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Kontrol Privacy Notice

Last Updated/Effective Date: 3.21.2023


This Privacy Notice (“Notice“) describes how Horizon Business Services, LLC (“Horizon Business Services”, “we”, “us”, or “our”) uses, shares, otherwise processes individually identifiable information (“Personal Information”) it collects from our website and Kontrol platform made available at Kontrol.gg, and any other Horizon Business Services service or product that specifically links this Notice (individually and collectively, the “Services”).


We reserve the right, at our discretion, to change, modify, add, or remove portions of this Notice at any time. All changes will be effective immediately upon posting to the Services. Material changes will be conspicuously posted on the Services or otherwise communicated to you through the Services. By using or accessing the Services after changes are posted, you agree to such changes.


We Collect Data You Provide


Personal Information. You may use or access the Services without submitting Personal Information. However, Personal Information is required to use certain Services features, for example, to create and maintain an account, make purchases, contact us via our Contact Us form (where we may retain your message’s content and our response), receive or request data from us, and respond to communications from us. You may also provide Personal Information as part of communications with other users of the Services, for example in our community message forums or chats. You may elect to provide Personal Information to use these features and services, such as your name, phone number, date of birth, age, address and email address. We will collect, use, and share such Personal Information pursuant to this Notice and applicable law.


Creation of an Account. In order to create an account, you must first complete the appropriate form or application. To create an account, you must provide your name, email address, phone number, date of birth or age and other information prompted upon creation. This data is used to populate a profile within your account.


Marketing Communications. If you sign-up for our promotional communications, you will need to submit your email address. We will use this information to provide you with promotional and other electronic communications. We may use third-party providers to deliver these communications to you. You may opt-out of marketing emails by contacting us at legal@HorizonBusinessServices.org. To opt-out of other communications, please contact us as set forth in the “Contact Us” section below. Opting out of marketing communications does not opt you out of other, non-marketing transactional communications from us.


Purchases; Payment Information. In order to make a transaction through the Services (e.g., to purchase content and services or to fund a prepaid account balance) or to make in-game purchases (of in-game purchases for games developed on the Kontrol platform purchased through a different platform (e.g., Steam)), you may need to provide payment data to Horizon Business Services to enable the transaction. To make a purchase using the Services, you will need to provide your name, address, email address, phone number, and credit or debit card type, number, expiration date, security code, and billing address to us. Horizon Business Services will only ever store tokenized credit card data. We will transmit your payment information to our PCI-compliant third-party payment processor, WePay, to enable the requested transaction and to perform anti-fraud checks. WePay’s processing of the payment information is subject to WePay’s privacy policies, which can be found here: https://go.wepay.com/privacy-Notice/. We will maintain a record of your purchases that you make on the Services.


Feedback. When you provide comments or feedback about the Services, the content on the Services, or our products or services (“Feedback”), we will not treat that Feedback as confidential, and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.


Data Automatically Collected


Account Activity. We may collect data about how you use your account and the Services when you are logged into your account. For example, we may track the pages you visit, and any activities you perform when you use the Services. We may combine this information with other Personal Information we have collected about you.


What types of online tracking mechanisms do we use? We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies”) on our Services.


What are cookies and web beacons / pixel tags? A cookie is a small text file that our Services saves onto your computer or device when you use the Services that provides us certain information about your activities. Cookies allows the Services to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.


Why do we collect Cookies? We use Cookies to:

• make our Services function properly;

• provide personalized experiences;

• tailor our interactions with you;

• help with our marketing efforts;

• provide us with valuable data and statistics about the usage and effectiveness of our Services and to help us improve our Services; and

• help us improve our services.


What type of information do Cookies collect? The Cookies on our Services may collect information such as:

• IP addresses assigned to the computers and other devices you use;

• your internet service provider;

• device ID number;

• approximate geographic location;

• browser type;

• Services pages visited;

• websites you access before and after visiting the Services; and

• data related to how and when you use the Services.


While we do not collect Personal Information automatically, we may tie automatically collected information to Personal Information about you that we collect from other sources or that you have previously provided to us.


How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable Services. Such Cookies are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a website that has implemented a persistent Cookie, the persistent Cookie is renewed, and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.


First and Third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual websites that you are visiting. A third-party Cookie allows your web browser to talk to a third-party websites, such as the source of an ad that appears on the websites you are visiting or a third-party analytics provider. We may not have control over how a third-party uses information collected through third-party Cookies.


