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Financity Privacy Policy

FINANCITY PRIVACY POLICY

Financity is a service offered by WealthEnV LLC (“Financity”). This document explains how we collect, use, and share your information when you use Financity. You can also read the WealthEnV privacy policy for more details by clicking https://www.wealthenv.com/privacy-policy/. If you have any questions, please Contact Us as described below. When we say “Financity” (or similar words like “we” or “us”) in this document, we mean the Financity team that oversees and responsible for your information, which includes WealthEnV LLC (“WealthEnV”) and its partners such as Kordspace that help us provide and support Financity.

1. What is Financity

We use the term “Financity” to refer to any WealthEnV products or services that are linked to this document. These include, for example:

WealthEnV.com
OtterBlotter

Please note that your use of Financity may also be subject to other terms and conditions such as the WealthEnV privacy policy, which you can find https://www.wealthenv.com/privacy-policy/. Please read this document carefully. You should also review any other agreements that apply to Financity and make sure you understand and agree with them before using them.

2. The information we collect

The information we collect depends on how you interact with Financity. We may collect information in three main ways: A) when you give it to us, B) automatically when you use Financity, and C) from service providers and third parties.

Information You Give Us – You can give us different kinds of information depending on how you use Financity. Sometimes we’ll ask you for specific information, such as when we need it to provide parts of Financity to you (for example, by asking you for your date of birth or asking you to complete an online registration process). If we ask you for information in these cases and you choose not to give it to us, you may not be able to access Financity or some features may not work as intended. For example, to buy and play our games, you may need to have a WealthEnV account. To create one, you’ll need to give us basic information like your name, a public display name, password, the country you live in, and email address. If you want to use WealthEnV, we may ask you for payment information (like your credit card number and expiration date) to complete the transaction. Also, many of our services require your date of birth to determine what features we can offer you and what settings to apply to your account based on your age and location. We also collect the information you voluntarily give us to sign up for email alerts, use social features like forums or chat, register for early access to our games, use our tools (including to create and publish games and other content), enable two-factor authentication, register for, or attend our events, complete surveys, or contact us through Player Support requests or customer service. If you use our voice chat feature and voice reporting is enabled in a voice channel, snippets of voice chat audio data will be stored on your device and the devices of participants in the voice channel. If someone reports a violation of our Community Rules, these snippets may be sent to Financity or WealthEnV to help us enforce those rules. If you enter a contest or competitive event, we’ll collect your application information and other information we may need to confirm your eligibility and process payouts. We collect whatever information you decide to give us in those or other situations.
Automatic Information Collection – We automatically gather some information when you interact with Financity. This includes details about your gameplay, application usage, purchases, entitlements, and other activities, typically linked to your account (if you’re logged into your WealthEnV account or using a third-party account to access Financity) or an identifier we’ve assigned to your device or profile. The specific types of information we collect can vary, but generally include:

Usage data and statistics, such as the application or game you used, duration and timing of use, gameplay attempts, progression, and results, saved preferences, crash reports, visited URLs of our websites, URLs of referring and exiting pages, page views, time spent on a page, number of clicks, and platform type.
Technical details about your computer, device, hardware, or software used to access our services, like IP address, device identifiers, your internet service provider, plugins, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other device or system-related specifications); and
Your device’s general location, typically derived from your device’s IP address.

Financity uses technologies like cookies, log files, and web beacons to automatically collect the types of information listed above. Some of these technologies may create small files or record-keeping tools stored on your device. They help us, our service providers, and third parties recognize your device and provide information about your interaction with Financity. For instance, they support our ability to authenticate users, remember preferences, manage advertising, personalize experiences, and conduct data analytics. Please note that if certain features on Financity are provided by third parties, those third parties may also use automated data collection methods and may record information about your use of Financity, their services, or other websites over time. For example, when you use Financity that includes third-party software (like Unreal Engine), those third-party providers may collect information through their technology. These features are subject to the privacy notices and policies of those third parties.

