Privacy Policy

Effective Date: 1 June 2026

Welcome to Big Heart Technology's Privacy Policy.

Note: This Privacy Policy also contains a note about dispute resolution near the end — please see the Governing Law section for details.

We respect your privacy and are committed to protecting it. This policy explains how we handle your Personal Information ("PI") in our Technology ("Technology") products.

Personal Information means information that identifies, relates to, describes, or could reasonably be linked to an individual. For purposes of this Privacy Policy, “Personally Identifiable Information” (“PII”) is included within and treated as Personal Information ("PI"). And for clarity, Personally Identifiable Information refers to information that directly identifies an individual, such as a name, email address, phone number, or similar identifiers.

In the event of any conflict between this Privacy Policy and any summary or description within our Technology, this Privacy Policy controls.

You retain ownership of any information you voluntarily provide. We do not claim ownership of your Personal Information, and we are not responsible for its accuracy or appropriateness, as it is provided by you, to the extent permitted by law. By using our Technology, you grant Big Heart Technology, p.b.c. ("BHT", "we", "us", "our"), our Technology Partners ("TPs"), and our 3rd Party Partners ("3PPs") the limited rights necessary to process, use, and store your Personal Information solely for the purposes described in this Privacy Policy. And, by using our Technology, you also consent to the use of your information for the purposes stated in our Terms of Use ("ToU") and Game Rules (if applicable).

You must be at least the age of majority in your jurisdiction and have the legal authority to accept the terms of this Privacy Policy to use our Technology.

Note, BHT is a Public Benefits Corporation and does not sell your Personal Information. BHT may act as a service provider or processor on behalf of its Technology Partners, who may act as the controller of your information. Except where expressly stated otherwise, BHT does not act as a joint controller with third parties regarding Personal Information processed through the Technology. BHT maintains commercially reasonable administrative, technical, and physical safeguards designed to align with the principles of the California Consumer Privacy Act (CCPA), the European Union General Data Protection Regulation (“GDPR”), and similar laws, to the extent such laws apply to our operation and role in processing data, including our specific role as a service provider or processor.

If you have any questions, please contact us at Legal@BigHeartTrivia.org.

Here's The Information We Collect

  • Any information you voluntarily provide. You are responsible for ensuring the accuracy of the PI you provide; BHT is not liable for any issues, including failed payments or tax reporting errors, resulting from inaccurate or outdated information provided by you.
  • Information we collect required to comply with laws and safeguard against cybercrimes, as well as perform normal business operations such as using our Technology and providing customer service. This information can include location, IP address, and electronic device info.

We may use de-identified or aggregated versions of this information for internal analytics, system security, fraud prevention, and improving our automated "Privacy-First" detection technologies.

  • In cases where our Technology involves money transfer or financial transactions, we use third-party service providers (such as payment processors and identity verification services) to collect and process sensitive financial and identity information. These providers may collect information such as your name, email, address, financial account details, and tax identification information directly from you. BHT does not store full financial account information. We may receive limited information from these providers as necessary to operate the Technology, comply with legal obligations (including tax reporting), and prevent fraud. We may also collect other information, such as an optional publicity photo, if applicable. Because these providers may vary, you may contact Support@BigHeartTrivia.org to request the applicable provider’s privacy policy. We are not responsible for the privacy or security practices of these third-party providers.
  • BHT relies on third-party services for payment processing, hosting, and related operations. These services may collect and process information as part of providing the Technology and may have their own privacy policies.
  • You are not required to provide sensitive Personal Information to use our Technology unless it is necessary for specific features (such as payments or tax reporting). You should not submit sensitive Personal Information unless specifically requested.

Our Use Of Photos:

In the case where you give us your permission to use a photo, we'll access your local photo gallery. In this situation, the experience is designed to occur entirely on your device and BHT does not access, view, or store your photos on its servers, and our team cannot view your photos, and you can turn on or off the use of photos at any time. In the case where you voluntarily upload a photo, we will store your voluntarily uploaded photos on our servers, and authorized personnel may access them solely as necessary to operate the Technology.

Here's How We Use The Information We Collect

BHT, its service providers, and partners may process and use collected information where reasonably necessary for the operation of the Technology, compliance with legal obligations, fraud prevention, security, contractual performance, legitimate business purposes, or where you have provided consent, including for the following purposes:

  • Operating, providing, and maintaining our Technology
  • Complying with legal and regulatory obligations
  • Detecting, preventing, and addressing fraud, security, or technical issues
  • Protecting the rights, safety, and integrity of our users and business
  • Where you have provided consent
  • We may use information in aggregated or de-identified form for internal analytics, system improvement, security, and operational purposes
  • We may also use information to establish, exercise, or defend legal claims and to enforce our agreements.