How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings but disabling Cookies may impact your use and enjoyment of the Services. Not all features or functions of the Services may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Services.


California’s “Do-Not-Track” Requirement. we currently do not honor “do not track” requests.


Data from Other Sources


We may obtain data about individuals from various third-party companies and public sources, and we may combine that data with other Personal Information. This enhances our existing data about our users, improves our ability to contact you, and enhances our marketing capabilities.


How We Use Personal Information. We use Personal Information for the following purposes:


As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.


Administration. We use Personal Information for administrative purposes, such as to inform our business strategies and to understand the demographics and user preferences of the Services.


Services Management. We use Personal Information for Services management, such as troubleshooting problems, improving the content and functionality of the Services, statistical and other analyses of the Services, and to customize the Services to you and our users.


Access to the Services. We use Personal Information to create an account for the Services and allow you to access the Services as needed.


Text Messages. When you sign up for an account, we may send you a verification code via text message to the telephone number you have provided to verify that telephone number. If prompted, you may need to enter that verification code into the Services to complete the account registration process. Message and data rates may apply.


Advertising and Communications. We may use Personal Information to send you promotions or to perform targeted advertising, to notify you of new services or programs, to notify you of new Services features, to notify you of changes to our Terms or this Notice, and for other similar communications.


To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Services, or to other users of the Services.


Disclosure of Personal Information


We do not sell, rent or lease Personal Information to any third party. We may share Personal Information with the following parties, in compliance with applicable laws:


Employees and Affiliates. We may share Personal Information with our employees, sister companies, and affiliates who have a need to know the information for our business purposes.


Third Parties and/or Service Providers. We may share Personal Information with third parties and/or service providers that provide services for us. For example, we may share Personal Information with our subcontractors and vendors to help us offer, host and manage the Services; improve the content and functionality of the Services; perform data analysis and statistical analysis; troubleshoot problems with the Services; provide public relations; provide email services; provide data processing; and support or provide the security of the Services.


Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, us or any other party.


Professional Advisors. We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to us.


Change in Ownership. In the event we are the subject of a change of control or in the event Services changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s).


Other. We may share Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).


Use and Disclosure of Non-Personal Information


We may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. We are the sole and exclusive owner of such de-identified and aggregated information, including if we de-identify Personal Information so that it no longer considered Personal Information under applicable laws.


Information We Do Not Intend to Collect


Sensitive Information.Sensitive Information” is any data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that involves genetic or biometric data or data concerning health or sexual orientation. We do not intend to collect any Sensitive Information from you. Please do not provide Sensitive Information to us.


Access & Update Your Personal Information


To access or update your Personal Information as it exists in our records, please visit your account you have created or contact us using the information below.


Children Under the Age of 13


The Services are not intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the contact information listed below.


Social Media


We are active on social media, including Facebook, Twitter and Instagram, and Twitch (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Services and our Social Media pages any comments or content that you post on Social Media. You agree to hold Horizon Business Services harmless and without liability for the results of any and all content you post on Social Media.


The Services may allow you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. The Services may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Services. Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Notice. We encourage you to review those policies and terms.


Data Security


We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.


You understand that no data transmission over the internet or electronic device can be guaranteed to be 100% secure. While we strive to protect Personal Information, we do not guarantee the security of Personal Information and you provide Personal Information at your own risk.


Access from Outside the United States


If you access the Services from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by other jurisdictions.


Third-Party Websites


The Services may link to, or be linked to, affiliate or third-party websites, including other gaming platforms such as Steam and Discord. We are not responsible for third-parties’ privacy policies or practices. This Notice does not apply to any third-party websites or to any data that you provide to third parties. You should read the applicable privacy notice for each website that you visit.


California Residents


Non-Discrimination. California residents have the right to not receive discriminatory treatment for exercising any of their rights under applicable California privacy laws. If we choose to offer a financial incentives program in the future, additional terms will apply which may be an exception to this section.


Shine the Light. Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by emailing us at legal@HorizonBusinessServices.org.


Contact Us


If you have any questions or concerns regarding this Notice, please feel free to contact us at the following email, telephone number or mailing address.


Email: legal@HorizonBusinessServices.org


Telephone Number: (304) 646-6300


Mailing Address:

Horizon Business Services LLC


Attn: Legal Counsel
801 Orchid Drive
Naples, Florida