Welcome to Toffee Rewards! At Galactica Games, Inc., the creator of Toffee Rewards (“Toffee,” “we,” “our,” or “us”), your privacy is a top priority. This Privacy Policy (“Policy”) explains the types of information we gather, how we may use it, who we may share it with, and the choices you have regarding your data. This Policy applies to your use of our website, the Toffee mobile app, and any products or services that reference this Policy (collectively referred to as the “Services”).   

This Policy does not cover information we receive from third parties.  If you have any questions regarding this Privacy Policy, please contact us at support@toffeecash.com.

By using the Services, you acknowledge and accept the terms outlined in this Policy. If you disagree with any part of this Policy, you should discontinue using the Services immediately. The version of this Policy in effect at the time you access the Services will govern its use. Therefore, it’s important to review the date at the top of this Policy and familiarize yourself with any updates or changes since your last visit.

By using the Services, you agree to comply with the Toffee Terms of Use in addition to this Privacy Policy.

INFORMATION WE COLLECT

We gather two categories of information from users of our Services: "personal information", which includes details you provide that can identify you (such as your name or email address), and "accumulated data", which consists of data that does not identify you (such as how often you visit our website or the type of browser you use). The collection of both personal and accumulated data occurs in the situations outlined below. 

We may share transaction details with Reward Partners to facilitate your participation in the Toffee Rewards Program. This includes sharing data such as card identifiers, merchant location, and transaction timestamps with participating merchants and service providers.

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Information You Provide to Us

Your Account Information: 

When you interact with our Services, you may share specific information with us directly. For instance, when you sign up for a Toffee Rewards account, we ask for your name, username, phone number, email address, and payment details (such as your credit or debit card number). Additionally, you have the option to include extra information in your profile during the account setup process.

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Toffee Rewards Program:
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The following definitions apply to the Toffee Rewards Program:

“Merchant” means a merchant that participates in the “Toffee Rewards Network.”
The “Toffee Rewards Network” refers to the mobile payments platform operated and maintained by Galactica Games Inc., encompassing the Toffee Rewards app and any related products or services designed, developed, or supported by Toffee Rewards as part of this network.
A “Loyalty/Rewards Account” refers to a rewards or loyalty account you hold with a participating Merchant, which you link to your Toffee Rewards account. This account will automatically apply to all purchases of goods and services with that Merchant unless you choose to unlink or remove it from your Toffee Rewards account.
“Payment Method” means the payment type or account you load into your Toffee Rewards Account to pay for goods and services at participating Merchants.
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When you use the Toffee Rewards Program, we also collect information from you when you:

Add a Payment Method, start or finalize a transaction using a Payment Method, open or use a Loyalty/Rewards Account, or redeem an offer through the Services (including location data from the physical point-of-sale terminal where the Payment Method or Loyalty/Rewards Account transaction takes place, for operational purposes such as maintaining transaction records and detecting or preventing fraud), interact with any advertising or offers in the Services, or redeem a promo code or other offer.
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We collect the following additional information from you when you use the Toffee Rewards Program:

• Transaction details and data for purchases of goods and services at participating Merchants, including the registered card identifier, merchant location, transaction timestamp, and transaction amount.

• Information about the Payment Method that you choose to provide to Toffee Rewards, along with details required to process Payment Method transactions. This may include your bank account details, credit or debit card information, gift card or prepaid account data, associated security codes, or other payment credentials.

• Additional personal details required to verify your Payment Method(s), such as your driver’s license number, social security number, or responses to security questions used for identity authentication. This information is used exclusively by Toffee Rewards’ third-party authentication service provider or by the issuer of your Payment Method if you request Toffee Rewards to link the issuer’s Payment Method to your account. Toffee Rewards does not store this information, use it for marketing purposes, or share it with any unaffiliated third parties. If you wish to review the privacy policy of Toffee Rewards’ authentication provider, you can request it by emailing support@toffeecash.com.

• Loyalty/Rewards Account IDs or account numbers.

