Privacy Statement

LAST UPDATED: September 1, 2021

This statement describes the personal data we collect and/or process (which may include collecting, organizing, structuring, storing, using, or disclosing) to provide products and services offered by Inventerprising Pty Ltd trading as Meeple.com (“Meeple”), including Meeple’s websites and its platform for event creation, organization, hosting, management, and payment collection (“Meeple Products” or “Products”). Meeple Products do not include products developed by Meeple that are covered under a separate privacy policy or not presented undering the “Meeple” brand.

What Personal Data Do We Receive?

Personal data is any information from or about an identified or identifiable person, including information that Meeple can associate with an individual person. We may collect, or process on behalf of our users, the following categories of personal data when you use or interact with Meeple Products:

• Account and Profile Information: Information associated with the Meeple account you are using, which may include name, picture, contact information, timezone and location, account ID, and billing information.
• Third-Party Streaming Keys and Event Details: Information you provide Meeple to enable streaming to third-party services (such as streaming keys), or details required to integrate or link to third-party videoconferencing or other services (such as event links).
• Settings: Information associated with the preferences and settings on the account or user profile, which may include audio and video settings, preferred currency settings, and other settings and configuration information.
• Device Information: Information about the computers, phones, and other devices people use when interacting with Meeple Products, which may include information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
• Event Information: Information associated with the creation, organization, management and/or details for an event or event series, which may include the event name, topic, start time, fee amount and currency, hosts information, users invited, users registered, users who have declined, applications to register, approvals or denial of applications, users who have pledged offerings or fees and the pledged amounts, and other event related information.
• Online Events on Meeple and Messaging Content and Context: Content generated during online events hosted using Meeple Products or messages that are hosted on Meeple Products, which may include audio, video, in-meeting messages, chat messaging content, transcriptions, written feedback as well as related context, such as event, participant and host details. Content may contain your voice and image, your settings, and what you do on Meeple Products.
• Product and Website Usage: Information about how people and their devices interact with Meeple Products, such as: when participants apply for an event, accept or decline an invitation, join and leave an event; whether participants made pledges of offerings or fees; when participants made payments; whether participants sent messages and who they message with; when hosts perform any actions relating to managing events, managing groups, and managing pledges of fees and offerings they have received from other users; performance data; mouse movements, clicks, keystrokes or actions (such as mute/unmute or video on/off), and other user inputs that help Meeple to understand feature usage, improve product design, and suggest features; features used (such as screen sharing, emojis, or filters); and other usage information and metrics. This also includes information about when and how people visit and interact with Meeple’s websites, including what pages they accessed, their interaction with the website features, and whether or not they signed up for a Meeple Product.
• Email and other communications by Meeple: Information about your interactions with email or other communication by Meeple (such as whether you have opened or viewed the communication).
• Communications with Meeple: Information about your communications with Meeple, including relating to support questions, your account, and other inquiries.
• Information from Partners: Meeple may obtain information about users from third-party companies, such as market data enrichment services.

How and Why Do We Use Personal Data?

Meeple employees do not access user content on Meeple Products unless directed by a user, or as required for legal, safety, or security reasons, or to conduct the following activities:

• Provide Meeple Products and Services: To provide Products, features, and services to users. Meeple also uses personal data, including contact information, to route event invitations, reminders and other messages. This may also include using personal data for customer support, which may include accessing audio, video, pictures, files, and messages, at the direction of the user. We also use personal data to manage our relationship with users, including for billing and account administration purposes.
• Product Research and Development: To develop, test, and improve Meeple Products, including, for example, video and audio quality, content-related features, and to troubleshoot products and features.
• Marketing and Promotions: To market, advertise, and promote Meeple Products, features, and services, including marketing products or features based on your product usage or information we receive from third-party partners. If you visit our websites, we may log information about how and when you visit, and your interactions with them, and use this information to provide advertisements to you relating to Meeple Products, features, and services or to engage third-party marketing partners to log your interactions on our website to assist us to market, advertise, and promote Meeple Products, features, and services.
• Authentication, Integrity, Security, and Safety: To authenticate accounts and activity, detect, investigate, and prevent malicious conduct or unsafe experiences, address security threats, protect public safety, and secure Meeple Products.
• Communicate with You: We use personal data (including contact information) to communicate with you about our Products, features, and services, including product updates, your account, and changes to our policies and terms. We also use your information to respond to you when you contact us.
• Legal Reasons: To comply with applicable law or respond to valid legal process, including from law enforcement or government agencies, to investigate or participate in civil discovery, litigation, or other adversarial legal proceedings, and to enforce or investigate potential violations of our Terms of Use or policies.

Meeple may use tools to automatically scan content such as virtual backgrounds, profile images, and files uploaded or exchanged through chat, for the purpose of detecting and preventing violations of our terms or policies and illegal or other harmful activity, and its employees may investigate such content where required for legal, safety, or security reasons.

How Do We Share Personal Data?

