PRIVACY POLICY

Last Updated: April 23, 2024

Telem 61 Software Inc. dba trophi.ai (“trophi.ai”, “us”, “we”, “our”) owns and operates the website located at trophi.ai  (“Website”) and provides the gaming companion, coaching, and analysis services and the trophi.ai platform (“Platform”), as described on the Website (together with Website and Platform, “Services”). This privacy policy (“Privacy Policy”) describes how we collect, use, and disclose information, including personally identifiable information about an individual (“Personal Information”), which we collect or receive via the Services. Please read the following carefully to understand our practices regarding Personal Information of users who use the Services. We may change this Privacy Policy from time to time at our sole discretion. trophi.ai may require you to provide consent to the updated Privacy Policy before further use of the Services is permitted.

1. CONSENT

By using the Services, you consent to the collection, use and disclosure of your Personal Information as described in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be collected, used, or disclosed for any other purpose without your consent.

2. PERSONAL INFORMATION YOU PROVIDE US

You may disclose Personal Information to us as follows:

(a) By creating a Services account. When you register for a Services account, we collect the following: name, email address, phone number, date of birth, and any other Personal Information requested during account creation. 

(b) By using the Services. We collect any Personal Information that you provide to us via the Services, including any Personal Information included in any content you share with us via the Services (such as gameplay or other content). 

(c) By using Third-Party Services. We may integrate with or rely on third-party platforms, offerings, and services to provide the Services to you (“Third-Party Services”). Any Personal Information submitted to us via Third-Party Services that we can access will be subject to this Privacy Policy, but please note that such Personal Information will also be subject to the terms of the applicable Third-Party Service.

(d) By contacting us. When you contact us (whether via email, the Services, or a Third-Party Service), we collect any Personal Information you choose to provide to us.

(e) By applying to work with us. If you would like to work with us and submit hiring materials to us, we collect any Personal Information you share with us in your hiring materials. If you submit hiring materials to us, we ask you to only include information relevant to the position you’re applying for, and your employment history and education, such as your resume, cover letter, transcripts, or certifications. If you are a current trophi.ai employee and would like more information about how we collect, use, and disclose your Personal Information, please contact us per Section 10 below. 

3. COOKIES AND AUTOMATIC DATA COLLECTION

When you use the Services, trophi.ai may collect certain information through technologies such as cookies and other automatic data collection technologies (“Cookies”). Please see the trophi.ai Cookie Policy for more information on how we use Cookies in connection with the Services: trophi.ai/cookie-policy.

4. HOW WE USE PERSONAL INFORMATION

We use Personal Information in the following ways:

a. To authenticate and verify you during account creation and onboarding;
b. To provide access to the Services; 
c. To provide, maintain, improve, and enhance the Services;
d. To communicate with you, provide you with updates and other information relating to the Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
e. For marketing and advertising purposes, such as providing promotional and advertising materials that may be relevant, valuable, or otherwise of interest to you, where you have subscribed to receive such materials;
f. To find and prevent fraud, and respond to trust and safety issues that may arise;
g. For compliance purposes, as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
h. For other purposes for which we provide notice at the time the Personal Information is collected.

In connection with Section 4c, we may create or use aggregated and anonymized statistical data generated from Personal Information we collect. Such statistical data is generated and used in a way that cannot identify the data subject. We may use this statistical data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

5. WHO WE SHARE YOUR INFORMATION WITH

We may share your Personal Information with our employees and with third parties, such as our affiliates, selected business partners, suppliers, and sub-contractors, while performing our contractual obligations. These third parties include web hosting partners, IT service providers, and advertisers.

We have put in place contractual and other organizational safeguards with such third parties to protect your Personal Information from unauthorized uses and disclosures. Such third parties have limited access to Personal Information solely for the purposes described herein, and they will be subject to contractual restrictions prohibiting them from using such Personal Information for any other purpose.  

In addition, we may disclose your Personal Information to third parties:

(a) In connection with a corporate re-organization, a merger or amalgamation with another entity, or a sale of all or a substantial portion of our assets or shares, including any due diligence exercise carried out in relation to the same, provided that the Personal Information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the Personal Information;

(b) If we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities; or

(c) If we believe in good faith that such disclosure is required by and in accordance with the law.

Our servers and those of third parties who may receive your Personal Information may be located outside of Canada. Accordingly, your Personal Information may be available to foreign governments or their agencies under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information.

6. THIRD PARTIES

The Services may contain links to third-party websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to the collection, use, and disclosure of your Personal Information by such third parties.

7. DATA RETENTION AND DELETION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. All retained Personal Information will remain subject to the terms of this Privacy Policy. You have the right to ask us to remove your Personal Information from our databases, and we will do so to the best of our ability, but it may not be possible to completely delete all of your Personal Information due to technological and legal constraints (for example, when your Personal Information pertains to another user of the Services).

8. ACCESS AND ACCURACY

You may access the Personal Information we hold about you to verify accuracy of your Personal Information, to have a general account of our uses of your Personal Information, and to correct your Personal Information as appropriate. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant Personal Information available to you (for example, where that Personal Information also pertains to another user of the Services). In such circumstances, we will provide reasons for the denial to you upon request. We will make every reasonable effort to keep your Personal Information accurate, and to respond to your in a timely manner.

9. SECURITY

We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff and third parties as reasonably necessary to carry out the stated purposes we have communicated to you.

10. CONTACT US

If you want to enforce any of your rights under this Privacy Policy or if you have any questions regarding this Privacy Policy or your Personal Information, please contact our Privacy Officer per the information below:

(a) Via Email: Email us at support@trophi.ai using the subject line “Re Privacy Policy”.

(b) Via Mail: Mail us correspondence to 302-34 Harvey Road, St. John's, NL, A1C 2G1.