PRIVACY POLICY

Effective Date: January 5, 2025

This "Privacy Policy" applies to the Websites controlled by Da Vinci Entertainment Holdings LLC and/or its subsidiary and affiliated entities ("us", "we", or "our") where the Privacy Policy is posted. "Websites" include sites hosted by one or more web servers (however accessed and/or used, whether via personal computers, mobile devices or otherwise (collectively, "Computer")) and other interactive features, applications or downloads that are operated by us and that are available through, or interact with, Websites where this Privacy Policy is posted. This Privacy Policy does not apply to our collection of information from other sources (unless specifically stated).

We have adopted this Privacy Policy to explain what information may be collected on our Websites, how we use this information and under what circumstances we may disclose the information to third parties. This Privacy Policy, together with the Terms of Use posted on our Websites, sets forth the general rules and policies governing your use of our Websites. Depending on your activities when visiting our Websites, you may be required to agree to additional terms and conditions.

We generally keep this Privacy Policy posted on our Websites and you should review it frequently, as we reserve the right to change it from time to time without prior notice to you. Any changes will be effective immediately upon posting of the revised Privacy Policy. We will not use your personally identifiable information, however, in a manner materially different than what was stated at the time it was collected without your consent. WHEN YOU ACCESS OUR WEBSITES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP ACCESSING OUR WEBSITES.

A. INFORMATION WE COLLECT

Our Websites typically collect two (2) kinds of information about you: (a) information that you provide that personally identifies you; and (b) information that does not personally identify you that we automatically collect when you visit our Websites or that you provide us.

1. Personally Identifiable Information:
Our definition of personally identifiable information includes any information that may be used to specifically identify or contact you, such as your name, mail address, phone number, etc. As a general policy, we do not automatically collect your personally identifiable information when you visit our Websites. In certain circumstances, we may request, allow or otherwise provide you an opportunity to submit your personally identifiable information in connection with a feature, program, promotion or some other aspect of our Websites. For instance, you may: (a) provide your name, mail/shipping address, e-mail address, credit card number and phone number when registering with our Websites, using our online store or in connection with a contest entry; (b) provide certain demographic information about you (e.g., age, gender, purchase preference, usage frequency, etc.) when participating in a survey, poll or joining a club; or (c) post a product rating and recommendation on our Websites. Certain information may not be personally identifiable when standing alone (e.g., your age), but may become so when combined with other information (e.g., your age and name). Whether or not you provide this information is your choice; however, in many instances, this type of information is required to participate in the particular activity, realize a benefit we may offer or gain access to certain content on our Websites.

2. Non-Personal Information:
Our definition of non-personal information is any information that does not personally identify you. Non-personal information can include certain personally identifiable information that has been de-identified; that is, information that has been rendered anonymous. We and/or our third party service providers obtain non-personal information about you from information that you provide us, either separately or together with your personally identifiable information. We and/or our third party service providers also automatically collect certain non-personal information from you when you access our Websites.

B. HOW WE USE & SHARE THE INFORMATION COLLECTED

1. Personally Identifiable Information:
The personally identifiable information you submit to us is generally used to carry out your requests, respond to your inquiries, better serve you, or in other ways naturally associated with the circumstances in which you provided the information. We may also use this information to:

• Provide you with information or services or process transactions you have requested or agreed to receive.
• Provide you with marketing or promotional information for our products or those of our affiliated companies.
• Communicate with you about content or other information you have posted or shared with us via our Websites.
• Send you updates about changes to the Websites and/or Website policies.
• For internal business purposes, or for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

You may opt-out from receiving future promotional information from us, or direct that we not share your information in the future with any affiliated companies or third parties for their direct marketing purposes, as set forth below in Section I.

