Privacy Policy

Basic Fun General Privacy Notice 

Effective Date: July 20, 2023 

Basic Fun, Inc. and its affiliates (“Basic Fun,” “we,” “us,” or “our”) respect your privacy. This Privacy Notice describes the processing of Personal Information (defined below) that is provided, collected, or shared on the sites, applications, social media pages, or other platforms that link to this Privacy Notice (collectively, the “Site”). It also describes your choices about the collection, sharing, and use of your Personal Information. 

We may modify this Privacy Notice at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Site or otherwise communicated to you. 

1. Personal Information We Collect 

We may collect and process a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.  

The types of Personal Information we collect may include: 

• Contact Information – If you create a profile, make a purchase, participate in contests, events, or promotions, send questions or comments via email, completed online survey, or live chat with a Basic Fun Consumer Relations representative, we collect your contact information. This information includes name, phone number, email address, postal address, birthday, or other identifying information. 
• Location Data – While navigating our Site your mobile device or browser may share your location data, both through WiFi and GPS. We will collect this information based on the settings of your phone and browser.   
• Usage Information – When you use our Site, our servers may automatically record information, including your Internet Protocol address (IP Address), browser type, referring URLs (e.g., the site you visited before coming to our Site), domain names associated with your internet service provider, information on your interaction with the Site, and other such information.  
• Employment Information – If you apply for employment, we will collect your employment and work history, as well as other Personal Information related to your potential employment. This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.   

• Communication Information – We may collect audio, electronic, or visual information, which includes screen sharing views; any data in any files uploaded, emailed or otherwise provided by customers; the contents of your communications with us, whether via e-mail, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect. 
• Customer Communication Records – Where permitted by applicable law, we may collect and maintain records of calls and chats with our agents, representatives, or employees via message, chat, post, or similar functionality.

1. How We Collect Your Personal Information  

• We May Collect Your Personal Information Directly From You – For example, if you create a profile, make a purchase, participate in contests, events, or promotions, send questions or comments via email, complete online surveys, or live chat with a Basic Fun Consumer Relations representative. 
• We May Also Collect Personal Information From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you. Additionally, if you create or log into your account through a third party social networking site, we will have access to certain information from that site, such as your name and any other account information disclosed in accordance with the policies of that third party social networking site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical services, advertising networks, analytics providers and search information providers, and may receive information about you from them. From time to time, we undertake or commission consumer research projects, and we may share personal data with third party research companies for this purpose. Also, such third party research companies may host survey data in their databases on our behalf. All data transfers for this purpose will be subject to a written contract between us and the third party vendor in question.  
• Through Online Tracking Technologies – We and our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the Site.  We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the Site, to enhance your experience through personalization, and to help us better understand the features of the Site that you and other users are most interested in.   

Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available, or some functionality may be limited or unavailable.  Please review the help pages of your browser or mobile device for assistance with changing your settings. 

Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the Site and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the privacy notice of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/. 

Online Behavioral Advertising.  We may use your Personal Information to send or deliver advertisements that are customized based on predictions about your interests generated from your visits to websites (including this Site) over time and across different websites.   

We use Google Ads to serve ads across various websites. Google uses Cookies to collect data about your visits to the Site to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Site. 

To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you. 

• Through Analytics – We use analytics services, including Google Analytics, to assist us with analyzing our website traffic through cookies and similar technologies.  To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.  

1. How We Use Personal Information 

To the extent permitted by applicable law, we may use Personal Information to: 

• send you advertising or promotional materials, including information about new products, contests, features and enhancements, special offers and other events of interest; 
• operate and improve the Site; 
• provide and deliver the products and services you request, process transactions, and to send you related information, including confirmations and invoices; 

• respond to your comments, questions and requests, and provide customer service; 
• monitor and evaluate trends, usage and activities in connection with the Site; 
• personalize and improve the Site, and provide ads, content, communications or features that match user profiles or interests; 
• link or combine with other information obtained through third parties to help understand your needs and provide you with better service; 
• operate the Site and provide support to our business functions; 

• fulfill customer requests, such as to create an account or complete customer purchases; 
• protect against criminal activity, claims and other liabilities; 
• send you information about our company, products, services, and promotions; 
• respond to reviews, comments, or other feedback provided to us; 
• support and personalize the Site and our advertising efforts; 

• protect the security and integrity of the Site; 
• send you technical notices, updates, security alerts, and support and administrative messages; 
• the extent required for benchmarking, data analysis, audits, developing new products, enhancing the Site, facilitating product, software and applications development, improving the Site or our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes; 
• meet our contractual requirements; 
• comply with applicable legal or regulatory requirements and our policies; 

• respond to inquiries related to employment opportunities; 
• market, advertise, and provide the Site and our services; and 
• the extent necessary for any other lawful purpose for which the Personal Information is collected. 

