Privacy Policy | The Royal Observer

Privacy Policy

Dated April 1, 2024

Mystify Entertainment Network Inc. (collectively, “we”, “us” or “our”) owns and operates websites, mobile applications, and other digital, interactive services (collectively, the “Services”). This Privacy Policy applies to the information we collect through the Services, unless the specific website, mobile application, or other digital, interactive service has a separate privacy policy, in which case that privacy policy will govern. This Privacy Policy, together with the Terms of Use, sets forth the general rules and policies governing your use of our Services. Depending on your activities when visiting our Services, you may be required to agree to additional terms and conditions.

This policy describes:

· The information we collect and how we collect it;

· What we do with the information we collect;

· How we share your information;

· Exercising choice;

· California Privacy Rights;

· How you can access and update your information;

· User based in EEA and Switzerland;

· Security of Personal Data;

· Retention of Your Personal Data;

· Children;

· Links to Third Parties; and

· Changes to Privacy Policy.

1. INFORMATION WE COLLECT

Our Services typically collect three kinds of information about you:

(a) information that you voluntarily provide that personally identifies you, including financial information;

(b) information that we automatically collect when you use our Services; and

How we collect and store information depends on the websites you visit, the activities in which you participate and the Services you use. You can use some of the Services without providing any information other than what is automatically collected as described below.

Information You Provide

We may collect information about you during your use of the Services, including your name, username, password, email address, postal address, phone number, mobile phone number, payment information, gender, birth year, and information you provide or post on our Services or allow us to access when you do certain things, such as:

· Enter registration information for one or more of our Services;

· Enter a sweepstakes or contest or register for a promotion;

· Participate in voting or polling activities;

· Make a purchase;

· Request certain features (e.g., newsletters, updates, and other products);

· Sign up to receive SMS (text message) notifications;

· Download or use one of our mobile applications;

· Connect with the Services or otherwise allow us to access certain information about you via a social networking site (SNS); or

· Post user-generated content, including comments, to or on any of our Services.

Automatically-Collected Information

Device/Usage Information

We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as

(a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and

(b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information.

As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information. We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique identifier for our internal use.

Location Information

We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features.

By using our Services, you consent to the collection of location information.

If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

Cookies and Local Stored Objects

To enhance your experience on our Services, we place "cookies" on your computer or device. Cookies are small text files that we place in your computer or device to store your preferences. Other information you provide to us may be linked to the data stored in the cookie. A cookie assigns a unique numerical identifier to your Web browser or device, and may enable us to recognize you as the same user who has used our Services, and relate your use of the Services to other information about you.

We use session and performance cookies to provide you with the services you request and to improve your experience with our Services. For example, we use cookies to personalize your experience on our Services (e.g., to recognize you by name when you return to our site, to save your password in password-protected areas, to enable shopping carts, or to tailor content or product and service offerings). Other cookies are essential to ensure the security and operation of our Services. We also use cookies (and Local Shared Objects, HTML5, cache cookies, web beacons, or clear gifs, all described further below) to understand usage of the Services, analyze traffic, and to improve our content and offerings. Some third parties, such as Google, may place cookies on your browser when you use our Services in order to track your activity across websites and to provide you advertisements tailored to your interests and online activities.

For more information on how to opt out of Online Behavioral Advertising, see the Exercising Choice section below. For our European based users, we only place or allow tracking cookies to be placed on your browser with your consent. Most browsers automatically accept cookies. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser.

Information from Third Parties

We may obtain additional information about you from third parties such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

Aggregate or De-identified Data

We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

2. HOW WE USE THE INFORMATION COLLECTED

In general, we use the personally identifiable information that we collect to provide you with the services, including the following based on our legitimate interests:

· To send you information about your relationship or transactions with us;

· To send you alerts or other communications via SMS messages or other media or networks;

· To notify you about new features of the Services, special events, or products, services, and special offers;

· To administer sweepstakes and contests;

· To process and respond to your inquiries;

· To contact you with information that we believe will be of interest to you;

· To attribute content to you that you make available through the Services (such as comments you post);

· To generate and review reports and data about our user base and Service usage patterns;

· To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Services;

· To improve the content and features of the Services or develop new Services;

· To allow us to personalize the content and advertising that you see on the Services and to understand how users interact with and use our advertisements and Services;

· To enforce the legal terms that govern your use of the Services;

· To administer and troubleshoot the Services; and

· To associate your activities, customize content or tailor advertising across different devices and browsers that you use to access the Services (for instance, computers, tablets, mobile devices, applications and websites).