We do not sell your personally identifiable information to unrelated third parties for monetary or other valuable consideration. In certain instances, however, we may share your personally identifiable information with:

• Third-party vendors performing functions on our behalf (or on behalf of our affiliated companies), such as processing credit card orders, delivering merchandise, administering promotions, providing marketing or promotional assistance, analyzing data, or assisting with customer service. These vendors agree to use this information solely to carry out our requests.
• Participating sponsors to a program or promotion (e.g., a sweepstakes or contest) you enter via our Websites.
• Third parties who assist us in using the content or other information you have posted or shared with us via our Websites (e.g., production companies we may use).
• Co-promotional partners and others with whom we have marketing or other relationships.

If we ever decide to sell (or reorganize) our business, merge it with another, or engage in a similar business transaction, personally identifiable information may be transferred as part of that transaction, consistent with Section C.2. below.

2. Non-Personal Information:
In addition to any personally identifiable information or other information that you choose to provide to us on the Websites, we and our third-party service providers may use a variety of technologies, now and hereafter devised, that automatically collect certain website usage information whenever you visit or interact with the Websites. This information may include browser type, operating system, the page served, the time, the source of the request, the preceding page view, and other similar information. We may use this usage information for a variety of purposes, including to enhance or otherwise improve the Websites. In addition, we may also collect your IP address or some other unique identifier for the particular device you use to access the Internet, as applicable (collectively, referred to herein as a "Device Identifier").

When analyzed, usage information helps us determine how our Websites are used, such as what types of visitors arrive at the Websites, what type of content is most popular, what type of content you may find most relevant, and what type of visitors are interested in particular kinds of content and advertising. We may associate your Device Identifier or website usage information with the personally identifiable information you provide, but we will treat the combined information as personally identifiable information.

Website usage information may be collected using methods such as:

• Web Beacons – Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs").
• Cookies – Data files placed on a Computer when it is used to visit the Websites.
• Mobile Device Identifiers – Certain mobile service providers uniquely identify mobile devices, and we or our third-party service providers may receive such device information if you access the Websites through mobile devices.
• Embedded Scripts – Programming code designed to collect information about your interactions with the Websites.

Information collected through passive means may be non-identifying or may be associated with you. In the latter case, it will be treated as personally identifiable information.

We use non-personal information in a variety of ways, including to help analyze site traffic, understand customer needs and trends, carry out targeted promotional activities, and improve our services. We may use your non-personal information by itself or aggregate it with information we have obtained from others. We may share your non-personal information with our affiliated companies and third parties to achieve these objectives and others, but remember that aggregate information is anonymous information that does not personally identify you. We may provide our analysis and certain non-personal information to third parties (who may, in turn, use this information to provide advertisements tailored to your interests), but this will not involve disclosing any of your personally identifiable information.

3. Information You Provide About A Third Party
If you send someone else a communication from the Websites, such as sending Website content to a friend, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Websites, your e-mail address may be included in the communication sent to your friend.

4. Information Third Parties Provide About You
We also may, from time to time, supplement the information we collect with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you, and to offer you opportunities to purchase products or services that we believe may be of interest to you. We may combine the information we receive from those other sources with information we collect through the Websites. In those cases, we will apply this Privacy Policy to any personal identifiable information received, unless otherwise specifically disclosed by us at the time you provide your personally identifiable information.

C. OTHER USES

1. E-mail Communications:
If you send us an e-mail with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personally identifiable information, such as passwords, social security numbers or bank account information, to us by e-mail. Further, we may send you e-mail under the following circumstances:

• If you request a particular service or sign up for a feature that involves e-mail communications;
• If it relates to purchases you have made with us (e.g., product updates, customer support, etc.);
• If we are sending you information about our other products and services;
• If you consented to being contacted by e-mail for a particular purpose;
• If you send us an e-mail, post information on the Websites (i.e., a blog) or otherwise submit information to us electronically, we may e-mail you to follow-up or otherwise communicate with you with respect thereto;
• To provide you legal notices or notices with respect to your use of the Websites; or
• To otherwise facilitate a transaction between us.