• Health-related information, claims, or other data reflecting your health or wellness may be included in your Payment Method transactions. Although direct health details are typically not necessary for Payment Method transactions, certain health-related information, such as the number of prescriptions you fill each month or the location of the pharmacy or store where you make these purchases, may be part of the data generated during a Payment Method transaction.

• Certain aspects of our Services, including events, websites, apps, and offers, may be jointly branded and provided in collaboration with a Merchant. For example, Toffee Rewards might deliver the Services through a Merchant’s branded app. In these cases, any information you provide may be shared with both Toffee Rewards and the Merchant involved in the transaction. Each party will handle the information in accordance with its respective privacy policy and any agreements the Merchant has separately established with you. Toffee Rewards does not oversee or take responsibility for how the Merchant uses your information. 

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Your Communication with Us:
We gather information when you interact with us. The details we collect depend on the method of communication. For instance, if you contact us via email, we will collect your email address along with the content of your message.  

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If and when our referral feature becomes available, you may choose to use it to share the Service with someone. In such cases, we may request information, such as the person’s email address, to send the invitation. A one-time email will then be sent to the individual, inviting them to explore our website. We retain this information solely to send the invitation, record the connection if the invitation is accepted, and monitor the performance of our referral program. The individual can contact us at support@toffeecash.com to request the removal of their information from our records.

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You may only refer people who have explicitly given you their consent, and it is your responsibility to inform them that they may receive communications from the Services on your behalf. Before providing us with their contact details, you must ensure you have their permission, and you confirm and guarantee that Toffee Rewards is authorized to send these communications without infringing on the individual’s privacy rights.

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Location Information:
Toffee Rewards employs location detection technology to assess your general location, including nearby Wi-Fi networks and cell towers. If you grant permission, the Services may also collect your exact geolocation data. Any location information provided through the Services is intended solely for general use and should not be relied upon in scenarios requiring highly accurate location details or where incorrect or incomplete data could result in harm, injury, property damage, or environmental risks. We make no guarantees regarding the availability, accuracy, completeness, reliability, or timeliness of the location data collected or displayed by the Services.

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If you are a user of the Toffee Rewards Program and choose to opt-in for location-based advertising, your location data may be used to "identify" you within a store or specific area to deliver tailored ads and offers. This data may also be utilized in connection with a Merchant’s loyalty or rewards program or their customer appreciation initiatives.

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Information We Automatically Collect

As with most apps and websites, when you use our Services we automatically receive and collect information about you and your device(s).  This information includes, but is not limited to, the following:

• ‍Information about your device, such as the operating system, hardware, system version, the Internet Protocol (IP) address, device ID, and device language.

• The specific actions that you take when you use our Services, including but not limited to the pages and screens that you view or visit, search terms that you enter, how you interact with our Services, and information about your interactions with other users.

• The time, frequency, connection type, and duration of your use of our Services.

• Information about your wireless and mobile network connections, such as mobile phone number, service provider, and signal strength.

• Location information, such as GPS information. 

• Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.

• Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below); and

• Pages you visited before or after navigating to our website.
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  Cookies and Analytics

Our Services place small data files on your computer or mobile device. These data files may be cookies, pixel tags, e-tags, or other local storage provided by your browser or Apps (collectively “Cookies”).
Some of these Cookies are technical (i.e., they allow us to provide the Services) and some are non-technical (i.e., they provide analytics about the use of our Services, allow us to remember your preferences, or facilitate advertising). We also use third-party advertisers (each, a “Third-Party Advertiser”) to market, sell and display advertisements on our Services. These Third-Party Advertisers may recognize Cookies we have placed (or place their own Cookie) on your device to collect information about your use of the Services for use in connection with their advertising activities.

How we use Cookies
We use both persistent and session Cookies. Persistent Cookies are used to improve your experience on our Services. This includes, for example, recording your acceptance of our Cookie Policy to remove the Cookie message that first appears when you use our Services. Session Cookies are temporary and are deleted from your device when your web browser closes. We use session Cookies to help us track internet usage.
We will not keep the personal data that we collect through Cookies for longer than is necessary to fulfil the purposes mentioned in this Privacy Policy.