3. HOW WE MAY SHARE YOUR INFORMATION

We will make your information available to other companies, websites, applications or people with your consent, or consistent with our legitimate interests, in the circumstances described below:

· We may rent, sell, or share your information with non-affiliated third parties:

(a) in order to provide services or products that we believe may be of interest to you;

(b) when we have your permission; or

· We may share your information with our agents or companies in order to provide the Services or advertising or to communicate with you on our behalf.

· When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, and/or sponsors and the use of that information will be also governed by the privacy policies or practices of those advertisers, operators, and/or sponsors.

· We may disclose your information in response to any subpoenas, court orders, or other legal process we receive, or to establish or exercise our legal rights or to defend against legal claims.

· We may share your information with third-parties with whom we have a contractual relationship, including without limitation third-party advertisers and advertising networks.

· We may disclose your information when we believe in good faith that such disclosure is appropriate in order to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or the Terms of Service for the Services you accessed, and/or to protect our rights and property, and the rights and property of our employees, users and the public. This may involve sharing your information with law enforcement, government agencies, courts, and/or other organizations.

· We may share your information in connection with any proposed or actual merger, reorganization, transfer of control, a sale of some or all of our assets, or a financing or acquisition of all or a portion of our business by another company.

· We may aggregate and/or de-identify your information so that the information no longer relates to you individually. Our use and disclosure of such aggregated or de-identified information is not subject to this Privacy Policy, and may be disclosed to others without limitation and for any purpose.

4. EXERCISING CHOICE

Promotional Emails

You may opt-out from receiving future promotional emails from us, or direct that we not share your information with any Affiliated Companies, by clicking the "unsubscribe" button that appears on our promotional e-mails. Please refer to the settings or options menu in your email client for more information. You can remove yourself from our postal mailings by emailing us at [email protected].

You can also remove yourself by contacting us as described in the "How to Contact Us" section below.

Online Behavioral Advertising

When you use the Services, we may serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your age or gender, your searches, demographic data, user-generated content and other information that you provide to us. Some of the services and advertisements are delivered or served by third-party companies. These companies place or recognize cookies, pixel tags, web beacons or other technology to track certain information about our Services website users.

For example, in the course of serving certain advertisements, an advertiser may place or recognize a unique cookie on your browser in order to collect certain information about your use of the Services. For another example, an advertiser or ad server may also be able to collect your device’s unique identifier in the course of serving an ad. In many cases, this information could be used to show you ads on other websites based on your interests. We do not have access to, nor control over, these third parties' use of cookies or other tracking technologies or how they may be used. For example, we use Google to serve advertisements on the Services, which use the Google Doubleclick cookie, and in some cases, a unique device identifier, to show you ads based on your visit to our websites and other sites on the Internet. You may opt out of the use of the Google Doubleclick cookie by visiting the Google ad and content network privacy policy. If you would like more information about this practice, and to learn how to opt out of behavioral advertising on the particular device on which you are accessing this Privacy Policy, please visit: http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#.

You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in mobile apps.

Please note that the opt out is cookie-based and will only affect the specific computer and browser on which the opt out is applied. If you delete your browser cookies and want to continue to be opted out of interest-based ads, you will need to opt out again.

For more information about how we use cookies please visit our Cookie Policy.

Precise Device Location Tracking

If you authorized us and/or our service providers to collect and/or share information about the precise location of your device through a mobile application, you can always withdraw your consent and prevent the further collection and sharing of your precise device location information by accessing your devices location privacy settings. Each operating system, iOS for Apple devices, Android for Android devices and Windows for Microsoft devices, provides its own instructions on how to turn off precise location sharing. Access the privacy settings for your mobile device or contact your platform operator for more information.