In certain instances, we may provide you with tools on the Websites that will allow you to set your preferences for receiving e-mail communications from us; that is, agree to some communications but not others. You may "opt out" of receiving future commercial e-mail communications from us by clicking the "unsubscribe" link or following the other instructions included at the bottom of most e-mails we send, or as provided below in Section I; provided, however, we reserve the right to send you transactional e-mails such as customer service communications.

2. Transfer of Assets:
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all (or substantially all) of our assets (including by way of merger or other business combination), the personally identifiable information and non-personal information we have about you will be transferred to and used by this acquiring entity, though we will take reasonable steps to ensure that your preferences are followed. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties. In every scenario, we will make reasonable efforts to ensure your information remains protected and is used in accordance with this Privacy Policy.

3. Other:
Notwithstanding anything herein to the contrary, we reserve the right to disclose any personally identifiable or non-personal information about you if we are required to do so by law, with respect to notices and counter-notices pursuant to our DMCA notice and takedown policy and procedures and/or if we believe that such action is necessary to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Websites, or other users; or (d) in an emergency to protect the health and safety of our Websites’ users or the general public.

4. Sweepstakes Contests and Promotions:
We may offer sweepstakes, contests, and other promotions through the Websites that may require registration. By entering any promotion, you are agreeing to the official rules that govern that promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion. If you choose to enter a sweepstakes, contest or other promotion, personally identifiable information may be disclosed to third parties or the public in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the promotion’s official rules, such as on a winners list.

5. Your California Privacy Rights:
(a) Residents of the State of California, under certain provisions of the California Civil Code, have the right to request from companies conducting business in California a list of all third parties to which the company has disclosed certain personally identifiable information as defined under California law during the preceding year for third party direct marketing purposes. You are limited to one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response. You may request the information in writing as provided in Section I.

(b) How We Respond to Browser "Do Not Track" Signals: Some web browsers incorporate a "Do Not Track" feature that signals to Websites that you visit that you do not want to have your online activity tracked. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to "Do Not Track" signals. How browsers communicate the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed. For this reason, we do not respond to Do Not Track signals currently, and we await the result of work by the policy community and industry to determine when such a response is appropriate and what form it should take. We do, however, provide a means for opting out of targeted advertising on our Websites. The effect of an opt-out will be to stop targeted advertising, but it will still allow the collection of usage data for certain purposes (e.g. research, analytics, and internal online services operation purposes).

6. Third Party Ad Server Networks:
The Websites may use third parties such as network advertisers to serve advertisements on the Websites and may use traffic measurement services to analyze traffic on the Websites. Network advertisers are third parties that display advertisements based on your visits to the Websites and other websites you have visited. Third-party ad serving enables us to target advertisements to you for products and services in which you might be interested. The Websites’ third party ad network providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies and other technologies on your Computer and track certain behavioral information regarding users of your Computer via a Device Identifier. These third party cookies and other technologies may be used to help deliver advertisements to you that you might be interested in, prevent you from seeing the same advertisements too many times, and understand the usefulness to you of the advertisements that have been delivered. Third party cookies, web beacons, and other third party technologies are governed by each third party’s specific privacy policy, not this one.

D. PUBLIC FORUMS

We may offer chat rooms, message boards, bulletin boards or similar public forums where you and other users of our Websites can communicate. The protections described in this Privacy Policy do not apply when you provide information (including personally identifiable information) in connection with your use of these public forums. We may use personally identifiable and non-personal information about you to identify you with a posting in a public forum. Any information you share in a public forum is public information and may be seen or collected by anyone, including third parties that do not adhere to our Privacy Policy. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Websites.

E. CHILDREN

The features, programs, promotions and other aspects of our Websites requiring personally identifiable information are not intended for children. We do not knowingly collect personally identifiable information from children under the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed personally identifiable information to us, please contact us at oscar@dt2k.com. A parent or guardian of a child under the age of thirteen (13) may review and request deletion of such child’s personally identifiable information as well as prohibit the use thereof.