Types of Cookies

• Strictly necessary/ Technical
  These Cookies are necessary to allow us to operate the Services so you may access them as you have requested. These Cookies, for example, let us recognize that you have created an account and have logged into that account to access content through the Services. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure the Services.

• Analytical / Performance
  These Cookies are used by us or our business partners to analyse how the Services are used and how they are performing. For example, these Cookies track what pages are most frequently visited, and what locations our visitors come from. These Cookies may be correlated to you. These Cookies include, for example, Google Analytics Cookies.

• Functionality
  These Cookies let us operate the Services in accordance with the choices you make. These Cookies permit us to "remember" you in between visits. For instance, we will recognize your user name and remember how you customise the Services, for example by adjusting text size, fonts, languages and other parts of web pages that are alterable, and provide you with the same customizations during future visits.

• Third-Party Advertising
  We allow our business partners to use Cookies on our Services for the same purposes identified above, including collecting information about your online activities over time and across different websites. The business partners that generate these Cookies, such as Adobe and Google, have their own privacy policies governing their use of this information, and may use their Cookies to target advertising to you on other websites, based on use of the Services.

• How to delete Cookies
  Most web browsers accept Cookies automatically. However, you can delete Cookies manually or set your browser to automatically delete Cookies on a predetermined schedule. Most browsers will tell you how to stop accepting new Cookies, how to be notified when you receive a new Cookie and how to disable existing Cookies. You can find out how to do this for your particular browser by clicking “help” on your browser's menu or by consulting other sources such as www.all aboutcookies.org.
  Please note that if you decline to accept Cookies, you may not be able to take advantage of or participate in certain features of the Services.
  Most browsers allow users to use a “private mode” by which Cookies are deleted after your website visit. Please read the help section of your browser to learn more about how to activate the “private mode.” You can still visit our website if your browser is in “private mode,” however, the user experience may not be optimal and some utilities may not work.
  If you want to remove previously-stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Services from placing further Cookies on your device unless and until you adjust your browser setting as described above.
  For more information on the development of user-profiles and the use of targeting/advertising Cookies, please consult sources such as www.youronlinechoices.eu, if you are located in the EU, or www.aboutads.info/choices, if in the United States.

• Adobe Flash Player
  Our Services enable the use of the Adobe Flash Player, which generates “flash cookies” by default. Flash cookies remember user settings, preferences and usage similar to the browser Cookies referenced above, but flash cookies can store more information than browser Cookies and are managed through a different interface than the one provided by your web browser.
  You can control the degree to which you accept flash cookies by accessing your Adobe Flash Player management tools directly through the settings manager for Adobe Flash, located at
  http://www.macromedia.com/support/documentation/
  en/flashplayer/help/settings_manager.html. If you do not allow flash cookies to take any disc space on your computer, you may not be able to take advantage of or participate in certain features on the Service.

• Web Beacons
  Our web pages or e-mail messages may contain a small graphic image called a web beacon, which allows us to monitor and collect certain limited information about our users, such as the type of browser requesting the web beacon, the IP address of the computer that the web beacon is sent to and the time the web beacon was viewed. We use web beacons to count visitors to our web pages or to monitor how our users navigate our Services, and we include web beacons in e-mail messages in order to count how many of the messages we sent were actually opened or acted upon.

• IP Addresses
  An IP Address is a number that is assigned to your mobile device, computer or network when you are linked to the Internet. When you use our Services, our servers log your IP Address. We use IP Addresses for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit the use of the Services. We associate your IP address with other personal data you provide.
  
  
  

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Third Party Advertising

‍Advertisements displayed on the Service may be provided directly to users by third-party advertisers. When this occurs, these advertisers automatically receive your IP address or device ID. They may also employ technologies such as cookies, JavaScript, or web beacons to evaluate the performance of their ads and tailor their advertising content to users. Through these methods, they can collect data about where ads were displayed to users of your device or browser and track which ads were clicked. However, third-party advertisers do not have access to your personal contact information.

