1. What this privacy policy covers

FACEOFF Limited (“FACEOFF”, “we,” “us,” “our”) is committed to letting you know how we will collect and use your information. This Privacy Policy covers FACEOFF's treatment of personally identifiable and other information that FACEOFF collects and receives, including information related to your use of FACEOFF websites and mobile applications. . "Data" and "information" includes information about you that is personally identifiable, such as your name, address, email address or phone number, and that is not otherwise publicly available. Where applicable we explicitly point out the use of personally identifiable data within our privacy policies. All other data is anonymous to us or is used pseudonymously.

The Privacy Policy also gives information about FACEOFF's use of cookies and how you may disable such cookies.

This Privacy Policy is applicable to all of FACEOFF’s websites, as well as any mobile applications published or distributed by FACEOFF (collectively, the “Sites”), as well as to any products or services offered by FACEOFF on the Sites. This Privacy Policy does not apply to information that you may submit to us offline, or to third-party websites and mobile applications that may be linked to on the Sites. We are not responsible for the actions and privacy policies of these third-party websites and applications. This Privacy Policy does not apply to the practices of companies that FACEOFF does not own or control, or to people that FACEOFF does not employ or manage.

By visiting our Sites, you are accepting the practices described in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Sites. We reserve the right to modify the terms of this Privacy Policy from time to time without notice. Your continued use of our Sites following the posting of changes will mean you accept those changes.

If you have any questions about this Privacy Policy, you should contact us by email at

2. Information collection

(a) We collect two basic types of information from you: (1) personally identifiable information (“PII”) and (2) non-personally identifiable information (“non-PII”). PII is any information that you supply to us that can individually identify you. PII includes, among other things, your name, contact information (e.g., email address, postal address, telephone number), payment information (e.g., credit/debit card information, bank account number), photographs in which you may be recognized, and biometric information (e.g., fingerprints, voiceprints). Non-PII includes information that does not personally identify you. Non-PII includes, among other things, information about your use of the Sites, such as your IP address, device identifiers, general location information, and demographic data.

FACEOFF collects PII in a number of ways, including when you:

  1. register for an FACEOFF account (such as by asking for your name, email address and birthdate)
  2. sign up to receive email offers, newsletters or alerts
  3. enter promotions or sweepstakes
  4. participate in surveys, panels or market research
  5. make purchases on the Sites
  6. request customer service or other assistance
  7. visit FACEOFF pages.

FACEOFF also automatically receives and records information on our server logs from your browser including your IP address, FACEOFF cookie information, software and hardware attributes, and the page you requested. Once you register with FACEOFF and sign in to our services you are no longer anonymous to us and your usage data will be connected to your account.

FACEOFF uses information (including anonymous and pseudonymous information, as well as PII ) for the following general purposes: to personalise the content you see, fulfil your requests for products and services, improve our services, contact you, conduct research, and provide anonymous reporting for internal and external clients.

As stated above, we also collect non-PII when users interact with the Sites. Non-PII does not personally identify you. Generally, we collect and store the following categories of non-PII:

  1. Device information used to access the Sites. This may include IP address (which is not considered PII in all jurisdictions), unique device identifiers, browser type, browser language, and other information.
  2. Usage information about interaction with the Sites. This includes a history of the pages viewed or advertisements clicked on, or other information used to customize the Sites.
  3. Additional use data such as time and date of access, software crash reports, session identification number, and referring website addresses.
  4. Aggregate data regarding the use of the Sites.
  5. Demographic data such as age, gender, ZIP code.
  6. User search terms and search results.

(b) Collection of Your Location Information You may send us information which may disclose the general location of your device at the time you access the Sites. Advertisements and certain content may be directed to you as a result of the collection of this data. In addition, in some cases the Sites can deliver content based on your specific location if you choose to enable that feature.

(c) Collection of Information from Other Sources. FACEOFF may combine information (including PII ) about you that we have with information we obtain from business partners or other companies, and from our offline interactions with you. For example, this may enable us to verify, update information contained in our records and to better customize the Sites for you.

(d) Use of Cookies, Web Beacons and Other Technologies.

Like many websites, we use “cookies”, which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We use cookies to track use of our Sites and exposure to our online advertisements.