F. KEEPING YOUR INFORMATION SECURE

We have implemented security measures we consider reasonable and appropriate to protect against the loss, misuse and alteration of the information under our control. Please be advised, however, that while we strive to protect your personally identifiable information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction or inadvertent disclosure of your personally identifiable information. In the unfortunate event that your "personally identifiable information" (as the term or similar terms are defined by any applicable law requiring notice upon a security breach) is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances. Delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system, as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation. From time to time, we evaluate new technology for protecting information, and when appropriate, we upgrade our information security systems.

G. OTHER SITES/LINKS

Our Websites may link to or contain links to other third-party websites that we do not control or maintain, such as in connection with purchasing products referenced on our Websites and banner advertisements. We are not responsible for the privacy practices employed by any third-party website. We encourage you to note when you leave our Websites and to read the privacy statements of all third-party websites before submitting any personally identifiable information.

H. THIRD PARTY APPLICATIONS

Third party applications may be available via the Websites. The owners of these applications ("Third Party Owners") may collect personally identifiable information from you and may have their own policies and practices. We are not responsible for how Third Party Owners or their applications use your personally identifiable information. These Third Party Owners may have their own terms of service, privacy policies, or other policies and ask you to agree to the same. We are not responsible for these policies or the practices of Third Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third party application or otherwise interacting with it.

I. CONTACT & OPT-OUT INFORMATION

The Websites may include subscription and registration management tools that allow you to make changes regarding your preferences for receiving communications. Regardless of whether these tools are available through the Websites, you may contact us at oscar@dt2k.com if:

• (a) you have questions or comments about our Privacy Policy;
• (b) wish to make corrections to any personally identifiable information you have provided to us;
• (c) want to opt-out from receiving future commercial correspondence, including e-mails, from us (we may continue to send you transactional messages such as responding to your inquiries); or
• (d) wish to withdraw your consent to our future sharing of your personally identifiable information with third parties for their direct marketing purposes.

We will respond to your request and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfill certain requests while allowing you access to certain benefits and features of our Websites. Also, please note that it is not always possible to completely change, remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. Also, if you have made any public postings on the Websites such as in forums or blogs, these communications are generally not removed by us.

J. YOUR RIGHTS UNDER THE GDPR (EU & UK USERS)

If you are located in the European Economic Area (EEA) or the United Kingdom, you may have the following data protection rights regarding your personal data:

• Right to Access: You have the right to request copies of your personal data.
• Right to Rectification: You have the right to request that we correct any information you believe is inaccurate and to complete any information you believe is incomplete.
• Right to Erasure (Right to be Forgotten): You have the right to request that we erase your personal data under certain conditions.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
• Right to Object to Processing: You have the right to object to our processing of your personal data, under certain conditions.
• Right to Data Portability: You have the right to request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.
• Right to Withdraw Consent: Where we rely on your consent to process your personal data, you have the right to withdraw consent at any time.

To exercise any of these rights, or if you have any questions relating to the processing of your personal data, please contact us at oscar@dt2k.com. We will consider and respond to your request in accordance with applicable laws. You also have the right to lodge a complaint with your local supervisory authority if you believe that we have not complied with applicable data protection laws.

K. CONSENT TO TRANSFER INFORMATION TO THE UNITED STATES

The Websites are operated in the United States and intended primarily for users located in the United States. If you are located in the EEA, UK, Canada, or elsewhere outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the Websites or providing us with any information, you consent to this transfer and processing of your information in the United States, subject to this Privacy Policy and applicable data protection regulations.

L. SOLE STATEMENT

This Privacy Policy as posted is the sole statement of our privacy policy with respect to the Websites, and no summary, modification, restatement or other version thereof or other privacy statement or policy, in any form, is valid unless we post a new or revised policy to the Websites.

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