Toffee Rewards does not share your personal information with third-party ad servers or ad networks unless you provide explicit consent or participate in a specific program or feature that you have chosen to opt into. However, if an advertiser requests Toffee Rewards to display an advertisement to a specific audience or demographic segment, and you interact with that advertisement, the advertiser or ad server may infer that you belong to the targeted audience.

You should consult the respective privacy policies of these third-party ad servers or ad networks. Toffee Rewards’ Privacy Policy does not apply to, and we cannot control the activities of, such other advertisers or websites.

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HOW WE USE YOUR INFORMATION 

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In general, we collect information to provide our Services, operate our business, and deliver information you request. This includes the following purposes and uses:

• Account Management

  • Create and manage your account.

• Service Operations

  • Provide, operate, enhance, maintain, and protect our Services, including the Toffee Rewards Program.

  • Ensure the safety and security of the Services.

• Support and Communication

  • Provide technical and customer support.

  • Send updates, marketing communications, service-related information, and details about Toffee Rewards and third-party products or services you may find relevant.

  • Respond to your inquiries and communicate with you.

  • Send push notifications through our app.

• Customization and Personalization

  • Tailor the content, products, features, and marketing offers provided through the Services.

  • Personalize your experience, such as customizing the content you see.

• Transaction Processing

  • Process, fulfill, and follow up on transactions and requests for products, services, support, and information.

• Research and Analysis

  • Conduct research, monitor trends, and analyze usage.

  • Enhance and improve user experience, business operations, and the Services.

• Legal Compliance and Enforcement

  • Comply with applicable laws, regulations, subpoenas, legal processes, or governmental requests.

  • Enforce our Terms of Service and investigate potential violations.

  • We may collect and disclose your personal information to comply with legal obligations, including those under the Bank Secrecy Act, anti-money laundering laws, and other applicable regulations.

• Fraud and Security

  • Detect, prevent, and address fraud, security breaches, or technical issues.

  • Protect the rights, property, and safety of Toffee Rewards, our users, customers, or the public, as required or permitted by law.

• General Business Operations

  • Perform necessary functions to ensure the proper functioning of the Services and protect their security.

Toffee Rewards Program.

Toffee Rewards, along with our reward partners and payment card networks, use your information to:

• Verify whether purchases made using your Payment Method meet the criteria for qualifying transactions.

• Communicate with you regarding these purchases.

• Ensure compliance with applicable laws and regulations related to transactions conducted through the Service.

• Tailor the content, products, features, and marketing offers provided to you.

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Toffee Rewards, card networks, and Reward Partners utilize your credit or debit card information, along with transaction data, to monitor your purchases. Additionally, if you opt to have any cash back credited directly to your credit or debit card, this information will be used to process and apply the earned cash back to your designated account.

Toffee Rewards and its Reward Partners will use information related to purchases made with your enrolled card solely to facilitate your participation in the Toffee Rewards or Reward Partner programs. Specifically:

• Confirming Qualifying Purchases: Transaction data will be used to verify qualifying purchases or returns to determine eligibility for Rewards or Offers. This may involve Toffee Rewards sharing transaction-related data with Reward Partners.

• Merchant Verification: Transaction details may be shared with participating Merchants to verify specific transactions or award points. For example, Toffee Rewards or Reward Partners may share the purchase date, amount, and the last four digits of your card number to help the Merchant confirm your transaction if it is missing or disputed.

• Aggregated Data for Campaigns: Aggregated and anonymized transaction data may be provided to participating Merchants or manufacturers to help them evaluate the performance of their campaigns.

• Record Keeping: Toffee Rewards or Reward Partners may create and maintain records of transaction data for the operation of the Toffee Rewards program.

• Program Optimization: Data may be analyzed to enhance and optimize the Toffee Rewards program.

• Compliance and Legal Requests: Toffee Rewards, Reward Partners, or Card Networks may share information as required to comply with requests from government authorities or payment organizations involved in transactions between you and a Merchant.