We may also use cookies to monitor traffic, improve the Sites, and make it easier to use and more relevant. Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Sites may not work or may not work as designed. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at


We may also use web beacons or other technologies. A web beacon (also known as “action tags”, “tracer tags”, or “single-pixel gifs”) is an invisible graphic on a web page that is programmed to collect non-PII about your use of a given website. We do not share or provide PII we may collect through such web beacons, such as names, e-mail addresses and phone numbers without your express permission. We may also use locally stored objects to store data about your use of our Sites. Locally stored objects are a feature that permits websites to store data on your computer but not in a cookie.


We may partner with third party advertising companies who may use cookies, web beacons or other technologies to provide advertisements about our goods and services that may be of interest to you or to serve advertisements on our Sites. These third parties may use these technologies to collect information about you when you use the Sites. They may collect information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based advertising or other targeted content. They may use persistent identifiers to anonymously track your Internet usage across other websites in their networks beyond these Sites. Such third parties may, with sufficient data from other sources, be able to personally identify you, unknown to us. For information about how we share your personal information with service providers, please see the “Information Use” section below.


To learn more about the use of this information or to choose not to have this information used by our third party advertising partners by opting out, please visit the European Interactive Digital Advertising Alliance at ( or by clicking , or the Network Advertising Initiative by clicking


Some content or applications, including advertisements, on the Sites may be served by unaffiliated third parties. We do not control any of these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.


“Do Not Track” Functionality

Your browser or device may include “Do Not Track” functionality. Our information collection and disclosure practices, and the choices that we provide to users, will continue to operate as described in this Privacy Policy, whether or not a Do Not Track signal is received.

(e) Information Collected by Mobile Applications

Certain aspects of the Services may be provided through an application on your mobile, tablet computer or similar device (“Mobile Application”). You agree that we may collect and use technical data and related information, including but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to any such Mobile Applications.


If we implement one or more Mobile Applications, the Mobile Application may automatically collect and store some or all of the following information from your mobile device (“Mobile Device Information”), including without limitation:

  1. Your preferred language and country site (if applicable)
  2. Your phone number or other unique device identifier assigned to your mobile device
  3. The mobile device manufacturer and model of your mobile device
  4. The IP address of your mobile device
  5. Your mobile operating system
  6. The type of mobile Internet browsers you are using
  7. Information about how you interact with the Mobile Application and any of our web sites to which the Mobile Application links, such as how many times you use a specific part of the mobile application over a given time period, the amount of time you spend using the Mobile Application, how often you use the Mobile Application, actions you take in the Mobile Application and how you engage with the Mobile Application
  8. Information to allow us to personalize the services and content available through the Mobile Application
  9. Your geolocation

We may use information automatically collected by the Mobile Application (including the Mobile Device Information) in the following ways:

  1. To operate and improve our Mobile Applications, other Services, our company's services, and tools;
  2. To create aggregated and anonymized information to determine which Mobile Application features are most popular and useful to users, and for other statistical analyses;
  3. To prevent, discover and investigate violations of this Privacy Policy or any applicable terms of service or terms of use for the Mobile Application;
  4. To customize the content or services on the Mobile Application for you, or the communications sent to you through the Mobile Application (if any)

We may associate your unique device identifier or Mobile Application usage information with any PII you provide, but we will treat the combined information as PII.

For purposes of your use of any of our Mobile Applications and the services offered through any Mobile Application, the Mobile Application may also collect certain information about you (including PII) that you knowingly supply to the Mobile Application such as the following:

  1. Your user name and any password required by the Mobile Application
  2. Age
  3. Gender
  4. Mailing or other address
  5. Zip code
  6. Telephone number
  7. Email address
  8. Photos uploaded by you

Registration may be required and PII may also be collected if there is content from the Mobile Application that you specifically and knowingly upload to an online community, website or to the public, e.g. uploaded photos, posted reviews. This uploaded content will also be subject to the privacy policy of the platform to which you upload the content.