1. Disclosing Your Personal Information 

We may disclose your Personal Information in the following circumstances: 

• For Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Basic Fun, its users, or the public against harm. 
• In the Case of a Merger or Sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer. 
• With Service providers – When we hire a service provider to help operate the Site or our business, we may give access to Personal Information as necessary to perform the service for Basic Fun.  This may include service providers that operate our Site, send our communications, or run our promotions.  
• With Business Partners – We may share Personal Information with our trusted business partners.  For example, we may share your Personal Information with a company when we co-sponsor a promotion or service, or whose products or services you may be interested in.  These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products. 
• With Social Media Partners – We may share Personal information with social media partners, through social sharing features and other integrated tools (such as the Facebook® “Like” button or widgets). These features may also collect your IP address, device ID, which page you are visiting on our website, and may set cookies and similar technologies to enable the features to function properly.  

1. How Long Do We Keep Your Personal Information 

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Notice, or any longer retention period required by law.   

1. How We Protect Your Personal Information 

We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information.  

1. Your Choices and Controls 

Depending on where you are located and subject to certain exceptions, you may have the right to exercise certain controls and choices regarding our collection, use, and sharing of your Personal Information.  These right may include the following:

• Right to Know – You may have the right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared. 
• Right of Access – You may have the right to be informed of and request access to the Personal Information we process about the applicant.   
• Right to Rectification (Correct) – Under certain circumstances, you may have the right to request that we amend or update inaccurate or incomplete Personal Information about them. 

• Right to Erasure (Deletion) – Under certain circumstances, you may have the right to request deletion of their Personal Information. 
• Right to Data Portability – Under certain circumstances, you may have the right to request a copy of their Personal Information in an electronic format and further request that we send such Personal Information to another party. 
• Communication Preferences and Opt-Outs– You may have the right to stop receiving marketing communications from us at any time. To opt-out of marketing communications please email us at  Cu*************@ba******.com  or by following the instructions included in the email or text correspondence.   

Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law.  Additionally, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our services to you. 

1. International Use of the Site 

If you are visiting this Site from outside of the United States, please note that by providing your Personal Information it is being transferred to, stored, collected, or processed in the United States, where our servers are located and operated.  

1. Children’s Privacy  
2. We do not intentionally collect or solicit any Personal Information from children under the age of 16 without their parent’s consent.  In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at  Cu*************@ba******.com  or contact us using the information listed in Section 15.  

Guidelines have been established under applicable privacy to protect the online privacy of children. Basic Fun is committed to complying with these guidelines, which include those set by CARU, for online privacy and security. We’d like you to review this website to make sure you’re satisfied with our approach and presentation. Basic Fun does not want to collect any information that you, as a parent, are uncomfortable having your child submit to us.  

Our Safety Guidelines strictly prohibit the posting of information that could personally identify a child, such as their photo, real name, email address, phone number or physical location, unless the parent explicitly agrees to allow such, perhaps in regard to becoming a contest winner, finalist, etc. We also aim to prevent kids from being exposed to web content that might make them feel anxious or frightened, so we rigorously regulate links to outside website 

1. Links to Third Party Websites 

We are not responsible for the practices employed by any websites or services linked to or from the Site, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s Privacy Notice. 

1. California Residents 

Subject to certain exceptions, this Section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations, as amended by the California Privacy Rights Act (the “CPRA”). This Section describes (1) the categories of Personal Information, collected and disclosed by us, subject to CPRA, (2) your privacy rights under CPRA, and (3) how to exercise your rights.

When we use the term “Personal Information” in the context of the CPRA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.   

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 15. 

1.  Categories of Personal Information Collected, Used, and Shared 

We have collected the following categories of Personal Information from our consumers within the last 12 months. The sources from which we obtain this information and the ways in which we use this information are set forth in Section 2 above. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

Category of Personal Information Collected	Category of source from which Personal Information is Collected	Purpose of Collection	Category of Recipients to whom Personal Information is Disclosed for a Business Purpose	Is Personal Information Sold or Shared?
Identifiers, such as your name, address, and email address.	Directly from you	See Section above titled “Purposes for Which We Collect Personal Information”	Service providers	No
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or health insurance information.	Directly from you	See Section above titled “Purposes for Which We Collect Personal Information”	Service providers	No
Internet or other similar network activity.	Directly from you; and Cookies	See Section above titled “Purposes for Which We Collect Personal Information”	Service providers	No
Geolocation data	Directly from you; Business partners; and Cookies	See Section above titled “Purposes for Which We Collect Personal Information”	Service providers	No
Professional or employment-related information.	Directly from you; Business partners	See Section above titled “Purposes for Which We Collect Personal Information”	Service providers	No

If you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by contacting us per the “Contact Us” Section below. 