• Purchase Details: Information about your purchases, such as item descriptions, quantities, purchase time, total cost, and the store location, may be collected. If you submit a receipt to redeem an offer, any details from that receipt, including items purchased, prices paid, and payment methods, may also be collected.

• Interaction Data: Information about how you use the Services—such as the offers you view or redeem, the products you purchase, and the stores you frequent—may be collected, along with details about your interactions with Merchants, business partners, and service providers.

By participating, you authorize the collection, sharing, and use of your transaction data as described above by Toffee Rewards, its Reward Partners, applicable card networks, and participating Merchants.

Toffee Rewards will automatically share details about any loyalty or rewards benefits based on the specific rules of the participating Merchant’s loyalty or rewards program. This information is shared exclusively with the Merchant or issuer that owns or manages the program. The use of your information is determined by the policies of the Merchant or issuer operating the loyalty or rewards program. Please review their terms and conditions for details on how your information is handled.

‍‍We may utilize Plaid Technologies, Inc. (“Plaid”) to monitor transactions on your Payment Method as described above. By using the Services, you authorize Plaid to act on your behalf to retrieve and transmit your personal and financial information from the applicable financial institution. You acknowledge and consent to the transfer, storage, and processing of your personal and financial data by Plaid in accordance with the Plaid Privacy Policy.

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HOW WE SHARE YOUR INFORMATION

We do not sell your personal information. However, like many businesses, we may share information with third parties under specific circumstances as part of operating our Services and conducting our business. Below is an explanation of when this occurs:

• Toffee Rewards Program
  If you participate in the Toffee Rewards Program, your information may be shared with Toffee Rewards Partners, relevant Card Networks, and participating Merchants, as outlined in the “Toffee Rewards Program” subsection of the “HOW WE USE INFORMATION” section above.

We may share your transaction and account data with card networks, participating merchants, and licensed money transmitters for operational purposes, such as qualifying transactions, processing cash-out requests, and enabling compliance with applicable regulations. This sharing is essential for the proper operation of the Toffee Rewards Program and related services.

• ‍Service Providers
  We engage third-party service providers to support our business operations and the delivery of our Services. These include technology vendors that maintain our platform and partners who assist with marketing and communications. These service providers may access your information to perform their duties. Additionally, if you make a purchase through our Services, your information will be shared with third-party payment processors to complete the transaction.

• As Directed By You and With Your Consent
  Except as otherwise outlined in this Policy, we only share your information with external companies, organizations, or individuals when you direct us to do so or when we have your explicit consent.

• Legal Proceedings
  We may disclose your information to third-party entities, government authorities, or individuals outside Toffee Rewards if we believe in good faith that it is necessary to:

• Comply with applicable laws, regulations, subpoenas, legal processes, or government requests;

• Enforce contracts, including our Terms of Service, and investigate potential violations;

• Detect, prevent, or address fraud, security concerns, or technical issues; or

• Protect the rights, property, or safety of Toffee Rewards, our users, customers, or the public as required or allowed by law.

Our Services may include links to third-party websites or applications. Toffee is not responsible for the privacy practices of these third-party entities. We encourage you to review their privacy policies before providing any personal information to such entities.

• Sale or Merger
  If Toffee Rewards or one of its affiliates undergoes a merger, acquisition, asset sale, financing, liquidation, or bankruptcy, we may share your information with the involved company before and after the transaction is finalized. Unless otherwise directed by applicable law, your information will continue to be governed by the privacy policy in effect at the time of the transfer.

• De-Identified and Aggregate Data
  We may de-identify or aggregate your data to ensure it no longer identifies you as an individual. Such data may be shared with third parties without restrictions. We may also share aggregate usage statistics with third parties or allow them to collect this information directly to understand how users engage with our Services. However, we will not disclose aggregate or de-identified data in a way that could identify you personally.

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CHOICES ABOUT YOUR INFORMATION

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We aim to give you control over your information. You can choose not to provide certain details to us; however, some information may be necessary to create a Toffee Rewards account or use certain features of our Services.

