Last Updated: 7/17/2023, 6:48 PM
Last Updated: July 1, 2023
Let’s get one thing clear: Statespace has never, does not and will not make money from the sale of your personal information. We run our business by building the best products and Services, not selling your info. In order to give you the best gaming experience, we may share your information with our partners to promote our own products and Services, as described below.
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR INFORMATION
4. HOW WE DISCLOSE YOUR INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. INTERNATIONAL DATA TRANSFERS
8. RETENTION OF PERSONAL INFORMATION
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
10. SUPPLEMENTAL NOTICE FOR VIRGINIA, COLORADO AND CONNECTICUT RESIDENTS
11. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
12. CHILDREN’S INFORMATION
13. OTHER PROVISIONS
14. CONTACT US
PERSONAL INFORMATION WE COLLECT
We collect personal information both from our user customers (“Users”), as well as from our expert coaches and content creators (“Creators”) who provide personalized online training (“Coaching Services”) as well as other. The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
Account Creation. Depending on whether you are a User or Creator, we may collect the following information to set up your account (“Account”):
Users: we may collect your email address, public-facing username, and password. If you create an Account or connect an existing account using your login credentials from a third-party social media account such as Discord, Twitch, Apple, or Google, we’ll be able to access and collect your name and email address and other personal information as determined by your third-party social media account settings. If you choose to link your Account to an account you have with a third-party video game provider (such as your Riot account), we may import user data from your third-party game account and public APIs to display additional statistics in your Account profile page, and correlate that data on our own backend with other data you provide through our Services (as described below).
Creators (Coaches): We may collect your email address, name, signature, link to social channels, supported games, payment information, photo, links to your prior coaching or other game-related content, your desired coaching rate, and other information about your interests and expert qualifications. You will also have the option to share information about yourself via our Services with other Users.
Interactive Features. We and other Users may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages like our Discord channel). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.
Additional note regarding Coaching Services. The Coaching Services may include additional activities, such as one-on-one training sessions, interactive seminars/classes, Video-On-Demand reviews of gameplay, Q&A sessions, personalized playlists, tasks or training regiments, or other similar services, as selected by the Creator. All of these Coaching Services may require both Creators and Users to provide additional personal information to us, which we will collect and store as part of your Account and use to determine whether the Coaching Services have been delivered as promised.
Purchases. We may collect personal information and details associated with your purchases (including your subscriptions), including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).
Your Communications with Us. We may collect personal information, such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, apply for a job, or otherwise communicate with us.
Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Sweepstakes, Tournaments, or Contests. We may collect personal information you provide for any sweepstakes, tournaments or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners. In the event that you enter personal information on behalf of teammates in a tournament or contest, you represent and warrant that you have consent to do so.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services:
Your Stats and Skill Level. When you interact with our Services, such as our Aim Lab software, we collect detailed statistics about your play history, including your performance and scores in certain Aim Lab tasks. These scores are used to assess your strengths and weaknesses, as well as your skill level and rank which are visible to other Users as part of your public profile. Additionally, your scores on Aim Lab tasks are shared with other Users via our leaderboards, but you can make your presence on our leaderboard anonymous.
Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below). For example, we may track your in-app activity, including recordings of your gameplay and other interactions with the Aim Lab software;
Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
See "Your Privacy Choices and Rights" below to understand your choices regarding these Technologies.
Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
C. Information Collected from Other Sources
HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfil our contract with you and provide you with our Services, such as:
Managing your information and Accounts;
Providing access to certain areas, functionalities, and features of our Services;
Answering requests for customer or technical support;
Communicating with you about your Account, activities on our Services, and policy changes;
Processing your financial information and other payment methods for products or Services purchased;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for events.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Short-term, transient use, such as contextual customization of ads;
Improving, upgrading or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
Debugging to identify and repair errors with our Services;
Auditing relating to interactions, transactions and other compliance activities;
Sharing information with third parties as needed to provide the Services, such as the Coaching Services;
Enforcing our agreements and policies; and
Complying with our legal obligations.
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, and “interest-based” or “personalized advertising,” including through cross-device tracking. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
Automated Decision-Making. We may engage in automated decision making, including profiling, such as to analyze your skill and identify areas of improvement. Statespace’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.
De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses we create.
Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend neighbor, or co-worker).
HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
Creators (for Coaching Services). If you participate in Coaching Services, your gameplay and other information will be accessible by your Creator coach.
Other Users. As described above in “Personal Information We Collect,” our Services allow you to share your profile and/or gameplay statistics with other Users and publicly, including to those who do not use our Services.
Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services.
Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
YOUR PRIVACY CHOICES AND RIGHTS
Statespace has never, does not and will not make money from the sale of your personal information. We run our business by building the best products and Services, not selling your info. In order to give you the best gaming experience, we may share your information with our partners to promote our own products and Services, as described below.
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. A DNT technology standard has not been adopted to this day, therefore and we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information;
Request Correction of your personal information where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
Request Restriction of or Object to our processing of your personal information when processing is noncompliant;
Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available;
Request data portability and receive an electronic copy of personal information that you have provided to us;
Be informed about third parties with which your personal information has been shared; and
Request the review of decisions taken exclusively based on automated processing if these decisions could affect your data subject rights;
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
SECURITY OF YOUR INFORMATION
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
If we transfer personal information to countries outside the European Economic Area, we will put in place appropriate safeguards to ensure that this transfer complies with the applicable laws and regulations. For more information about these safeguards, please contact us as set forth below.
RETENTION OF PERSONAL INFORMATION
SUPPLEMENTAL NOTICES FOR RESIDENTS OF CALIFORNIA, NEVADA, COLORADO, CONNECTICUT, VIRGINIA AND UTAH
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Statespace has collected about them and whether Statespace disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
Category of Personal Information Collected by Statespace
Category of Third Parties Information is Disclosed to for a Business Purpose
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Account name, or other similar identifiers.
Data analytics providers
Other Users/Public (username only)
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, physical characteristics or description, address, bank account number, credit card number, debit card number, or any other financial information.
Data analytics providers
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Data analytics providers
Physiological, biological, or behavioral characteristics, keystroke patterns or rhythms.
Data analytics providers
Other Users/Public (performance metrics only)
Internet or other electronic network activity
Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
Data analytics providers
Audio, electronic, visual, or similar information.
Data analytics providers
Other Users/Public (performance metrics only)
Inferences drawn from other personal information to create a profile about a consumer
Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Data analytics providers
Other Users/Public (performance metrics only)
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.
“Sales” of Personal Information under the CCPA
Statespace does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age, as the term “sale” is commonly understood. That said, we do share information with third-party advertisers for the purpose of promoting our Services. To the extent that such sharing is considered a “sale” under the CCPA, you may opt-out of having your information shared by disabling third-party cookies on your device, or by contacting us as set forth in “Contact Us” below.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your Account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
Refer-a-Friend and Similar Incentive Programs. As described above in How We Use Your Personal Information (“Share Content with Friends or Colleagues”), we may offer referral programs or other incentivized data collection programs. For example, we may offer incentives to you such as discounts or promotional items or credit in connection with these programs, wherein you provide your personal information in exchange for a reward, or provide personal information regarding your friends or colleagues (such as their email address) and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party’s data to us depends on whether the referred party ultimately becomes a User and/or Creator and uses our Services. Said value will be reflected in the incentive offered in connection with each program.
Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in “Contact Us” below.
SUPPLEMENTAL NOTICE FOR VIRGINIA, COLORADO AND CONNECTICUT RESIDENTS
The Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”) and the Connecticut Data Privacy Act (“CTDPA”) provide residents of Virginia, Colorado and Connecticut with specific rights regarding their personal information. This section describes the rights of consumers who are residents of Virginia, Colorado and Connecticut and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information. Before we disclose information to you, we will ask you for information to verify your identity. Once we receive and confirm your verifiable consumer request, we will disclose to you whether we process your personal information and provide you with access to your personal information. We will provide a copy of personal information we have obtained about you in a portable and, to the extent technically feasible, readily usable format. Please note that we may not disclose the information you have requested if we are unable to verify your identity. In addition, we may not disclose certain information that is covered by one or more exemptions, as outlined in the VCDPA, CPA and CTDPA.
Deletion Request Rights. You have the right to request that we delete personal information that we collected and retained. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. If we deny your deletion request, we will inform you and explain the basis for our denial.
Correction Request Rights. You have the right to request that we correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing. Once we receive and confirm your verifiable consumer request, we will correct your personal information from our records, unless an exception applies. If we deny your correction request, we will inform you and explain the basis for our denial.
Appeals. If we deny your request, you have the right to appeal our decision. We will respond to appeals from Virginia and Connecticut residents within 60 days. We will respond to appeals from Colorado residents within 45 days.
How to Exercise Your Virginia, Colorado or Connecticut Privacy Rights. To exercise any of the rights described above, please contact us directly as set forth in “Contact Us” below. You must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to it.
SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us as set forth below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your Account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s Account if applicable.
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
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