Privacy Policy

Effective date: [4/1/2020]

This Privacy Policy (“Policy”) describes how Kolosseum LLC, (“Kolosseum,” “we,” “us,” or “our”) collects, uses, discloses and secures the information that we collect from and about users of any of Kolosseum’s websites, mobile applications, platforms, products or services (collectively, the “Services”). We also describe the rights and choices you have regarding our use of your information. By using the Services, you agree with the terms and conditions described in this Policy.  If you do not agree with the terms and conditions described in this Policy, you may not use the Services.  

Your use of the Services is also subject to our Terms of Use found at ‘https://kolosseum.co/terms-of-use’.

1. THE INFORMATION WE COLLECT

When you download, register with, or use the Services, we collect information you provide directly to us or to other users, and information collected automatically from you and your device. Depending on how you use the Services and interact with us, we may collect the following information about you or your use of the Services.

1.  Information you provide to us:

We may collect certain information about you or your use of our Services when you provide that information to us.  You may provide this information when filling in forms in our Services or when you contact us.  This information allows us to provide our Services to you and interact with you.  

• Contact and/or Account Information: You may choose to provide certain information to us. For example, you may decide to share your first and last name, date of birth, location, email address, phone number, username and password, and the country and state in which you reside when you create an account to log in to our network (“Account”). We need this information to set up your Account, and provide you with our Services.
• Feedback: If you submit feedback or contact us via email, we will collect your name and email address, as well as any other content provided in the email.  This information is necessary for us to reply to you, provide customer and technical support, improve and optimize our Services, satisfy our legal obligations, enforce our contracts, and address any existing or anticipated disputes.
• Contests: When you participate in any contest, game or other similar feature through the Services (each, a “Contest” and, collectively, “Contests” ), we collect information about your participation in the Contest.
• Location Information: If you tell us where you are (e.g., by allowing your mobile device to send us your location or by otherwise permitting us to geolocate you), we may store and use that information to verify your eligibility to enter certain Contests, to comply with relevant laws, and for fraud prevention purposes.
• Survey Responses: When you participate in one of our surveys, we may collect additional information about your profile, activity, usage, and preferences related to the Services, so we can evaluate your interest in and the quality of our products, Services, and provide customer and technical support.

2. Automatically Collected Information

We may automatically collect certain information about the devices (including mobile devices or tablets) you use to access the Services. This information allows us to improve, personalize, and optimize our Services. Some of this information may also be collected so that when you use the Services again, we will be able to recognize you and optimize your experience accordingly.

• Device Information: We may collect information about the devices you use to access our Services, including the hardware models, IP addresses (including city and state information), operating systems and versions, software, file names and versions, unique device identifiers, advertising identifiers, and mobile network information. 
• Usage Information: We may also collect certain information from your mobile device, including information about how you use the Services, such as: platform type, the number of clicks, pages and content viewed and the order of those pages, statistical information about the use of the Services, error logs, and other similar information. We generally use this information to help us deliver relevant information to you. 
• Error Logs: In the event our mobile application crashes on your mobile device, we will also receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs, provide other technical support, and improve and optimize the performance of our Services.

2. COOKIES

We, and third parties we allow, use cookies and other similar technologies. Cookies are small text files placed on your device that uniquely identify your device and which a website can transfer to a user’s hard drive to keep records of his or her visit to a website. We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which we explain below:

• Essential. Some cookies are essential in order to enable you to move around our websites and use their features, such as accessing secure areas of our websites. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
• Analytics. We use Google Analytics to measure how you interact with our Services and to improve your user experience. To learn more about Google Analytics privacy practices and opt-out mechanisms, please visit the Google Analytics Security and Privacy Principles page at https://support.google.com/analytics/answer/6004245?hl=en. Google also provides a complete privacy policy and instructions on opting-out of Google Analytics at https://tools.google.com/dlpage/gaoptout. 

3. HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information, to:

• Provide you with the Services and their contents, and any other information, products or services that you request from us.
• Set up your Account.
• Fulfill any other purpose for which you provide it.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• Notify you when updates are available, and of changes to any products or services we offer or provide.
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Services according to your individual interests.
• Recognize you when you use the Services.
• Contact you about our Services that may be of interest to you.
• Identify and fix bugs, provide other technical support, and improve and optimize the performance of our Services.
• To comply with relevant laws, and for fraud prevention purposes

4. HOW WE SHARE YOUR INFORMATION

We do not share any of the information identified above with third parties except as described in this section. We may disclose your information to the following categories of third parties in the following circumstances:

• Affiliates and Subsidiaries. We may share information we collect from you to current and future affiliates and subsidiaries of Kolosseum.
• Service Providers and Other Third-Parties. We may provide access to or share your information with select third parties who perform services on our behalf, including without limitation, for marketing, market research, customer support, data storage, analysis and processing, and legal services.
• Protection of Kolosseum and Others. We may access, preserve, and disclose your information if required to do so by law or in a good faith belief that such access, preservation, or disclosure is reasonably necessary to: (a) comply with legal process; (b) enforce our Terms of Use, this Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property, or personal safety of Kolosseum, its agents and affiliates, its users, or the public. 
• Business Transfers. As we continue to develop our business, we may undergo reorganization. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be disclosed in connection with the negotiation of such transaction, or sold or transferred as part of such a transaction as permitted by law or contract.
• User Feedback. We may publicly post user feedback on the Services from time to time.  We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting. 
• Parties You Share With. When you use the Services, the personal information you openly provide with others will be shared with parties you allow to receive such information. For example, you may elect to communicate personal information with other users who are participating in the same Contest as you.
• Professional Financial and Legal Advisers. From time to time, we may also need to share your information with professional advisers, including lawyers, auditors, bankers, insurers and consultants, in order to obtain advice or other professional services from them. Such advisers are bound by legal or contractual duties of confidentiality and other prohibitions against disclosure of personal information.
• Promotions. When you participate in a Contest, we may use your name, opinions, and biographical information for publicity, advertising, trade, or promotional purposes without further payment, consideration, notice, or approval.
• Social Networking Sites. Our Services may enable you to post content to social networking services (e.g., Facebook). If you choose to do this, we will provide information to such services in accordance with your elections. In such an event, you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of such services. We will not be responsible or liable for: (i) the availability or accuracy of any such service’s terms of use or privacy policy; (ii) the content, products or services on or availability of such services; or (iii) your use of any such services.

We may also aggregate, de-identify, and/or anonymize any information collected through the Services in such a way that we cannot reasonably link the information to you or your device. We may use such aggregated, de-identified, or anonymized information for any purpose, including without limitation for research and marketing purposes.

5. NOTICE OF PUBLIC POSTING AREAS

If you make any comments on a blog or forum associated with the Services you should be aware that any personal information you submit there can be read, collected, or used by other users of the blog or forum and might be used to send you unsolicited messages. We are not responsible for any personal information you choose to submit in these blogs and forums.

6. SECURITY 

We take technical, administrative, and physical measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk.

Where we have given you (or where you have chosen) a password that enables you to access the Service, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.

7. YOUR CHOICES REGARDING PERSONAL INFORMATION

Accessing, Updating, and Deleting Your Information. You may be able to access, update, or delete certain information we hold about you in the user settings of our mobile application. If you wish to request access or deletion of your information, please contact us at the information provided below. We will respond to your request within a reasonable timeframe.

Marketing Communications and Sharing. You may instruct us not to use your contact information to contact you with marketing communications regarding products, services, promotions and special events that might appeal to your interests by contacting us. In commercial email messages, you can also opt-out by following the unsubscribe instructions located at the bottom of such emails. Please note, we may send you information regarding our Services, such as information about changes to our policies and other notices and disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature, rather than promotional.

Uninstall. You may stop all collection of information by our mobile application by uninstalling the mobile application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

8. THIRD PARTY LINKS 

The Services may contain links to or from third-party websites, applications, and other services available to support the operations and functionality of the Services. Please be aware that we are not responsible for the privacy practices of such other websites and services. If you submit information to any of those websites, your information is governed by their privacy statements. We encourage our users to be aware when they access third-party websites and/or leave the Services and to read the privacy statements of each and every website they visit that collects their information.‍

9. RETENTION OF YOUR INFORMATION

We keep your information for no longer than necessary for the purposes for which it is processed and/or as required to comply with applicable laws. The length of time for which we retain information depends on the purposes for which we collected and use it.‍

10. CHILDREN

We do not knowingly collect or solicit personal information from anyone under the age of 13. If we learn that we have collected personal information from a child under age 13, we will take reasonable steps to delete it as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at the information provided below and we will endeavor to delete such information from our systems without undue delay.

11. NOTE TO INTERNATIONAL USERS

The Services are hosted in the United States and are intended for and directed to users in the United States. If you are a user accessing the Services from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the Services, you are transferring your personal information to the United States and you consent to that transfer. Your information may be stored and processed in any country where we have facilities or in which we engage service providers and, by using the Services, you consent to the transfer of information to jurisdictions outside of your country of residence, which may have different data protection rules than those of your country.

12. YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits visitors to the Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes. ‍

13. HOW WE RESPOND TO DO NOT TRACK SIGNALS

At this time our websites do not recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

14. HOW TO CONTACT US

To ask questions or comment about this Policy and our privacy practices, or any reports regarding suspected or actual security violations, contact us via email at help@kolosseum.co.

15. CHANGES AND UPDATES TO THIS PRIVACY NOTICE

We may update this Policy from time to time. If we make any material changes, we will notify you by email at the primary email address specified in your account.

The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this Policy to check for any changes. Your continued use of the Services following the posting of changes to this Policy will mean you accept those changes.