Information from Other Sources – We may also collect information about you from service providers and third parties related to your use of Financity or your interactions with us on other platforms. For instance, if you link your Financity account with a third-party social media (like Facebook), gaming (like Steam), or similar website or service, or if you interact with a Financity ad on an external website or service, the company running that website or service may share some information with WealthEnV according to their privacy practices. The specific types of information they can share with WealthEnV are typically controlled by your privacy settings on the other company’s website or service, so we recommend reviewing and updating them regularly. Examples of linked account information might include your third-party account display name and user ID, as well as associated device information, name, and email address. We may also collect the number of followers you have on social media for program eligibility purposes. You might be able to purchase, download, or access some Financity products or services through third party operated services. If so, they may provide us with information to help you access and use Financity. This usually includes information like your display name, user ID, and device and region information. For example, you can choose to download and play other games on gaming consoles (like PlayStation®, Microsoft Xbox, and Nintendo Switch) through your gaming console account. When you do, the company operating that platform or service may share some information with us, which helps us facilitate your gameplay and track your progression and entitlements.

3. Use of Information

In general, we use the information we collect (either individually or in combination with other information as outlined in this policy) to help us deliver, enhance, customize, analyze, and promote the Financity Product. This includes using it for purposes such as:

Creating, verifying, and managing user accounts and features.
Providing the Financity Product, as well as support and assistance for them, including responding to inquiries, processing transactions or requests, and communicating with users (such as by sending service and account-related messages and updates).
Developing, delivering, and improving the Financity Product and other offerings, some of which may be offered in partnership with other parties.
Personalizing your experience, including by presenting content or features better suited to you or your interests, or our inferences about your interests through WealthEnV.
Promoting the Financity Product, including managing, customizing, and measuring the effectiveness of our advertisements, promotional offers, surveys, and events. • Managing alpha, beta, or early access tests (and collecting feedback).
Conducting data analytics (like analyzing how the Financity Product is used so we can better understand, improve, and personalize it).
Complying with our legal or contractual obligations and enforcing our terms; and
Securing the Financity Product, such as by detecting fraud and otherwise protecting WealthEnV and other users from illegal or harmful actions.

We may also process information that does not identify you individually, including aggregate or de-identified information that we create or collect from other sources. This information helps us better understand larger groups of users. If we combine this information with information that identifies you, we will treat it as described in this privacy policy. However, please note that this privacy policy does not limit our ability to process information that does not individually identify you, and we may use and disclose aggregated or de-identified information for any reason permitted by law.

4. Sharing Information

We may distribute some of the information we gather to assist in the operation and enhancement of the Financity Product. The specifics of what we share depend on your interactions with us, but common instances might include sharing:

With console and platform partners (for instance, to enable gameplay when you access the Financity Product via a third-party console provider);
With other game developers (such as to activate features for games you obtain through WealthEnV).
With other users (like when you use social features such as chat).
Publicly (for example, your display name, content you create or share, basic game statistics, and other similar information may be accessible to others).
With service providers who work on our behalf to assist in supporting the Financity Product according to our instructions (for example, cloud storage providers, payment processors, or marketing and advertising partners).
When we believe it’s necessary to comply with the law or to protect you, WealthEnV, or others (for example, in response to a court order or subpoena, during an investigation of fraud or other illegal activity, or violation of our terms or policies, or if required to protect others from serious harm to body or property).
With other WealthEnV entities (including to assist in providing international support for the Financity Product).
In relation to certain types of corporate transactions (like in the event of a restructuring or the sale of all or a significant portion of our business); and
With your consent (for example, if you link external accounts with your WealthEnV account, or use your WealthEnV account to sign into third-party games and services or participate in cross-promotional events).
We may also distribute information that does not identify you to third parties, including aggregate or de-identified information.

No mobile phone numbers given to WealthEnV for security reasons will be shared with third parties or affiliates for marketing/promotional purposes. Third parties you interact with through the Financity Product may have different privacy practices than WealthEnV, so we recommend reviewing their privacy policies before sharing your information with them.

5. Fraud Prevention & Anti-Cheat

Ensuring a fair, balanced, and competitive user experience on Financity is our top priority. We have a strict policy against cheating, hacking, account theft, and any other unauthorized or fraudulent activities on Financity. To enforce this, we may employ various anti-cheat and fraud prevention technologies. These services would help us identify and prevent malicious activities by collecting and analyzing data about your computer and its software. This process aids in detecting cheating and may be facilitated by WealthEnV or other providers.

