Privacy Policy for Shuffle.us

This Privacy Policy governs the manner in which Munyon Canyon Limited ("Shuffle.us", "We", "us", or "our"), collects, uses, maintains and discloses information collected from customers of its website www.shuffle.us. This Privacy Policy applies to www.shuffle.us and all products and services offered through www.shuffle.us.

Shuffle.us is committed to protecting and respecting your privacy and maintaining the confidence and trust of its customers. This Privacy Policy explains how your personal information is collected, why it is collected and how it is kept secure.

Munyon Canyon Limited is responsible for processing the data collected from you using the website www.shuffle.us.

1. Definitions

Personal Information: Any information about you, whether it is true or not, that can reasonably be used to identify you, or otherwise make you identifiable.
Anonymous Information: Information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual.
Aggregate Information: Information about groups or categories of customers, which does not identify and cannot reasonably be used to identify an individual customer.
Shuffle.us (including "Munyon Canyon Limited", "We", "Us" or "Our"): Refers to Munyon Canyon Limited and any applicable subsidiaries or affiliates that form the Shuffle Group and may collect, use, maintain and disclose information collected from the Website as applies to this Privacy Policy.

2. Data Controller

Munyon Canyon Limited is a company incorporated under the laws of the British Virgin Islands, with the register number 2179096 and head office at Trinity Chambers, PO Box 4301, Road Town, Tortola, British Virgin Islands, British Virgin Islands. Munyon Canyon Limited is responsible for processing the data collected from you using the website www.shuffle.us.

3. Type of Information We Collect

We collect three types of information: Personal Information, Anonymous Information, and Aggregated Information. Any other information that we receive and identify as your Personal Information will be treated as Personal Information by Shuffle.us.

The types of Information we may process depend on the business context and the purposes for which it was collected. It may include:

Contact Details, such as your first name and surname, email address, residential address, and mobile or other phone numbers.
Personal Information, such as gender, age, age range or your image.
Unique personal identifier attributed from your username, email address, mobile or other phone number(s) and/or residential address.
Account login details, including your username, password and pictures associated with your profile.
Transaction Information you provide when you make a purchase, request a redemption or otherwise use the Website, such as your postal address, phone number and payment or redemption information including banking and financial details, credit card details and bank account statements (we do not store your full card details).
Geolocation Information, including approximate location information provided by a mobile or other device interacting with the Website, or associated with your IP address, where we are permitted by law to process this information.
Usage Data, which may include activity, technical and device information about your use of the Website, such as the content you view, the time and duration of your visit on our Website, how often you use our services, how you first heard about our Website, your preferences and information about your interaction with the content offered through our Website, your hardware model, device type, other unique device identifiers, operating system version, browser type and IP address.
Sensitive Information, which may include government issued identity (including drivers licenses, passport and social security numbers), geolocation and financial information to comply with our business, legal and regulatory purposes.
Information we obtain from a third party, such as a site or platform provider (including Facebook and Google), about your use of or interest in our services.
Identification documents (may include ID, utility bills, bank statements, etc.).
Communications exchange with our teams (support, live chat, complaints, etc.).

4. Jurisdictional Statement

The Shuffle Group of which Shuffle.us is an affiliate operates in several international jurisdictions and Personal Information we collect may be transferred to, and stored and processed by, individual companies in the Shuffle Group or by third parties in the European Union, the United States, Canada, Australia, or any other country in which our third-party processors maintain facilities. We will ensure that transfers of Personal Information to any country or organization are subject to appropriate safeguards.

5. Policy Updates

This Privacy Policy may be updated from time to time to reflect changes in the way we work or the way our work is regulated. We will notify you of material changes and, where required by law, will obtain your consent. Notice may be by the posting of such changes on our website or by other means in accordance with applicable law. Any changes to the Privacy Policy will become effective when the updated policy is posted on www.shuffle.us. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the Personal Information we collect.