3. Information Use

We use the information we learn from you to help us personalize and continually improve your experience on the Sites. We may use your personally and non-personally identifiable information in the following ways:

General Uses. The following general uses:

  1. Provide the games, activities, contests, content, products and services on the Sites
  2. Post user generated content provided by users
  3. Communicate about account or transactions and send information about features and enhancements
  4. Communicate about changes to our policies
  5. Personalize content and experiences, including providing recommendations based on users’ preferences
  6. Send offers or promotions for our products, services or special events
  7. Send offers or promotions for third-party products, services or special events
  8. Provide advertising including advertising based on users’ activity on the Sites or activity on third-party websites
  9. Administer contests, sweepstakes, promotions, or surveys
  10. Optimize or improve our products, services and operations
  11. Customize your experience with the Sites or to serve specific content that is more relevant to you;
  12. Contact you with regard to your use of the Sites
  13. Detect, investigate, and prevent activities that may violate our policies or be illegal
  14. Perform statistical, demographic, and marketing analyses of users of the Sites and their purchasing patterns

Combination of Your Personally Identifiable Information. We may use the information from one portion of the Sites on other portions of Sites, and we may combine information gathered from multiple portions of the Sites into a single record. We may also use or combine information that we collect offline or we collect or receive from third-party sources to enhance, expand, and check the accuracy of your customer records.

4. Information sharing and disclosure

FACEOFF may share non-PII, such as aggregated user statistics, with third parties. In addition, FACEOFF may share PII about you as described below or otherwise in this Privacy Policy, or as disclosed at the time you provide your PII.

FACEOFF rent, sell, or share PII about you with other people or non-affiliated companies except to provide products or services you've requested, when we have your permission, or under the following circumstances:

  1. We provide the information to trusted partners, vendors and service providers who work on behalf of (such as to perform certain functions or aspects of the Sites or our services) or with FACEOFF under confidentiality agreements. These companies may use such information to help FACEOFF communicate with you (to the extent consented by you) about offers from FACEOFF and our marketing partners. However, these companies do not have any independent right to share this information. While we may use third-party analytics service providers to evaluate and provide us with information about the use of the Sites and viewing of our content, we do not share PII with these analytics service providers, but they may set and access their own cookies, web beacons, and embedded scripts on your Device and they may otherwise collect or have access to information about you, including non-PII.
  2. Certain aspects of the Sites may be provided to you in association with third parties (“Co-Branded Services”) such as sponsors and may require you to disclose PII to them. Such Co-Branded Services will identify the third party. If you elect to register for products and/or services through the Co-Branded Services, you may be providing your information to both FACEOFF and the third-party. Further, if you sign-in to a Co-Branded Service with a user name and password registered through our Sites, your PII may be disclosed to the identified third-parties for that Co-Branded Service and will be subject to their posted privacy policies.
  3. We respond to subpoenas, court orders, legal process, or to any legitimate request by authorities with which we must comply, or to establish or exercise our legal rights or defend against legal claims
  4. We believe it is necessary to share such information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of FACEOFF's Terms of Use, or as otherwise required by law
  5. FACEOFF may transfer such information about you if FACEOFF acquires, or is acquired by or merged with, another company. In this event, FACEOFF will notify you before information about you is transferred and becomes subject to a different privacy policy
  6. On the Sites, FACEOFF may display targeted advertisements based on anonymised or pseudonymised data and information, and FACEOFF may also display targeted advertisements based on PII. FACEOFF does not provide any PII to the advertiser when you interact with or view a targeted ad. However, by interacting with or viewing an ad you are consenting to the possibility that the advertiser will make the assumption that you meet the targeting criteria used to display the ad

5. Your ability to edit and delete your account information and preferences

You can edit your FACEOFF account information at any time, excluding your username. New categories of marketing communications might be added to the Account Holder's preferences page from time to time. Users who visit this page can opt out of receiving future marketing communications from these new categories or they can unsubscribe by following instructions contained in the messages they receive.

You will not be permitted to examine the PII of any other person or entity and may be required to provide us with PII to verify your identity prior to accessing any records containing information about you. We may not accommodate a request to change or delete PII if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.

6. Email Communications

We reserve the right to send and by becoming an Account Holder you hereby consent to us sending you certain communications, including commercial messages.

We do not offer you the opportunity to opt out of receiving service announcements and administrative messages and other communications relating to the FACEOFF service.

You may delete your FACEOFF account by emailing a request to

You may however opt-out of receiving commercial messages from us.

7. Confidentiality and security

We are concerned about ensuring the security of your PII and take certain security measures to help protect such information. Our security procedures mean that we may occasionally request proof of identity before we disclose your PII to you. We limit access to information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.

We have physical, electronic, and procedural safeguards that comply with our legal obligations to protect information about you.

