PRIVACY POLICY

Last updated September 22, 2024

This Privacy Notice for Total Drama Queen Inc. ("we," "us," or "our"), describes how and why we might access, collect, store, and/or use ("process") your personal information when you use our services ("Services"), including when you:

• Download and use our mobile application (Kathy), or any other application of ours that links to this Privacy Notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. You are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at .

SUMMARY OF KEY POINTS

What personal information do we process? When you visit, use, or navigate our Services, we collect anonymous data, about which sections of the Services are being used using a first party collector, but do not collect any sensitive information about you or your child nor use any third party tracking. Because it is anonymous, we cannot use the tracking data to identify you, your device, your child, etc.

Do we process any sensitive personal information? Some information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any personal information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We do not share any personal information that we process with any third party.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

This information is primarily needed to improve our Services, maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

Sensitive Information. We do not process sensitive information.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) nor does it include any information about your child, location, etc.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). This will not be used for marketing or promotional purposes. All management of push notifications occurs on your device and does not use any back end servers/services to fulfill. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
  • We may also collect error reports (sometimes called “crash dumps”) if the application fails or has errors for the purposes of correcting any issues in future releases. These collections are handled by the Apple App Store services and Google Play services respectively.
  
  
  2. HOW DO WE USE YOUR INFORMATION?
  
  
  • To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
  
  In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
  
  If you are located in the EU or UK, this section applies to you.
  
  The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
  
  
  • Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to: (1) Analyze how our Services are used so we can improve them to engage and retain users; (2) Diagnose problems and/or prevent fraudulent activities
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
  
  If you are located in Canada, this section applies to you.
  
  In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
  
  
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  
  
  • We do not share your personal information with any other third parties.
  • We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  5. HOW LONG DO WE KEEP YOUR INFORMATION?
  
  We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law.
  
  When we have no ongoing legitimate business need to process your personal information, we will delete it where possible.
  
  6. HOW DO WE KEEP YOUR INFORMATION SAFE?
  
  We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
  
  7. WHAT ARE YOUR PRIVACY RIGHTS?
  
  In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
  
  In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details.
  
  We will consider and act upon any request in accordance with applicable data protection laws.
  
  If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
  
  If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
  
  Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the "HOW CAN YOU CONTACT US ABOUT THIS NOTICE? section"
  
  However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  
  8. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  
  If you are a resident of California, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.
  
  In the past twelve (12) months, we have not collected sensitive identifiers, personal information as defined in the California Customer Records statute, protected classification characteristics, commercial information, browsing information or online interests from third parties, geolocation data, audio/sensory or similar information, nor employment information.
  
  We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
  
  We may collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
  
  
  • Receiving help through our customer support channels;
  • Facilitation in the delivery of our Services and to respond to your inquiries.
  
  
  We will use and retain the collected personal information as needed to provide the Services or for up to one year.
  
  Your Rights
  
  You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
  
  
  • Right to know whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
  
  Depending upon the state where you live, you may also have the following rights:
  
  
  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's privacy law)
  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law)
  
  How to Exercise Your Rights
  
  To exercise these rights, you can contact us by emailing us at .
  
  Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
  
  Request Verification
  
  Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
  
  If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
  
  California "Shine The Light" Law
  California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
  
  9. DO WE MAKE UPDATES TO THIS NOTICE?
  
  We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
  
  10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  
  If you have questions or comments about this notice, you may email us at