We will retain each category of your personal information for as long as necessary to fulfill the purposes described in the “How We May Use your Personal Information” section above, unless otherwise required by applicable laws. Criteria we will use to determine how long we will retain your Personal Information include whether: we need your Personal Information to provide you with products or services you have requested; we continue to have a relationship with you; you have requested information, products, or services from us; we have a legal right or obligation to continue to retain your Personal Information; we have an obligation to a third party that involves your Personal Information; our retention or recordkeeping policies and obligations dictate that we retain your Personal Information; we have an interest in providing you with information about our services; and we have another business purpose for retaining your Personal Information.  

1. Your California Privacy Rights 

Subject to certain exceptions, if you are a resident of California, you may have the following rights: 

Privacy Right	Description
Notice	The right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
Access	The right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
Data Portability	The right to receive the Personal Information you have previously provided to us.
Erasure	The right to have your Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.
Correction	You have the right to request that we correct any incorrect personal information that we collect or retain about you, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see below), we will correct (and direct any of our service providers that hold your data on our behalf to correct) your personal information from our records, unless an exception applies. We may deny your correction request if (a) we believe the personal information we maintain about you is accurate; (b) correcting the information would be impossible or involve disproportionate; or (c) if the request conflicts with our legal obligations.
To Opt Out of Sales or Sharing of Personal Information	We do not sell or share your Personal Information. However, if we did, you would have the right to opt out of the sale or sharing of your Personal Information.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your Personal Information. You may also make a request on behalf of your minor child. 

You may only make a request for access or data portability twice within a 12-month period. The request must: 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. 
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 

1. Individuals in the European Union, European Economic Area, and United Kingdom 

The purpose of this section is to provide information and additional provisions that apply regarding our processing of Personal Information of individuals located in the European Union and/or United Kingdom (“UK”) in accordance with the EU General Data Protection Regulation 2016/679 and the UK General Data Protection Regulation (collectively referred to herein as the “GDPR”). 

1. Legal Basis for Processing 

Our legal basis for processing the Personal Information described in this Privacy Notice will depend on the Personal Information concerned and the context in which we process it.  We process Personal Information from you: 

• where we need it to perform a contract with you; 
• where the processing is in our legitimate interests (including the purposes described, above, in How We Use Personal Information);  
• where the processing is necessary for us to meet our applicable legal obligations; or 
• if we otherwise have your consent. 

1. Transfers of Personal Information 

Personal Information may be transferred to and/or processed by third parties that are located outside of the EU or UK, some of which may not be considered to have an adequate level of protection for Personal Information. We will only transfer Personal Information to third parties located outside of the EU or UK when we have ensured appropriate safeguards for the protection of such Personal Information through use of the standard contractual clauses or other approved methods. 

1. Your Privacy Rights 

Pursuant to the GDPR, you may have the right to: 

• Request access to your Personal Information.   

• Request correction of your Personal Information. 
• Request erasure of your Personal Information. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
• Object to processing of your Personal Information.  
• Request restriction of processing of your Personal Information. 
• Request the transfer of your Personal Information to you or to a third party. 
• Withdraw consent at any time where we are relying on consent to process your Personal Information.  

For more information on how to exercise any of these rights, see Section 14 below. Depending on where you are located, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning your Personal Information.  We encourage you to first reach out to us so we have an opportunity to address your concerns directly before you do so. 

1. Exercising Your Individual Privacy Rights 

You will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.   

To exercise your privacy rights under applicable data protection law, please submit a request to us by one of the following methods: 

• Phone: 1.561.208.7970 
  E-mail:  Cu*************@ba******.com   

Verification: We must verify your identity before fulfilling your requests.  If we cannot initially verify your identity, we may request additional information to complete the verification process. We will only use Personal Information provided in a request to verify the requestor’s identity. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.    

We endeavor to respond to requests within the time period required by applicable law. If we require more time, we will inform you of the reason and extension period in writing.  

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. 

We do not charge a fee to process or respond to your 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. 

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us.  

We may deny certain requests, or only fulfill some in part, as permitted or required by law.  For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes 

Appeals: If you are not satisfied with the resolution of your request and would like to submit an appeal, please email us at  Cu*************@ba******.com   

1. Changes to this Privacy Notice   

Please note that we may modify or update this Privacy Notice from time to time, so please review it periodically. We may provide you with an updated Privacy Notice if material changes are made. Unless otherwise indicated, any changes to this Privacy Notice will apply immediately upon posting to the Site.   

1. Contact Us 

If you have any questions about our practices or this Privacy Notice, please contact us at  Cu*************@ba******.com . You may also write to us at: 

Basic Fun, Inc. 
301 Yamato Road, Suite 4200 
Boca Raton, FL 33431 
1.561.208.7970 
Cu*************@ba******.com   

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