Privacy Policy
Sweetspot Marketing Group Ltd. (“Sweetspot,” “we,” “us,” or the “Operator”) respects your privacy and is committed to protecting the personal information collected through THE GAME — Are You Worthy?, our website, screening process, registration systems, communications and Game activities.
This Privacy Policy explains what personal information we collect, why we collect it, how we use and disclose it, how long we retain it, and the choices and rights available to you.
This policy applies to visitors to worthychallenge.com, applicants, screening participants, Accepted Players, Team Captains and other individuals who interact with THE GAME.
1. Personal Information We May Collect
Depending on how you interact with THE GAME, we may collect the following types of personal information:
Contact and Registration Information
This may include:
- name;
- email address;
- telephone number;
- age or date-of-birth information where required for eligibility;
- city or residency information;
- Player ID or account information;
- Team selection or participation status; and
- other information submitted during registration.
Screening and Eligibility Information
If you apply to participate in THE GAME, we may collect information reasonably required to evaluate eligibility, administer screening and determine whether an applicant may continue into THE GAME. This may include:
- screening responses;
- application information;
- eligibility confirmations;
- recorded video or audio screening sessions;
- communications with the Game Team; and
- information reasonably required for identity, age, eligibility or safety verification.
Screening recordings and screening-related information are also subject to the applicable Screening Terms and notices provided during the screening process.
Payment and Transaction Information
When you make a payment relating to screening, Game entry, a Milestone or another authorized Game transaction, payment information may be processed by a third-party payment processor. We may receive and retain transaction information such as:
- amount paid;
- transaction date;
- payment status;
- entry type;
- Invite Code or discount used;
- refund, reversal or chargeback status; and
- transaction identifiers.
Full payment-card information is generally handled by the applicable payment processor rather than directly by Sweetspot.
Game Participation Information
If you participate in THE GAME, we may collect information required to administer and verify your participation, including:
- Team and Captain status;
- Round and Milestone progress;
- completion times and deadlines;
- submissions and supporting evidence;
- Game Credit activity and ledger records;
- advancement and elimination status;
- Prize preferences;
- Prize eligibility and fulfillment information;
- Completion Reward eligibility;
- rule-compliance information; and
- records relating to disputes, investigations or disciplinary decisions.
Recordings, Photographs and Game Media
Certain Game activities may involve video recordings, audio recordings, photographs or other media. Where recording, filming, publicity use, location tracking or similar collection is not already covered by the Screening Terms or this Privacy Policy, appropriate notice or consent will be provided where required.
Communications
We may retain communications you send to or receive from THE GAME, including email, text messages, support requests, payment communications and other Game-related correspondence.
Website and Technical Information
When you visit our website or use our online systems, certain information may be collected automatically, including:
- IP address;
- browser and device information;
- approximate location derived from an IP address;
- referring pages;
- pages viewed;
- dates and times of visits;
- website interactions; and
- cookie or similar technology information.
We do not use ordinary website access to collect precise device location unless a particular Game activity separately requires it and appropriate notice or consent is provided.
2. Why We Collect and Use Personal Information
We collect and use personal information only for reasonable purposes connected with THE GAME and our business operations. These purposes may include:
- responding to inquiries;
- processing screening applications;
- determining eligibility;
- registering and identifying Players;
- processing payments;
- administering Complimentary Entries and discounts;
- forming and administering Teams;
- communicating Game instructions;
- administering Rounds and Milestones;
- verifying submissions and completion;
- maintaining Game Credit records;
- determining advancement and Prize eligibility;
- administering Completion Rewards;
- preventing cheating, fraud, duplicate accounts and payment manipulation;
- protecting Players, Sponsors, staff and the integrity of THE GAME;
- responding to disputes and chargebacks;
- fulfilling prizes;
- maintaining accounting and tax records;
- meeting legal and regulatory requirements;
- improving our website and Game administration systems; and
- sending promotional communications where permitted by law and applicable consent.
We will not use personal information for a materially different purpose without appropriate authority or consent where consent is required.
3. Consent
Where required, we obtain consent for the collection, use or disclosure of personal information.
Consent may be provided electronically, through a registration or screening process, by submitting information, by selecting an acceptance box, through a separate consent form, or by another method appropriate to the circumstances.
You may withdraw or modify consent where legally permitted by contacting us. Withdrawal of consent does not affect collection, use or disclosure that has already lawfully occurred.
Some information is necessary to operate THE GAME. If you withdraw consent relating to information that is reasonably required to establish eligibility, administer participation, verify results, process payments or fulfill legal obligations, we may be unable to continue providing the applicable service or permit continued participation.
4. Communications
We may contact applicants and Players about matters relating to screening, registration, payments, THE GAME, Teams, Rounds, Milestones, deadlines, prizes, Completion Rewards, support or administration.
Operational communications necessary to administer an application or participation in THE GAME may continue even where an individual chooses not to receive promotional marketing.
Where required by law, commercial electronic messages will include the applicable identification and unsubscribe information.