Updating and Accessing Your Information
Most of your information can be accessed and updated directly through our app. If you need to modify or access additional details not available in the app, you can reach us at support@toffeecash.com. We may require verification of your identity or additional details before processing your request. Requests may be denied for various reasons, such as suspected fraud or if certain information must be retained for legal or record-keeping purposes.
It is your responsibility to ensure that your account information is accurate and up-to-date. Failure to provide accurate or current information may result in account suspension or termination, as outlined in the Terms of Use.

Deleting Your Information or Account
You can delete most of your information or your account directly through our app. Alternatively, you can request account deletion by contacting us at support@toffeecash.com. Please note that some information may be retained for legal, regulatory, or operational purposes even after deletion. If deletion is restricted, we will notify you. We may continue to use aggregated or de-identified data derived from your information after deletion, but only in a way that does not personally identify you.
Upon requesting account deletion, we will process your request within 30 days. However, we may retain certain information to fulfill legal or regulatory obligations or resolve outstanding issues such as pending rewards or account balances.

Marketing Communications
You can opt out of receiving Toffee Rewards marketing emails at any time by clicking the "unsubscribe" link in any email.

Messages
To stop receiving messages from us, email support@toffeecash.com and write  STOP, END, CANCEL, UNSUBSCRIBE, or QUIT contacting. You may receive a confirmation email to verify your opt-out request.

Additional Financial Disclosures

By using our Service, you authorize Toffee Rewards to act on your behalf to retrieve and transmit your personal and financial information from the relevant financial institution. You also grant Toffee Rewards permission to share your identity and account details with third parties as needed to establish and maintain your accounts with them. You are solely responsible for ensuring the accuracy and completeness of the information you provide.

Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal data by Galactica Games to third parties for those third parties’ direct marketing purposes. To make a request to opt out of such disclosure, please use the Menu section of the App or the FAQ section of a Website.The California Consumer Privacy Act (“CCPA”) also provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to access and control Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a federal privacy law, such as the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed
Please see our Notice of California Consumer Data Collection and Sharing Practices included in our Privacy Policy.

Right to Access Information
You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we will verify your identity before we can act on your request by seeking information which may include: (i) device ID; (ii) your player identification name and/or number; (iii) name; (iv) confirmation of California residency; (v) physical address and/or (vi) email.

Right to Request Deletion of Information
You have the right to request, in certain circumstances, that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we will verify your identity before we can act on your request by seeking information which may include: (i) device ID; (ii) your player identification name and/or number; (iii) name; (iv) confirmation of California residency; (v) physical address and/or (vi) email. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to Information Regarding Participation in Data Sharing for Financial Incentives
We run promotions from time to time whereby we incentivize a consumer to share certain pieces of information with us; for example, certain games offer “Reward Videos” where players can earn virtual goods and/or game credits by watching targeted advertisements. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.

Right to Opt out of Sale of Personal Information to Third Parties
You have the right to opt out of any sale of your personal information to third parties. To exercise this right, please visit the “Do Not Sell My Personal Information” webpage if you are using a Website or the Menu section of an App. Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.

Right to Non-Discrimination
You have the right to receive non-discriminatory treatment based on your exercise of any of the privacy rights conferred by the CCPA.

How to Submit a Request
You may submit a request by contacting us at support@toffeecash.com or through the menu options in the App or Website, if available.

Notice of California Consumer Data Collection and Sharing Practices
The following is a description of our data collection practices, including the personal information we collect, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties. We may use any and all of the information for any of the purposes described in our Privacy Policy, unless limitations are listed. The categories we use to describe the information are those enumerated in the CCPA.· 

Personal Identifiers:· We collect your name, email address, phone number, and contact address when you create an account or complete a transaction.
If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile.
You provide us with payment information, which may be your credit card number or a bank account, when you complete a transaction. You have the option to store this information to your account. We do not collect your Driver’s Licence or passport number. We do not collect any medical information or health information about you. We collect your social security number only if you are a player of Galactica Games and choose to withdraw money that you have won, in order to comply with tax law. We may request additional information or use third party platforms in respect of AML or KYC obligations. We collect your IP address automatically when you use our Services and we will collect your IP address at the time you seek to withdraw any funds. We collect your Device ID automatically when you use our Services.

