PRIVACY POLICY

GAMESQUAE PRIVACY POLICY
This website is operated by GameSquare Esports (USA), Inc. and/or its affiliates (“GameSquare”). We are committed to protecting your privacy and believe that the first step in that process is your understanding of how we use your personal information.  This Privacy Policy applies to information you provide to us and information we collect through your use of GameSquare’ website, applications and services (collectively, the “GameSquare Service”).  Please take a moment to read this Privacy Policy carefully before using the GameSquare Service.  We hope this will help you make an informed decision about sharing information with us.  In addition, please review our Service Terms, which govern your use of the GameSquare Service.
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ACCEPTANCE OF PRIVACY POLICY.
By accessing or using the GameSquare Service and/or providing us with your Personal Information (defined below), you consent to the terms of this Privacy Policy and understand that we will collect, maintain, use, and disclose your Personal Information in accordance with this Privacy Policy and United States law.
If you do not agree to the terms of this Privacy Policy, do not use the GameSquare Service.  Please review this Privacy Policy frequently as we reserve the right to change the policy at any time.  For more information, please refer to the section entitled “Changes To This Privacy Policy” detailed below.  If you have any questions regarding this Privacy Policy, please contact us at support@GameSquare.com.
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SPECIAL NOTE ABOUT CHILDREN.
We do not offer the GameSquare Service to, or knowingly collect or solicit information from or about, anyone under the age of eighteen (18), unless such information is provided by their parent or legal guardian in connection with obtaining the GameSquare Service on behalf of such persons.  Accordingly, we do not knowingly collect age identifying information, nor do we knowingly collect any Personal Information from children under the age of eighteen (18). If you are under the age of eighteen (18), do not use or provide any information through the GameSquare Service or on or through any of its features, use any of the interactive or public comment features, or provide any information about yourself to us. In the event we discover that anyone under the age of eighteen (18) has provided Personal Information to us, other than by their parent or legal guardian as noted above, we will delete that person’s Personal Information from our files to the extent technologically possible.  If you believe we might have any information from or about a person under the age of eighteen (18), please send an email to: support@GameSquare.com.
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INFORMATION WE COLLECT.
Personal Information - Our primary source of information about you is the information you provide to us in connection with your registration for services that are available through the Site.  This information may be provided by you through population of forms, documents you provide us and through your communications with us, and may include your name, email address, home address, phone number and information about your family members.  For some GameSquare Services, we may ask you to provide information to document your identity, including age and gender, and employment history.  Additionally, in connection with your use of our Services, we may collect Unique identifiers, such as an Internet Protocol (IP) address, a processor or device serial number or other unique device identifiers, that are combined with other information that would permit your identification.  You may be able to limit the device information you share with us and other parties through the privacy settings on such devices.  The foregoing categories of information are referred to herein as “Personal Information.”  Our legal basis for the processing of your data is our legitimate interests in providing the Services, performing a contract with you and for the purposes of analysis and improvement of our Services.  

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General Information
In addition to collecting Personal Information about you, whenever you interact with the GameSquare Service, we and/or service providers may use a variety of technologies that automatically or passively collect information about how you access and use the GameSquare Service that does not identify you personally (“General Information”).  This includes your browser or device type, your operating system, the page served, the time, the preceding page views, and your use of features or applications on the GameSquare Service.  This statistical data provides us with information about the use of the GameSquare Service, such as how many visitors visit a specific page, how long they stay on that page, and which hyperlinks, if any, they “click” on.  This information helps us monitor and improve the GameSquare Service.
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Technologies used on the GameSquare Service to collect General Information may include, but are not limited to:
Cookies.  Cookies are data files placed on a device when it is used to access the GameSquare Service.  Either we or our third-party service providers may place cookies or similar files on your device for security purposes, to facilitate site navigation and to personalize your experience while visiting the GameSquare Service.  Cookies allow us to collect technical and navigational information, such as your browser type, time you spend on the GameSquare Service and the pages you visit.  If you would prefer not to accept cookies, you can change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; or set your browser to automatically not accept any cookies.  However, please be aware that some features of the GameSquare Service may not work properly because we may not be able to recognize and associate you with your GameSquare account.  In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.  You may learn more about cookies and how to manage them at https://www.allaboutcookies.org.  
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Pixel Tags. A pixel tag is a transparent graphic image, sometimes called a clear GIF, web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed.  In addition, a pixel tag may tell your browser to get content from another server.
Device Identifiers.  We may also automatically collect your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device you use to access the GameSquare Service.  A Device Identifier is a number that is automatically assigned to your device when you access a web site or its servers, and our computers identify your device by its Device Identifier.
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HOW WE USE THE INFORMATION WE COLLECT.
The information collected by GameSquare will be used for a variety of business purposes, including:
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• Providing the Services to you, including authenticating you when you log in, providing customer support, and operating and maintaining the Services.
• Communicating with you and fulfilling your request for products, services and information
• For billing, account management and other administrative matters
• Promoting and marketing aspects and features of the GameSquare Service to you and contacts you share with us;
• Improving the quality and design of the GameSquare Service, and to create new features and functionality, promotions and services;
• Customizing the content and information you see when you access the GameSquare Service;
• Anonymizing or aggregating your information for business purposes, including for reporting and research purposes;
• To investigate and help prevent security issues and abuse.
• Enforcing compliance with our Terms of Use;
• Complying with any applicable laws and regulations; and
• For any other purposes disclosed to you at the time your information is collected or pursuant to your consent.