5. How We May Disclose Personal Information
We may disclose personal information where reasonably necessary for the purposes described in this Policy.
Service Providers
We may use third-party service providers to assist with services such as:
- website hosting;
- payment processing;
- email and text messaging;
- video conferencing or recording;
- application and database administration;
- analytics;
- identity or eligibility verification;
- accounting;
- information technology and security; and
- Prize administration.
Service providers are authorized to receive or process information only for purposes related to the services they provide or as otherwise permitted by law.
Sponsors and Prize Suppliers
Sponsors and Prize Suppliers do not automatically receive a Player’s personal information merely because they participate in THE GAME. We may provide personal information to a Sponsor or Prize Supplier where reasonably required to:
- verify Prize eligibility;
- arrange Prize selection or fulfillment;
- schedule an activity;
- confirm participation;
- administer a Sponsor-supported Game activity; or
- fulfill another purpose disclosed to the Player.
Information unrelated to that purpose will not be disclosed merely because an organization is a Sponsor.
Legal, Safety and Fraud Matters
We may disclose personal information where permitted or required by law, including where reasonably necessary to:
- comply with a court order, legal process or lawful government request;
- investigate fraud or payment disputes;
- protect the safety or security of a person;
- investigate serious misconduct;
- protect our legal rights; or
- enforce the Official Game Rules.
Business Transactions
If Sweetspot Marketing Group Ltd. undergoes a proposed or completed business transaction such as a sale, financing, merger, restructuring or transfer of business assets, information may be handled as permitted by applicable privacy law.
6. Processing Outside Canada
Some technology and service providers used to operate THE GAME may process or store personal information outside Canada, including in the United States.
When personal information is processed in another country, it may be subject to the laws of that jurisdiction and may be accessible to courts, governments, law-enforcement authorities or regulators in accordance with those laws.
Our service providers may process information outside Canada for purposes including payment processing, communications, hosting, video services, technical administration and related business services.
You may contact our Privacy Officer using the information below if you have questions about service providers outside Canada or the handling of your personal information.
7. Cookies and Similar Technologies
Our website may use cookies or similar technologies necessary to operate the site, understand website traffic, maintain functionality and improve the user experience.
Some third-party services integrated into the website may also use their own cookies or similar technologies.
Browser settings may allow you to block or delete certain cookies. Disabling some cookies may affect website functionality.
8. Security
We use reasonable administrative, technical and organizational measures designed to protect personal information against risks such as unauthorized access, collection, use, disclosure, copying, modification, loss or destruction.
No website, electronic transmission or storage system can be guaranteed to be completely secure.
Where a privacy incident creates circumstances requiring notification under applicable law, we will take the steps required by law.
9. Retention of Personal Information
We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and for applicable legal and business requirements.
General Player information will normally be retained for no longer than one year after the end of Season One, unless the information remains reasonably required for:
- a legal obligation;
- an active complaint or dispute;
- fraud or security investigation;
- Prize administration;
- enforcement of the Official Game Rules; or
- another legitimate business or legal purpose.
Screening recordings and related screening information are retained in accordance with the Screening Terms, applicable consent and legal requirements.
Financial, accounting, payment and tax records may be retained for the period required by applicable law. Business and supporting tax records are generally required to be retained for six years from the end of the tax year to which they relate.
When personal information is no longer reasonably required, it will be securely destroyed, deleted or anonymized as appropriate.
10. Accessing or Correcting Your Personal Information
Subject to applicable law, you may request access to personal information about you that is held by Sweetspot Marketing Group Ltd.
You may also request correction of information that is inaccurate or incomplete.
We may need to verify your identity before responding to an access or correction request. Certain information may be withheld where permitted or required by law.
Requests may be submitted to the Privacy Officer using the contact information below.
11. Information About Other People
If you provide personal information about another individual, you are responsible for ensuring that you have appropriate authority to provide that information.
Players should not submit another person’s sensitive personal information unless the applicable Game instructions specifically require it and doing so is lawful.
12. Age Requirement
THE GAME is intended only for individuals who are 18 years of age or older.
We do not knowingly accept individuals under 18 as Players.
If we determine that information has been submitted as part of a Game application by a person who is not eligible because of age, we may delete or restrict that information subject to legal and administrative requirements.
13. Third-Party Websites and Services
Our website or Game communications may contain links to third-party websites or services.
Those organizations may have their own privacy practices and policies. Sweetspot Marketing Group Ltd. is not responsible for the privacy practices of an independent third-party website or service.
We encourage users to review the applicable privacy information before providing personal information to a third party.
14. Changes to This Privacy Policy
We may update this Privacy Policy when our practices, technology or legal obligations change.
The current version will be posted on our website with the applicable effective or last-updated date.
Material changes affecting information already collected will be handled in accordance with applicable law.
15. Privacy Officer and Contact Information
Sweetspot Marketing Group Ltd. has designated a Privacy Officer responsible for questions about our privacy practices and compliance.
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Privacy Officer |
Please use “Privacy Request” in the subject line of an email relating to access, correction or another privacy matter.