SIDEHUSTLE GAMES GLOBAL PRIVACY POLICY

This Global Privacy Policy (“Privacy Policy”) describes how Side Hustle games, (part of the Mi Hiepa scout Group limited) (collectively, “Sidehustle games,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies to information we collect when you access or use our websites, and other online products and services that link to this Privacy Policy (collectively, our “Services”), or when you otherwise interact with us, such as through our customer support channels, or on social media pages.

We may provide different or additional notices of our privacy practices with respect to certain products or services, in which case this Privacy Policy will not apply.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the bottom of this policy. We may also provide you with additional notices (such as by adding a statement to the Services or sending you a notification) in connection with making material changes to this Privacy Policy. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

If you are a California resident, please see the “Your California Privacy Rights” section.

CONTENTS

Collection of Information

Use of Information

Sharing of Information

Analytics

Transfer of Information to the United States and Other Countries

Anonymization of Data

Your Choices

Your California Privacy Rights

Additional Disclosures for Individuals in Europe

Contact Us

COLLECTION OF INFORMATION
Information You Provide to Us

We collect information you provide directly to us. For example, we collect information directly from you when you fill out a form, submit or post content through our Services, communicate with us via third-party platforms, request customer support, participate in public forums, or otherwise communicate with us. The types of information about you that we collect include your name, email address, postal address, country of residence, username, password, phone number, and any other information you choose to provide. If you decide not to provide this information, it may limit our ability to provide some of our Services.

Information We Collect Automatically

We automatically collect certain information about your interactions with us or our Services, including:

Activity Information:

We collect information about your activity on our Services, such as when you request Services or information from us, or when you register with us (including when you link your profile on a third-party site or platform with your registration account), or when you participate in public forums, such as on Discord.

Transactional Information:

When you make a purchase or return, we may collect information about the transaction, such as product details, purchase price, and the date and location of the transaction or receive such information from the platform on which you purchased our products or Services.

Device and Usage Information:

We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.

Location Information:

In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices below for details).

Information Collected by Cookies and Similar Tracking Technologies:

We (and those who perform work for us) use tracking technologies, such as cookies and web beacons, to collect information about your interactions with the Services. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy and the Your Choices section below.

Information We Collect from Other Sources

We obtain information from other sources. For example, we may collect information from data analytics providers. Additionally, if you create or log into your Sidehustle game account through a third-party platform (such as, but not limited to, Sony PlayStation or Oculus), we will have access to certain information from that platform, such as your name and account id, in accordance with the authorization procedures determined by such platform.

USE OF INFORMATION

We use the information we collect to improve our website, games, and Services. We also use the information we collect to:

Provide, maintain, improve, and develop new products and services, including to debug and repair errors in our Services;

Personalize your experience with us;

Send you technical notices, security alerts, support messages and other transactional or relationship messages;

Communicate with you about products, services, and events offered by Side Hustle Games and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);

Monitor and analyze trends, usage, and activities in connection with our products and Services and our website;

Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;

Detect, investigate, and help prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and help protect the rights and property of Side Hustle Games and others;

Comply with our legal and financial obligations;

Create de-identified, anonymized or aggregated information; and

Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

With vendors that perform work for us, such as companies that assist us with web hosting or marketing.

If we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

If we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Sid Hustle games, our users, the public, or others.

With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

In connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

Between and among future parents, affiliates, and subsidiaries and other companies under common control and ownership.

With your consent or at your direction.

We may share aggregated or de-identified information that cannot reasonably be used to identify you.

We also receive hashed or encrypted information from the game platforms, such as Sony PlayStation and Meta Social, to allow us to provide customer support and Services for in-game issues.

ANALYTICS

We engage others to provide analytics services across the web. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by Side Hustle Games, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity. For more information, please review our Cookie Policy.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES
Side Hustle Games is headquartered in the United Kingdom and we have operations and vendors in the United Kingdom and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, or executing Standard Contractual Clauses. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at hello@sidehustlegames.com

ANONYMIZATION OF DATA
In certain instances, we may anonymize or de-identify your data. Anonymization is a data processing technique that removes or modifies personally identifiable information; it results in anonymized data that cannot be associated with any one individual.

By analyzing anonymized data, we are able to build safe and valuable products and features and better detect security threats, like phishing and malware sites, all while protecting user identities. We can also safely share anonymized data externally, making it useful for others without putting the privacy of our users at risk.