6. Children’s Privacy

We are developing the Financity Product to be accessible and enjoyable for users of all ages globally. However, during the initial development releases, children under 13 will not be permitted to play. Please look forward to future releases of the Financity Product that will accommodate Children Accounts. These will allow parents and guardians to understand our privacy practices concerning children (under 13 or the age of digital consent in the user’s specific region), including any notices, consents, and parental controls.

7. Personal Information

We aim to give you significant control over the personal information that we collect. The specific choices available to you often depend on our relationship with you, such as the Financity Product you use. Common examples include:

You can request access to, or correction or deletion of, personal information we’ve collected from you. Please submit requests to access, update, or delete personal information associated with your WealthEnV account by contacting us as indicated in the “Contact Us” section. Note that we may ask you for additional information to verify your identity before fulfilling your request.
You can modify your email marketing preferences at any time, such as by using the opt-out mechanism provided in our marketing emails, updating your WealthEnV account settings, or contacting us with your request (see “Contact Us” below).
You can adjust your privacy settings on other parties’ websites (such as social networks) or platforms (like console providers) to limit the information they may share with us.
You can alter your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies. Please note, blocking or disabling cookies may cause the Financity Product not to work as intended and some features may not be available.
If you’re under the age of 18 and have a WealthEnV account, you can request that we remove or anonymize certain content you’ve provided on the Financity Product. Please direct requests to delete or edit content on the Financity Product to WealthEnV as described in “Contact Us” below.
Children under the age of 13 will not be able to access the Financity Product until future releases that enable Children Accounts.

Certain regions around the world provide individuals with specific choices related to their personal information by right under local law.

8. Operations

Financity, Inc. is based in the United States, but we intend to operate globally to help provide users all around the world with a better experience on the Financity Product. WealthEnV may process the information we collect in connection with your use of the Financity Product in places outside the region where you reside.

Data Transfers

When you use Financity, your information may be transferred to or stored in the United States or other countries where we or our service providers are based. The data protection laws in these countries may differ from those in your country of residence. We rely on various legal mechanisms to lawfully support the transfer of information outside the country where it was collected, as needed. If allowed by local law, by using Financity, you’re authorizing WealthEnV to process your information in any of the locations where we operate, including the United States. For more information about the WealthEnV entity responsible for operating the Financity Product you use, please refer to the “Contact Us” section.

California Residents

The California Consumer Privacy Act, or “CCPA,” grants certain rights to California residents regarding their personal information. If you are a resident of California, you may have the right to:

Request more information about the categories and specific pieces of personal information we collect, use, and disclose.
Request deletion of your personal information.
Opt out of the sale of your personal information (if applicable).
Not be discriminated against for exercising these rights.

You or your authorized agent can make these requests by contacting us as indicated in the “Contact Us” section. Please note that we may ask for additional information to verify your identity before fulfilling your request. If we receive your request from an authorized agent, we may ask for evidence that you have given that person the authority to submit requests on your behalf. We will not discriminate against you if you exercise your rights under the CCPA.

We collect the following categories of personal information, as described in the CCPA:

Identifiers (such as email addresses).
Demographic information (like ages).
Commercial information (including entitlements or purchase history).
Internet or electronic network activity (for example, gameplay or website usage details).
Audio, electronic, visual, or similar information (like voice chat).
Geolocation information (such as may be derived from your IP address or included in your billing information).
Other “personal information” as defined under California law (like your credit or debit card information).
Inferences drawn from any of these categories.

For details about the specific the data we collect and the categories of sources from which we obtained that information, please refer to the “Use of Information” section above. We collect personal information for business and commercial purposes as described above in “Use Information”.

WealthEnV does not sell or share (as those terms are defined in the CCPA) the personal information we collect. However, we do disclose personal information as described in this policy (see “Use of Information” above). In the past 12 months, we may have disclosed personal information to the following categories of recipients:

Business partners (e.g., Kordspace).
Other WealthEnV entities.
Other users (for example, if you use chat or social features on the Financity Product).
Service providers (as described in “Use of Information” above).
Operating systems and platforms.
Government entities or other third parties in response to a legal request.

Residents of The European Economic Area, The United Kingdom, And Switzerland

If you’re located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, you have certain rights regarding how your personal data is processed.

