Last Updated January 2022

This Privacy Notice explains how information about you, that directly identifies you, or that makes you identifiable (“personal information”) is collected, used and disclosed by Boink Technologies, Inc. (“Slushy,” “we,” “our,” or “us”), our Slushy platform (the “Platform”), our website http://slushy.com (the “Site”), and our other online products and services that link to this Privacy Notice (collectively, the “Service”).

GLOBAL APPLICABILITY AND REGION-SPECIFIC DISCLOSURES

This Privacy Notice is designed to apply to our Site visitors and users of our Services. We may choose or be required by law to provide additional disclosures relating to the processing of personal information in certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

• California - Your California Privacy Rights: If you are a California resident, please see the Additional Notice for California Residents for additional California-specific privacy disclosures, including what constitutes personal information and your consumer rights with respect to your personal information.
• Nevada: Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Note we do not sell your personal information within the meaning of Chapter 603A. However, if you would still like to submit such a request, please visit our Privacy Rights Request Center.
• European Economic Area, United Kingdom or Switzerland: If you are located in the European Economic Area (“EEA”), United Kingdom or Switzerland, or otherwise engage with Boink’s European operations, please see the Privacy Disclosures for the European Economic Area, United Kingdom and Switzerland for additional European-specific privacy disclosures, including what constitutes your personal information, the lawful bases we rely on to process your personal information, how we use cookies when you access our Sites from the EEA, UK or Switzerland and your rights in respect of your personal information.

1. INFORMATION WE COLLECT AND OUR USE

We collect personal information about you in connection with your use of our Service. This collection includes information that you may provide in connection with the Service, information from third parties, and information that is collected automatically such as through the use of cookies and other technologies.

Information That You Provide

We collect personal information from you. The categories of information we collect can include:

• Sign Up. We collect personal information that you provide when you register for an account to use our Service. This information may include your phone number, email address, handle, and display name. We use this information to administer your user account, provide you with the relevant services and information, communicate with you regarding your account, the Service, and for customer support purposes.
• Creator Invitations. If you are invited to become a creator on our Platform, we may collect the information provided in connection with your invitation, including your first and last name, date of birth, email address, social security number or tax ID, address, banking information, EIN/business tax ID, and government identification (such as your driver’s license and passport). We use this information to verify your identity, administer your Creator account and to communicate with you. If you are approved as a Creator, we will also connect you with our background checks service provider and will collect the information required to perform the background checks (including in connection with sex offender screenings).
• Identity Verification Information. We may use identity verification services provided by a third-party provider, Persona, to verify your identity documents, confirm your identity and protect against fraud and abuse. When you create an account, you may be asked to submit your name, birthdate, address, phone number, email address, government identification number and copies of government identification documents, along with a selfie image. Our third-party provider, Persona, may use a combination of machine learning tools and optical scans to authenticate your identity document, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a "match." Slushy does not receive the biometric identifier generated from the images. It is generated and held by Persona until we inform them that the biometric identifier is no longer needed for the purposes described in this paragraph and must be destroyed. For identity verification and security purposes, Slushy will have access to the selfie image and will receive the information extracted from the identity scan of the ID document as well as the results of the identity verification process. We may use this process and associated information to verify your identity, authenticate your identity documents, and protect against fraud and misrepresentation. We do not use, disclose or retain your biometric information for any other commercial purpose. Our third-party provider, Persona, processes this information on our behalf strictly in accordance with our contractual agreements. For more information on Persona’s data processing practices, please see Persona’s Privacy Policy (available here).
• Payment Information. If you sign up for our Service and choose to provide your payment information, we collect the information provided in connection with your payment, such as your payment card information. Please note that we use third party payment processors to process payments made to us and such third-party processor collects and retains your payment information. Our third-party processor is Inovio Payments, LLC. The payment processor’s use of your personal information is governed by their privacy notice. To review their privacy policy: https://www.inoviopay.com/privacy.
• Creator-Generated Content. If you upload content as a Creator, we collect your visual and audio information, such as videos, photographs, messages, and other information provided when using our Service. We use this personal information to fulfill your request to upload certain content. Please note Creators are responsible for all Creator-generated content and other information they provide through our Service. We may use third party services to review Creator-generated content.
• Marketing Emails. If you sign up to receive news or alerts from us, we collect your email and applicable interests and communication preferences in order to send you regular updates about the Service. We use this information to manage our communications with you and send you information about products and services we think may be of interest to you. To unsubscribe from promotional messages, please follow the instructions within our messages and review the Control Over Your Information section below. Note that you cannot unsubscribe from certain services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).