YOUR CHOICES

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. For more information about cookies and how to disable them, see our Cookie Policy.

Communications Preferences

You may opt out of receiving promotional emails from Side Hustle Games by following the instructions in those communications or by emailing hello@sidehustlegames.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

YOUR CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.), as modified by the California Consumer Privacy Rights Act or “CPRA”, affords consumers residing in California certain rights with respect to their personal information. Although the California Consumer Privacy Act does not presently apply to SideHustle games, Side Hustle games honors the CCPA’s protections and obligations. If you are a California resident, this section may apply to you.

California Consumer Privacy Act

In the preceding 12 months, we have collected the following categories of personal information: personal identifiers such as real name, alias, postal or electronic address, unique personal identifier, online identifiers, internet protocol addresses, and account names; commercial information; Internet or other electronic network activity information; audio, electronic, and professional or employment-related information or other similar identifiers as defined under Cal. Civ. Code § 1798.140(o). For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Category of Personal Information

Examples

Categories of Recipients

Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.

Vendors and service providers, web hosting and internet service providers, information technology, data analytics, customer service, cloud service, marketing and advertising.

1798. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, physical characteristics or description, address, telephone number, education, employment, or employment history.

Some personal information included in this category may overlap with other categories.

Vendors and service providers, web hosting and internet service providers, information technology, data analytics, customer service, cloud service, marketing and advertising.

1. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, or sex.

N/A

2. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

N/A

3. Internet or other similar network activity.

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.

Vendors and service providers, web hosting and internet service providers, information technology, customer service, cloud service, data analytics, marketing and advertising.

4. Audio, electronic, visual, thermal, olfactory, or similar information.

Audio chat features.

Vendors and service providers, web hosting and internet service providers, and information technology.

5. Professional or employment-related information.

Current or past job history or performance evaluations.

Vendors and service providers, web hosting and internet service providers, information technology, customer service, cloud service, data analytics, marketing and advertising.

Sidehustle Games does not “sell” or “share” your personal information as those terms are defined under the CCPA/CPRA.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request deletion of your personal information, (3) opt out of any “sales” or “sharing” of your personal information that may be occurring, and (4) request transmission of your personal information to another entity, (5) correct inaccurate personal information; (6) limit the use and disclosure of your sensitive personal information; (7) request to know more about automated decision-making; (8) opt-out of automated decision-making technology; and (9) not be discriminated against for exercising these rights.

You may make these requests by emailing hello@sidehustlegames.com. We will verify your request by asking you to provide information related to your recent interactions with us, such as your hashed ID of your player ID or Oculus ID. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent and they do not provide a valid power of attorney, we may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, we may also require you to verify your own identity directly with us or confirm to us that you otherwise provided the authorized agent permission to submit the request. If you are an authorized agent seeking to make a request, please email hello@sidehustlegames.com

ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE
If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

Additional UK GDPR info:

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
You have the right under this Privacy Policy, and by law if You are within the EU, to:

• Request access to Your Personal Data.
The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.

Contact: hello@sidehustlegames.com

• Request correction of the Personal Data that We hold about You.
You have the right to have any incomplete or inaccurate information We hold about You corrected.

• Object to processing of Your Personal Data.
This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.

• Request erasure of Your Personal Data.
You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.

• Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.

• Withdraw Your consent.
You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Legal Basis for Processing

When we process your personal data, we will do so in reliance on the following lawful bases:

To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).

When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).

To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).

When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for processing your personal data, you may withdraw such consent at any time.

Data Retention

We store personal data associated with your account (e.g., email, hashed/encrypted ID, name) for as long as your account remains active. We will delete your account data after two years of inactivity. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. If you consent to our use of cookies, we may collect and store data analyzing use of our website for up to two months. See our Cookie Policy for additional information.

Data Subject Requests

Subject to certain limitations, you have the right to request access to the personal data we hold about you and to receive your data in a portable format, the right to ask that your personal data be corrected or erased, and the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please email hello@sidehustlegames.com .

WE DO NOT DISCRIMINATE AND ALLOW ALL USERS ACCESS AND COMPLY TO REQUESTS TO DELETE PERSONAL DATA.

Questions or Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

CONTACT US

If you have any questions about this Privacy Policy, please contact us at hello@sidehustlegames.com

Side Hustle Games
(Part of Mi Hiepa scout LTD group)
Lower ground Floor, / Parsonage Chambers,
3 The Parsonage, / Manchester
M3 2HW

Last Updated: 16th September 2022