Data Subject Rights

You may have the right to access, correct, or delete personal data we have collected about you through the Financity Product. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. Where you have provided your consent to our data processing, you have the right to withdraw your consent.

You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.

Please see the “Contact Us” section below to learn more about reaching out to WealthEnV with any relevant concerns you may have. You can find more details about your local Data Protection Authority as follows:

Basis for Processing

The legal bases we rely on to process your personal data depend on the Financity Product you use and how you interact with them. They primarily include:

Contractual Necessity: we process personal data to perform the Financity Product you requested under our Terms of Service or other similar contractual agreements with you. For example, we process personal data to set up and maintain your account; process your purchases; authenticate users; provide user-experience features (like saving your preferences); monitor and analyze the Financity Product; detect and prevent fraud, cheating, or other similar misuse; facilitate features like cross-progression that allow you to play a game on one platform and continue your progress on another, which may require us to share your information with third-party partners; and contact you about your account, transactions, or other updates. We also rely on the performance of a contract to manage our relationship with you, which includes responding to your support requests or general inquiries and notifying you about changes to our applicable terms or policies.
Legitimate Interests: we process personal data as needed for WealthEnV’s business purposes, as balanced against the potential impact on your privacy rights. This includes many common purposes that you’d reasonably expect, such as to: communicate with you, respond to your requests, or provide you with updates and information; better understand our users and their preferences; personalize your experience, save your preferences, authenticate our users, and provide similar user experience features; develop, deliver, and improve the Financity Product and other offerings (some of which may be offered in partnership with other parties); manage and customize advertisements or promotional offers; manage (in-game) purchases; secure and protect the Financity Product; prevent fraud and illegal activity; and support internal purposes such as auditing and data analysis. To support these business purposes, we may use machine learning technologies to help identify harmful, toxic, or fraudulent content in our services. The content identified by these technologies will be subject to human review.
Legal Obligations: we process personal data when necessary to comply with legal obligations, such as responding to legitimate requests from law enforcement authorities or other government officials in accordance with relevant legal processes or processing date of birth to facilitate compliance with applicable youth protection laws.
Consent: we process personal data when you provide us with your consent to do so. You aren’t required to provide consent if you do not want your personal data to be processed for the requested purposes, and you may withdraw your consent at any time.

Retention

The specific personal data we process and our reasons for doing so often vary depending on your use of the Financity Product, which also affects the duration of its retention. We generally store personal data for as long as we reasonably need it for the purposes outlined in this policy (such as complying with our legal obligations, managing internal records, enforcing our terms, and resolving disputes), unless a longer retention period is required or permitted by law.

The main factors we consider when determining specific retention periods often include minimum requirements under applicable law, relevant industry standards, the types of data in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (like defending ourselves against legal claims), and whether the data is required to prevent fraud or similar abuse of the Financity Product (including to enforce prohibitions against cheating and other unauthorized behavior). For instance, if you create a WealthEnV account, we will generally store the personal data associated with your WealthEnV account for as long as needed to maintain your account, provide the Financity Product you requested, enforce any terms that govern your use of the Financity Product, and maintain appropriate records to reflect how we deliver the Financity Product to you.

To learn more about requesting that WealthEnV delete your personal data, please refer to the “Personal Information” and “Data Subject Rights” sections above.

9. SECURITY

We implement suitable administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use, as well as other unlawful forms of processing. In certain cases, your information can be accessed when you log into a feature we provide. In these instances, it’s crucial that you keep your user credentials and password confidential and secure to protect your information. If we become aware of any unauthorized disclosure of your personal information, we will notify you as mandated by law and take measures to help secure your information.

10. UPDATES

This policy will be updated periodically to reflect changes in our practices or relevant laws. When updates occur, we’ll modify the date indicated at the top of the policy. In certain instances, we may also inform you of pertinent changes via email or within the Financity Product. We encourage you to regularly review this policy to ensure you understand your relationship with WealthEnV and how we may collect, use, and share information in relation to the Financity Product.

11. CONTACT US

If you have any queries or concerns about the Financity Product, such as issues related to games, difficulties accessing your WealthEnV account, bugs or other technical problems, payment matters, or issues with content and entitlements, please reach out to our Player Support teams.

For more information about our privacy practices or this policy, feel free to email your questions about our products and services to: • privacy@wealthenv.com