Protected Classifications: We collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors. We do not collect your racial or ethnic origin, or sexual orientation.

Commercial Information: When you engage in transactions with us, we create records of purchases made or considered, as well as purchasing histories or tendencies. We also create records of your play preferences and information about gameplay.

Biometric Information: We do not collect information about your physiological, biological, or behavioural characteristics.

Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, and information regarding your interaction with websites, applications, or advertisements automatically when you utilise our Services.

Geolocation Data: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on the IP address. We do not collect your precise location (e.g., your GPS coordinates) unless you play for cash on Galactica Games. If we collect your precise location, when you use the Services for the first time, we ask for your permission to collect your precise location (e.g., your GPS coordinates). If you allow your device to provide us with this information, we use it to make improvements to our products and services, and to provide recommendations and deliver relevant advertising.

Audio, electronic, visual, thermal, olfactory, or similar information: We do not collect your image, voice recording, or any thermal, olfactory, or similar information.

Professional or employment-related information: We do not collect information about your current employer or your employment history.

Education information: We do not collect any information about the institutions you have attended or the level of education you have attained.

Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyse your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile. We share the above-listed information with service providers, which are external parties that we engage for business purposes and are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of service providers with whom we share information and the services they provide are described in this Privacy Policy. On certain occasions, we also sell information to third parties. An external party may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes. To “sell” information means to disclose it to an external party for monetary or other benefit.
We sell the following information:·
Personal Identifiers: We provide your IP address and Device ID to our advertising partners. Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We provide our observations about you to our advertising partners. We may also disclose information to other external parties who are not listed here when required by law or to protect Galactica Games or other persons, as described in our Privacy Policy.

‍Notice to Residents of the EU and the UK
If you are located in the EU or the UK, you have certain rights with respect to your personal data. If you would like to exercise those rights, please contact us at support@toffeecash.com or through the menu options in the App or Website, if available.

Legal Basis for Processing
We will rely on the following legal bases for processing your personal data, in accordance with the General Data Protection Regulation (GDPR), the UK GDPR, and the Data Protection Act 2018 (DPA 2018), depending on the purpose of such processing (together “GDPR”).

You have consented to the processing of your personal data: We will obtain your consent before using or sharing your data for advertising that is targeted based on your browsing history, online behaviour or other personal data that we or third parties may have collected about you. If you consent to our use of your personal data for any purpose, you have the right to withdraw consent at any time by contacting us, as explained above.

We have a legitimate interest in processing your personal data:
Toffee has a legitimate interest in processing your personal data for certain business and security purposes and to comply with applicable laws, including, but not limited to, the following:·

• Product and Service development, management, delivery and enhancement;· 

• Fraud detection and prevention;·

• Network and system security;·

• General corporate operations;

• User personalization;· 

• Compliance with applicable foreign laws;· 

• Communications regarding your purchases; and· 

• Non-targeted marketing and advertising.

You have the right to object to our processing of your personal data based on our legitimate interests. You can do so by contacting us through the Website or App you are using, as described above. The processing of some types of personal data is necessary to provide you the Services. Therefore, if you object to certain types of processing, we may not be able to provide you the Services.

Processing is necessary for compliance with a legal obligation:
We will process personal data when necessary to comply with an obligation under UK, EU, or EU Member State law. If we intend to use personal data that we have collected for a different purpose than was described to you, we will provide you with information about this secondary purpose and any additional information necessary to ensure fair and transparent processing, before we engage in further processing.

Rights of Individuals Located in the EU or UK
If you are located in the EU and UK, you have the following rights, subject to applicable exceptions, under the GDPR and UK data protection laws:

Right of access:
You have the right to obtain confirmation as to whether we are processing personal data about you, and if so, request a copy of the personal data. If you are located in the EU or UK and you would like a copy of the personal data that Toffee holds about you, please send a description of the personal data you would like a copy of and proof of your identity to the emails set forth within.