Meeple provides personal data to third parties only with consent or in one of the following circumstances (subject to your prior consent where required under applicable law):

• Vendors: Meeple may work with third-party service providers to provide, support, and improve Meeple Products and technical infrastructure. Meeple may also work with third-party service providers to provide advertisements and business analytics regarding Meeple Products. These vendors can access personal data subject to contractual and technical requirements for protecting personal data and prohibiting them from using personal data for any purpose other than to provide services to Meeple or as required by law.
• For Legal Reasons: Meeple may share personal data as needed to: (1) comply with applicable law or respond to, investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Use or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; 4) meet our corporate and social responsibility commitments; (5) protect our and our users’ rights and property; and (6) resolve disputes and enforce agreements.
• Marketing and Analytics Partners: Meeple may use third-party marketing and advertising providers to provide statistics and analysis about how people are using our services, and to provide advertising and marketing, including targeted advertising based on your use of our services. Where required by law, Meeple will first obtain your consent before engaging in the activities described here.
• Corporate Affiliates: Meeple may share personal information with corporate affiliates to provide integrated and consistent experiences across Meeple Products and to detect, investigate, and prevent fraud, abuse, and threats to public safety.
• Change of Control: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of Meeple’s business or assets, including in connection with bankruptcy or similar proceedings.

Who Can See and Share My Personal Data When I Use Meeple?

When you use Meeple Products, the following parties may be able to see content and information that you share:

• Event Hosts and Participants: Hosts and other participants in an event may be able to see your name and profile picture. Hosts can also see and (depending on settings) record or save event content (including event video and/or audio), and other information shared during an event.
• Third-Party Platforms: Hosts can choose to integrate/link to third-party platforms to host online events. Such third-party platforms may be subject to different terms and conditions and privacy practices.
• Livestreams: Hosts can choose to livestream to a third-party site or service, which means anyone with access to the livestream will be able to see the event.
• Payment Processors and Funds Transfer Services: We use third-party payments processors and funds transfer services in order to initiate, process and transfer payments on users’ behalf and we provide these third-parties with the information required to perform their services.

Privacy Rights and Choices

If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:

• Inform you of what personal data we have about you that is under our control;
• Amend or correct such personal data or any previous privacy preferences you selected, or direct you to applicable tools; and/or
• Delete such personal data or direct you to applicable tools.

In order to exercise any of your rights as to personal data controlled by Meeple, or if you have any other questions about our use of your personal data, please send a request to privacy@meeple.com. Please identify yourself and your contact details. We may also require you to provide further information or take additional actions to enable us to authenticate and respond to your request. Where legally permitted, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others. As a registered user, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.

Under 18 Years of Age

Meeple does not allow individuals under the age of 18 to sign up for a Meeple account.

How to Contact Us

To exercise your rights or if you have any privacy-related questions or comments related to this Privacy Statement, please send an email to privacy@meeple.com.

Retention

We retain personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law.

The criteria used to determine our retention periods include the following:

• The length of time we have an ongoing relationship with you and provide Meeple Products to you (for example, for as long as you have an account with us or keep using our Products);
• Whether users modify or delete information through their accounts;
• Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation).

European Data Protection Specific Information

Data Subjects Rights

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

• Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
• Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
• Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
• Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
• Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

In order to exercise any of your rights as to personal data controlled by Meeple, or if you have any other questions about our use of your personal data, please send a request at the contact details specified in the How to Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information or take additional actions (eg. signing into Meeple and performing a particular action) in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

Depending on the specific personal data concerned and the factual context, when Meeple processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

• As necessary for our agreement with you: When we enter into an agreement with you through your acceptance of our Terms of Use and use of Meeple Products, we process your personal data to perform our services in accordance with the agreement (e.g., providing Meeple Products, features and services to users). If we do not process your personal data for these purposes, we may not be able to provide you with all Products, features, and services;
• As necessary to comply with our legal obligations: We may process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;
• To protect your vital interests or those of others: We may process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
• As necessary for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data: We process your personal data based on such legitimate interests to (i) enter and perform the agreement with you as specified in the Meeple Terms of Use; (ii) develop, test, and improve our Products and troubleshoot products and features; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and Products, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the Products; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our users, resolve disputes, and enforce agreements.

International Data Transfers

Meeple operates globally, which means personal data may be transferred, stored (for example, in a data center), and processed outside of the country or region where it was initially collected.

Therefore, by using Meeple Products or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in other countries outside of the EEA, Switzerland, and the UK. Such countries may have data protection rules that are different and less protective than those of your country.

We protect your personal data in accordance with this Privacy Statement wherever it is processed.

California Privacy Rights

California Consumer Privacy Act

Under the California Consumer Privacy Act of 2018 (CCPA), California residents may have a right to:

• Access the categories and specific pieces of personal data Meeple has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom Meeple has shared personal data;
• Delete personal data under certain circumstances; and
• Opt out of the “sale” of personal data. We do not sell your personal data to any other party.

Meeple will not discriminate against you for exercising any of these rights. To exercise your rights, contact us by emailing privacy@meeple.com.

We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to 90 days) in writing.

Under the CCPA, only you or an authorized agent may make a request related to your personal data. Note that to respond to your requests to access or delete personal data under the CCPA, we must verify your identity. We may do so by requiring you to log into your Meeple account (if applicable), provide information relating to your account (which will be compared to information we have, such as profile information), give a declaration as to your identity under penalty of perjury, and/or provide additional information. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.

California’s Shine the Light Law

California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.

Changes to This Privacy Statement

We may update this Privacy Statement periodically to account for changes in our collection and/or processing of personal data, and will post the updated Privacy Statement on our website, with a “Last Updated” date at the top. If we make material changes to this Privacy Statement, we will notify you and provide you an opportunity to review before you choose to continue using our Products.