Please understand, however, that while we try our best to safeguard your PII once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

You need to help protect the privacy of your own information. You must take precautions to protect the security of any PII that you transmit over any public or untrusted network by using encryption and other techniques to prevent unauthorized interception of your PII. You are responsible for the security of your information when using unencrypted, public or otherwise unsecured networks.

8. Your Obligations to Keep Your Access Rights Secure

You promise to: (a) provide true, accurate, current and complete information about yourself as prompted by our Sites and (b) maintain and promptly update your information to keep it true, accurate, current and complete. If FACEOFF suspects, in its sole discretion, that such information is untrue, inaccurate, not current or incomplete, FACEOFF has the right to suspend or terminate your account and refuse any use of the Sites (or any portion thereof). If you create an account through the Sites you are solely responsible for the security and confidentiality of your username and password and you are solely responsible for any and all activities that occur under your account.

9. How Long Do We Keep Personally Identifiable Information?

The time period for which we keep information varies according to what the information is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.

10. Children’s Information

To create an account and use the Sites, you must be at least 18 years of age or the age of majority in your jurisdiction (whichever is older). Therefore, the Sites are not intended for children under 18 years of age. Unless otherwise disclosed during collection and with parent or guardian consent, FACEOFF does not knowingly collect PII from children under 13 years of age. If you are under 13 years of age, do not provide PII to FACEOFF. If FACEOFF discovers that a child under the age of 13 has provided us with PII and we do not have parental consent, FACEOFF will promptly delete that child’s information from the Sites. If you believe that FACEOFF has been provided with the PII of a child under the age of 13 without parental consent, please notify us immediately at

11. Public Areas, Interactive Features and Activities

Please remember that any information you share in public areas of the Sites is public, and anyone may take and use that information. Please be careful about what you disclose and do not post any information that you expect to keep private. FACEOFF cannot control who views information that you post in public areas of the Sites and is not responsible for how third parties may use or disclose information that you post in public areas of the Sites.

12. What About Changes to The Privacy Policy?

We reserve the right to change this Privacy Policy from time to time. You agree that we may notify you of the updated Privacy Policy by posting it on our Sites so that it is accessible via a link on the home page of web sites or via a link or tab on Mobile Applications, and your use of the Sites after we have posted the updated Privacy Policy (or engaging in such other conduct as we may reasonably specify) constitutes your agreement to the updated Privacy Policy. Therefore, you should review this Privacy Policy from time to time, and before using any of our Services. The updated Privacy Policy will be effective upon reasonable notice after posting, or such later date as may be specified in the updated Privacy Policy.

13. Your California Privacy Rights

California’s “Shine the Light” law, California Civil Code § 1798.83, requires certain businesses to respond to requests from California customers (those who have an established business relationship with us) asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes., or alternatively allow customers to opt-out of having their personal information shared for such third-party marketing purposes. FACEOFF does not share your PII with any third-parties for their direct marketing purposes, and thus this California statute is not applicable to it.

14. What About Social Media Features and Widgets?

Some of our Sites may include social media plug-ins and features (such as the Facebook Like button) and widgets (such as the “Share This” button) or interactive mini-programs that run on our Sites. In addition, some of our Sites may also permit or require you to register or log into your account via a social networking platform such as Login with Facebook.

These social media features and plug-ins may share with us your username and password for the social media services and other information available about you or collected from you on these social media services, in accordance with the terms and conditions (e.g., terms of use and privacy policy) of the company providing them. In addition, the companies providing these features and plug-ins may be able to collect information about you, including your IP address, your activity on our Sites, and they may notify your connections on the social networking platform about your use of our Sites. These social media services may also set a cookie to enable a feature to function properly, and employ unique identifiers which allow your activity to be monitored across multiple Sites for purposes of delivering more targeted advertising to you.

Social media features and widgets are hosted by either a third-party or hosted directly on our Sites. Your interactions with these plugs-in and features are governed by the privacy policy of the company providing them.

15. How Can You Contact Us?

To opt-out of having your PII shared for third-party marketing purposes, to correct or update your account information, to request information under California’s Shine the Light law (section 12) or if you have any questions about this Privacy Policy or our data practices, you may contact us in the following ways:

By e-mail:

By postal mail: Clinch's House, Lord Street, Douglas, Isle of Man IM99 1RZ