Updated Date" at the beginning of the document. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy. If we make material changes to the Policy, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective, in accordance with applicable legal requirements.
11. Lfcarry contact information
If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us using the following information:

Digital Companion Services Pte. Ltd.,
4 Battery Road #25-01,
Bank of China Building,
Singapore 049908

Contact us 24/7 privacy@lfcarry.com

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