5. CALIFORNIA PRIVACY RIGHTS

If you are a California Consumer, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.

Collection of Personal Information

When California Consumers access our websites, use our services, or contact us, we collect the following Personal Information.

Categories of consumer’s Personal Information collected: Identifiers

Examples: Real Name, Alias, Post Address, Email, Phone Number, Date of Birth, and Account Name

Business or commercial purpose for which the Personal Information was collected: Provide you with access to our content. Provide you with the services you request.

Communicate with you regarding your account or transactions with us. Send you offers and promotions for our products and services

Categories of sources from which that Personal Information was collected: The Information was collected directly from you

Categories of third parties with whom the business shares Personal Information: Affiliates, analytics providers, service providers, transaction processors, IT vendors, and law enforcement (if necessary)

Categories of consumer’s Personal Information collected: Financial Information

Examples: Credit Card Number

Business or commercial purpose for which the Personal Information was collected: Process your transactions

Categories of sources from which that Personal Information was collected: The Information was collected directly from you

Categories of consumer’s Personal Information collected: Commercial Information

Examples: Subscriptions purchased.

Business or commercial purpose for which the Personal Information was collected: Process your transactions. Provide you with access to our content

Categories of sources from which that Personal Information was collected: This information is collected directly from you or by logging our interactions with you.

Categories of consumer’s Personal Information collected: Internet or Electronic Network Activity Information

Examples: Browsing History. Information regarding a consumer’s interaction with an Internet website, application or advertisement.

Internet Protocol address, device ID. Cookies, beacons, pixel tags, mobile ad identifiers.

Business or commercial purpose for which the Personal Information was collected: Provide you with targeted advertising based on your activity on our sites.

Operate, understand, develop, or improve our sites, applications, products, services, and operations.

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity.

Debugging to identify and repair errors that impair existing intended functionality.

Investigate and prevent activities that may violate our policies.

Categories of sources from which that Personal Information was collected: We collect your internet or other electronic network information from your interactions with our website.

Categories of consumer’s Personal Information collected: Geolocation Data

Examples: Location information, device location information.

Internet Protocol address, device ID. Cookies, beacons, pixel tags, mobile ad identifiers.

Business or commercial purpose for which the Personal Information was collected: Provide you with access to our content.

Provide you the services you request.

Categories of sources from which that Personal Information was collected: We collect your geolocation information from your interactions with our Services.

In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

Individual Rights

Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we disclose the Personal Information it collects, uses, and discloses about you to third parties. There are two types of Right to Know requests you can make:

· Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:

Category of personal information collected,
Categories of sources from which that information was collected,
The business or commercial purpose(s) for which the information was collected,
The categories of third parties to whom we sold or disclosed the category of personal information for a business purpose, and
The business or commercial purpose for which we sold or disclosed the category of personal information.

· Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:

Specific pieces of Personal Information collected about you.

We do not sell any Personal Information of California consumers. This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

Right of Deletion

You have the right to request that our service providers and we delete any Personal Information about yourself that we have collected from you upon receipt of a verifiable request. This right is subject to exceptions.

Submitting Requests

You can submit your request by calling us at 917-231-8680. You may also submit a request through a webform available by emailing us at [email protected].

Verifying Requests

We provide California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. We must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.

Authorized Agent

You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in us denying your request.

Right to Equal Service

We will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

· Denying goods or services to you.

· Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.

· Providing a different level or quality of goods or services to you.

· Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

DO NOT TRACK

Our Sites and Services do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Sites or Services, and we do not alter any of our data collection and use practices upon receipt of such a signal.

SHINE THE LIGHT

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 (if any) 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 at: [email protected] with the subject heading “California Privacy Rights.”

7. ACCESSING AND UPDATING YOUR INFORMATION

You may contact us as at [email protected] if you have questions or comments about our Privacy Policy; wish to make corrections to any personally identifiable information you have provided; want to opt-out from receiving future commercial correspondence, including emails, from us or our Affiliated Companies; or wish to withdraw your consent to sharing your personally identifiable information with others.