Information Collection Table

Information Category	What this contains	We Capture this Information
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, or other similar identifiers.	YES
Personal Information	Including but not limited to name, signature, social security number, physical characteristics or description, communications such e-mails or chat messages, address, telephone number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.	YES
Protected Classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
Commercial Information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
Biometric Information	An individual's physiological, biological or behavioral characteristics that can be used singly or in combination with each other or with other identifying data, to establish individual Identity. Facial recognition technology collects information from your image capture, including biometric data, and shares this information with us, which assists us to verify your ID.	YES
Internet or other similar network activity	Browse history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
Geolocation data	Physical or IP address location or movements.	YES
Sensory data	Audio, electronic, visual, or similar information.	YES
Professional or employment-related information	Current or past job history.	YES
Non-public education information	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, predispositions, behaviour.	YES
Government Identifiers	Social security, driver's license or state identification card.	YES
Complete account access credentials	Customer names, account numbers, digital currency addresses, or card numbers combined with required access/security code or password.	YES
Precise Geolocation	Precise physical or IP address location or movements.	YES
Racial or ethnic origin	Racial or ethnic origin information that may be revealed through Government or other identifiers or other personal information.	YES
Religious or philosophical beliefs		NO
Union membership		NO
Genetic data		NO
Mail, email or text messages content not directed to us	Chat conversations conducted on our platform; communications with our affiliates or service providers.	YES
Unique identifying biometric information	Biometric information that may be revealed through Government or other identifiers or other personal information.	YES
Health, sex life, or sexual orientation information		NO

6. Sources of Information

We obtain the categories of personal information listed above from the following sources:

Directly from our customers. For example, when customers register for our services or respond to requests for information verification.
Directly and indirectly from activity on our websites and applications. This includes:
- Usage and log information. For example, service-related, diagnostic and performance information. This includes information about your activity on our websites and applications, log files and reports.
- Device and connection information. We collect device-specific information such as hardware model, operating system information, browser information, IP address etc.
From third-parties that interact with us in connection with the services we perform. We may work with third-parties, for example, in order to understand, customise, provide, support and market the services we provide and/or to comply with laws.

7. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To provide and manage the services you request
To maintain, develop, and improve customer service and our services
To create, maintain, customize, and secure your customer account
To fulfill purchases or redemptions and prevent transactional fraud
To personalize user experience
To contact you about our services
To send important notices to you
To comply with our legal and regulatory obligations
To offer alternative dispute resolution services.

We will not retain the categories of personal information and sensitive personal information longer than reasonably necessary to achieve these business purposes. Ordinarily, we will retain your personal information and sensitive personal information for up to 12 months beyond any closure of your account, unless a longer retention period is required or permitted by law.

8. Sharing of Personal Information

We may disclose your personal information to third-parties for the business purposes described above. We may disclose your personal information for a business purpose to the following categories of third-parties:

Our affiliates
Service providers
Third-parties that interact with us in connection with the services we perform

We do not sell your personal information or share it with third-parties for cross-context behavioral advertising.

9. Exercising Access and Deletion Rights

To request access to or deletion of your personal information, please submit a verifiable consumer request to us at [email protected].

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. If you decide to use an authorized agent, please also include written permission that you have designated that agent to make this request, or proof of the agent's power of attorney. We may follow up with you to verify your identity before processing your authorized agent's request.

For your consumer request to be verifiable, you must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. You will need to provide:
- Full name
- Date of birth
- Address
- E-mail address
- Whether you are a California consumer pursuant to CCPA
If you would like to know the specific pieces of personal information that we have collected about you, or to delete your personal information, identification that clearly shows your name, date of birth and address (for example, driver's license or other photo identification)
Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

10. Response Timing and Format

We endeavor to provide timely responses to verifiable consumer request. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

11. Non-Discrimination

We will not discriminate against you for exercising any of your rights described above.

12. Changes to this Notice

This Notice may be updated from time to time to reflect changes in the way we work or the way our work is regulated. We will notify you of changes by posting changes here, or by other appropriate means.

13. Contact Information

If you have specific questions regarding your Personal Information, how we process or use it, or to exercise your rights, please contact our Privacy Team directly by email at [email protected].