Right to correction:
You have the right to correct any inaccuracies in the personal data we hold about you and, where applicable, complete any incomplete personal data that we hold.

Right to erasure: You have the right to request that Toffee erase the personal data that we hold about you, if one of the conditions in Article 17 of the GDPR applies.

Right to restriction of processing:
You have the right to restrict our processing of your personal data, if one of the conditions in Article 18 of the GDPR applies.

Right to data portability:
You have the right to receive personal data concerning you in a structured, common and machine-readable format or request transmission of the data to a third party, if the conditions in Article 20 of the GDPR are met.
Right to object:
You have the right to object to processing of your personal data based on our legitimate interests at any time. We will no longer process the data, unless there are compelling legitimate grounds for our processing that override the interests, rights and freedoms of the data subject, or the processing serves the purpose of asserting, exercising or defending legal claims.

Right to withdraw consent:
If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.If you are located in the EU or UK and you would like to invoke any of these rights (other than “access,” which is explained above), you can make the appropriate change through your Toffee Account, or you can contact us as described above.

Lodging a Complaint
Under Article 77 of the GDPR, if you are located in the EU or the UK, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes your rights under the GDPR. The right to lodge a complaint may be invoked in the EU Member State in which you reside, in which you work or where the alleged infringement occurred.

How You Can Contact Us
Toffee is dedicated to protecting your personal data and welcomes comments and questions on this Privacy Policy. You may e-mail us at the following address: support@toffeecash.com

CHILDREN
Our Services are not directed at children under 13, and we do not knowingly collect information from children under 13. If you are under 13, please do not attempt to use our Services or send any information about yourself to us.  
Users must not upload or share content that includes images or data of minors under the age of 13. Any such violations are prohibited and may result in account suspension or termination, as outlined in the Terms of Use.

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SECURITY OF YOUR INFORMATION
We implement reasonable security measures to protect your information from unauthorized or unlawful processing, as well as accidental loss, destruction, or damage. Additionally, we take steps to enhance the security of our Services. However, because the Internet is not completely secure, we cannot guarantee or ensure the absolute security of any information you share with us. There is always a risk that your data could be accessed, disclosed, altered, or destroyed due to a breach of our physical, technical, or managerial safeguards. You are responsible for safeguarding your login credentials to help protect your account. 
Users are responsible for maintaining the confidentiality of their account credentials, including passwords. If you suspect unauthorized access or use of your account, you must promptly update your credentials and notify us immediately to prevent further unauthorized actions.

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INTERNATIONAL TRANSFER

Our operations are based in the United States, where our Services are also hosted. If you access our Services from outside the United States, please be aware that the data protection laws applicable to our collection and use of information may differ from those in your country. By choosing to use our Services or share your information with us, you consent to the application of U.S. laws and the transfer of your information to the United States.
For users located in the United Kingdom or the European Union, as described above, we process your personal data in compliance with the GDPR.

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THIRD PARTY WEBSITES AND SERVICES

‍Our Services may include links to external websites or services operated by third parties, as well as social media features, such as buttons or embedded links. If you click on these links or interact with these features, third-party websites or services may collect information about you. Social media platforms may also track your browsing activity when you visit websites that include their buttons or features. Your use of these third-party websites and interactions with their features are subject to their respective privacy policies, not this one.  

CHANGES TO THIS POLICY

We may update this Policy periodically and will publish the revised version on this page. We recommend reviewing this page each time you use our Services to stay informed about any modifications. By continuing to use our Services after changes are made, you acknowledge and accept the updated Policy. Unless otherwise specified, updates to this Policy will become effective as of the date they are posted. 

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CONTACT US

If you have any comments, questions, concerns, or suggestions about Policy, or about our privacy practices in general, please contact us at  support@toffeecash.com.

‍Last Updated: 18th of December, 2024