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 Services.

8. USERS LOCATED IN THE EEA AND SWITZERLAND

If you are a user in the EEA or Switzerland, the following information applies with respect to personal data collected through your use of our Services.

Purposes of Processing and Legal Basis for Processing

We process personal data consistent with our disclosures in this Privacy Policy. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services to you; (3) to meet legal obligations, and (4) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedoms related to data privacy.

Transfers

Personal data we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or processors maintain facilities. We have put in place appropriate safeguards to ensure the protection of any personal information transferred from the EEA or Switzerland to the United States and other countries. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in our Privacy Policy.

Individual Rights.

If you are a resident of the EEA or Switzerland, you have certain rights under EU General Data Protection Regulation, as set forth below:

· Right of access: You have the right to request a copy of the information that we hold about you.

· Right of rectification: You have the right to have information that we hold about you that is inaccurate or incomplete corrected.

· Right to be forgotten: In certain limited circumstances, you have the right to request that we erase from our records the information that we hold about you.

· Right to restriction of processing: In certain limited circumstances, you have the right to restrict the processing of your information.

· Right to withdraw consent: If you have provided consent for the processing of your information, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.

· Right of portability:In certain limited circumstances, you have the right to have the information we hold about you transferred to another organization.

· Right to object to automated processing, including profiling: You have the right to not be subject to the legal effects of automated processing or profiling.

· Right to lodge a complaint: You have the right to lodge a complaint with a regulatory authority, if you believe that we have not complied with the requirements of the GDPR with regard to your personal information. A listing of EU data protection authorities can be located at: https://ec.europa.eu/justice/article-29/structure/data-protection-author...

· Right to Object: You have the right to object to certain types of processing of your information such as direct marketing (to the extent applicable).

This Privacy Policy does not create rights enforceable by third parties.

If you would like to exercise the above-mentioned rights, please direct your written concerns to the following address: [email protected]

9. SECURITY OF PERSONAL DATA

We maintain administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, loss, modification, disclosure, and any form of unlawful processing of personal data in our custody and control, and our service providers are bound to maintain similar safeguards. These measures also aim at preventing unnecessary collection and further processing of personal data. Although we take appropriate measures to safeguard the personal data in our custody and control, and we require similar safeguarding measures from our service providers, we need you to understand that we are unable to guarantee the security of your personal data.

To provide you with an increased level of security online, access to your personal data on certain of our websites may be protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication.

10. RETENTION OF PERSONAL DATA

We will take reasonable steps to accurately record the personal data that you provide to us and any subsequent updates. We will retain your personal data as long as necessary to fulfill the purposes for which it was collected. Thereafter, we will either delete your personal data or de-identify it so that it cannot be attributed to your identity. Please note that we may continue to retain personal data for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

11. CHILDREN

The features, programs, promotions and other aspects of our Services requiring the submission of personally identifiable information are not intended for anyone under 18 years of age. We do not knowingly collect personally identifiable information from children under the age of 13. If you are a

9197/2/8122480.v1

parent or guardian of a child under the age of 13 and believe he or she has disclosed personally identifiable information to us, please contact us at [email protected]. A parent or guardian of a child under the age of 13 may review and request deletion of such child's personally identifiable information as well as prohibit its use.

12. OTHER SITES/LINKS

Our Services 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 Services 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 Services and to read the privacy statements of all third party websites before submitting any personally identifiable information.

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy. When we change it, we will make a copy of it available to you by making it available on the Services, or through other methods. If we make material changes to this Privacy Policy, we will make you aware of them where we post the updated policy and may also notify you by other reasonable methods that we select. If we make material changes to this Privacy Policy that will result in a new use, disclosure, or permission of access to your personal data that we previously collected and stored, we will obtain any consent that may be required by law.

You understand and agree that if you use this website after the effective date of the updated Privacy Policy, we consider your use as acceptance of it.