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SHARING OF INFORMATION.
GameSquare is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you.  We never share information we receive from you unless: (i) we have your permission to share that information, e.g., a specific program that you can opt-into or opt-out of at any time; (ii) we have given you prior notice that the information will be shared, and with whom (such as in our Service Terms or this Privacy Policy); or (iii) the information is General Information, e.g., aggregate information or other information that does not identify you.  GameSquare may use and disclose General Information without limitation.
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Third Parties Providing Services On Our Behalf.  GameSquare may use the services of third parties in connection with the provision of GameSquare’ Services, such as companies or individuals that host or operate the GameSquare Service, analyze data or provide customer service.  To the extent that we provide paid products and/or services within Service, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the security standards set by PCI-DSS.
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Your Agreement To Have Your Personal Information Shared. While using the GameSquare Service, you may have the opportunity to opt-in to receive information from someone else or to otherwise consent to the sharing of your information with a third party. If you agree to have your Personal Information shared, the Personal Information you disclose will be subject to the privacy policy and business practices of that third party.
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Business Transfers. We may share your Personal Information with other entities and affiliates in the family of companies controlled by GameSquare for business and operational purposes. 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, or assets related to the GameSquare Service, Personal Information about you may be disclosed to such entity as part of the due diligence process and will be transferred, in whole or in part, to such entity as one of the transferred assets.  If so, we will seek to obligate the acquiring entity to use any information transferred in a manner consistent with this Privacy Policy, but cannot guarantee that it will be able to impose that requirement or that the acquiring company will comply.  Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered one of our assets and as such may be sold or transferred to third parties.
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Legal Disclosure. In addition, we may transfer and disclose information, including your Personal Information to third parties to comply with our legal obligations; when we believe that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce the GameSquare Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the GameSquare Service or the public.
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REFERRAL PROGRAMS.
We may allow you to refer friends to the GameSquare Service via email and social networking platforms. If you refer a friend by email, we will collect the name and email addresses of proposed recipients to send the email on your behalf. We may also use your name and email address in order to identify you as the initiator of the email. Please inform your friends that we may send them emails on your behalf.
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If you refer a friend via social networking platforms, you will be subject to the privacy policy and the terms and conditions of the specific social networking platform. Some social networking platforms enable functionality that allows a user to receive and transmit data to the social networking platform through use of overlays or other technology.  Although it appears the data is collected by us, the data is in fact collected directly by the social networking platform. If you decide to use this functionality, the data to be transmitted will be collected directly by the social networking platform, and we do not receive, collect or use the information. Please note your social networking account settings, as those settings will affect how and with whom your posts, information and other content are shared.
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YOUR CHOICE AND ACCESS.
You may always update your information sharing preferences through your GameSquare account or reaching out to us at support@GameSquare.com.  You may request a copy of your personal information, that we correct your information, that we limit the processing or sharing of your information or that we delete some or all of your information from our system and you acknowledge that requests to limit our use or processing of your information may limit or prevent us from providing you with the Services.  In some instances, you may also make or effectuate such requests directly in your Account.
Please note that it is not always possible to completely remove or delete all of your information from our databases without retaining some residual data because of backups and other reasons.
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SECURITY AND RETENTION OF YOUR INFORMATION.
We take information security seriously, and we use reasonable security measures to help protect against the loss, misuse or alteration of your Personal Information.  Please note, however, that we cannot ensure the security of any information you transmit to us or that we store.  Accordingly, you use the GameSquare Service and provide us with your information at your own risk.
We generally keep user data on our servers or in our archives for as long as we reasonably need it. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted to us. We are under no obligation to store your Personal Information indefinitely, and we disclaim any liability arising out of, or related to, the destruction of your Personal Information.
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CONSENT TO PROCESSING AND TRANSFER OF INFORMATION.
We operate the GameSquare Service in the United States. Our use of your information necessarily involves the transmission of data on an international basis. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the GameSquare Service, or providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen.
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DO NOT TRACK.
Some web browsers may give you the ability to enable a “do not track” setting that is an HTTP header field indicating your preferences regarding user tracking or cross-site tracking. This is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled still have the ability to accept cookies. GameSquare does not recognize web browser “do not track” signals at this time.  Instead, information collection and disclosure practices and the choices that GameSquare provides to users will continue to operate as described in this Privacy Policy, whether or not a “do not track” signal is received. For more information about “do not track,” see http://donottrack.us/.
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STATE LAW PRIVACY RIGHTS.
Subject to certain limitations, various state laws, including the California Consumer Privacy Act (“CCPA”) provide user the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.  Users, and where permitted, their agents, may make a request pursuant to their rights under the CCPA or other applicable state laws by contacting us at support@GameSquareprotect.com. We will verify your request using the information associated with your account, including email address. Government identification may be required.
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SEVERABILITY.
If any part of this Privacy Policy is held invalid or unenforceable, that portion shall be interpreted in a manner consistent with applicable law to reflect, as nearly as possible, our original intentions, and the remaining portions shall remain in full force and effect.
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CHANGES TO THIS PRIVACY POLICY.
We may change, add or delete information on the GameSquare Service and/or this Privacy Policy, at any time without prior notice to you. If we make what we determine to be material changes to this Privacy Policy, we will update the “Date Last Modified” and will notify you by posting the updated Privacy Policy on the GameSquare website and may otherwise communicate such changes to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy, and we encourage you to check back regularly for any changes, additions or deletions.  If you do not agree to the changes, your sole remedy is to cease using the GameSquare Service.
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CONTACT US.
Please contact us if you have any questions or concerns about this Privacy Policy or your experience with the GameSquare Service.  Please send an email to: support@GameSquare.com.
Date Last Modified December 29, 2023