Notes:

  • Device Integrity Measures: We may use third-party services that process device signals and identifiers. These measures may include the use of device signals, identifiers, or probabilistic techniques (sometimes referred to as “device fingerprinting”) solely for fraud prevention, security, and integrity purposes, including the detection of bot-driven or AI-automated interactions. Such identifiers are hashed and further pseudonymized within our systems and are not used for advertising, profiling, or cross-context behavioral tracking. We do not attempt to use these measures to directly identify individuals, and such measures are not reasonably capable of being used to identify an individual without additional information held separately. These data elements are retained only as long as necessary to support the operation and security of the Technology for fraud prevention, security, and operational integrity purposes. These measures are not used to track users across unrelated services or to build user profiles.
  • Some of the information we collect may be visible to the other users of our Technology, for example, a chosen nickname or company logo.
  • If applicable, you can review and update your voluntarily-provided information in the Technology. We say "applicable" because some of our Technology pseudonymizes, de-identifies, and aggregates data, which means your data may no longer be in a state that can be identified. If you don't have access to an actual Technology app or web application, your data is in this latter category.
  • We will comply with applicable laws and valid legal process, including lawful requests from authorities.
  • Our Technology is intended for a general audience and not directed to children. We do not knowingly collect personal information from children under 13. If you believe we have collected a child's personal information, or that your child has misidentified their age, please contact us at Legal@BigHeartTrivia.org.
  • We go to great lengths, including implementing business security, including, where applicable, the use of unique invite-only sign-up codes, to protect your information from security threats and cross-contamination. We share information only as described in this Privacy Policy, including where necessary to provide the Technology, comply with legal obligations, protect our users and business, or where you have provided consent. Note, because the primary way you hear about our Technology is via our TPs, that means the TP may already have your information despite our safeguards. To the extent personal information is independently collected by TPs and 3PPs, those parties are responsible for their own privacy practices. Even though our TPs and 3PPs may already have your personal information, as an extra layer of safety, we may ask you to voluntarily opt in when there is a request for additional data.
  • BHT does not verify or guarantee the accuracy, completeness, or reliability of any information provided by users or third parties. You further agree that any data found to be generated by automated or artificial intelligence means may be discarded without notice, and such activity constitutes a material breach of the applicable ToU. BHT makes no representations or warranties regarding the accuracy, reliability, completeness, or usefulness of any data, insights, or outputs generated through the Technology.
  • You acknowledge that you should not rely on our Technology or any output from it as a substitute for professional, financial, legal, or other advice. You are solely responsible for how you use the Technology and any decisions or actions taken based on information obtained through it.
  • While we strive to comply with applicable laws, compliance may depend on how the Technology is used, and you are responsible for ensuring that your use complies with applicable laws. We do not represent or warrant that the Technology will comply with all laws or regulations applicable to your specific use, jurisdiction, or circumstances.
  • BHT has no obligation to monitor, review, or verify user activity or content within the Technology.
  • If applicable, if you want to stop using our Technology and request deletion of your account, simply delete your account. Please know, though, that we may be obliged to retain certain information, for example, to complete the transaction for which the information was collected, or for security and IRS purposes. In particular, the California Consumer Privacy Act (CCPA) has carved out exceptions that give companies the latitude to do this if necessary. Please see the CCPA for details. We retain information only as long as necessary to fulfill the purposes described in this policy, comply with legal obligations, resolve disputes, and enforce our agreements.
  • Nothing in this Privacy Policy creates any fiduciary or special relationship between you and BHT.
  • The rights you are consenting to are transferrable in the case that BHT is merged, acquired, or sold.

Here's How Our Survey Partners Use Information Collected

Our Technology does not engage traditional online advertising. Therefore, we do not collect or sell information normally associated with presenting relevant display or video ads.

However, our Technology may involve market research. If applicable, we do not sell your Personal Information, nor share Personal Information with survey partners for cross-context behavioral advertising purposes, as defined under applicable law. We share only a summary of aggregated or de-identified audience insights with market researchers. BHT is not obligated to re-identify or maintain data in identifiable form once it has been de-identified or aggregated. For the avoidance of doubt, BHT’s disclosure of aggregated insights to survey partners is a functional necessity of the Technology and does not constitute a sale of PI under the CCPA or other applicable law.

Note, our market research survey partners each have their own privacy policies and you are required to read, and if appropriate, consent to these as well.

We contractually prohibit our market research partners from collecting Personally Identifiable Information (PII), such as your name, address, or telephone number. For purposes of this Privacy Policy, Personally Identifiable Information (PII) is treated as Personal Information. We also do not knowingly work with partners that violate this requirement. If you come across a survey that asks for PII, please contact Big Heart Technology immediately at Legal@BigHeartTrivia.org. It is always your choice to opt out of any market research we may offer.

Security Of Information

BHT uses commercially reasonable technical and organizational measures to safeguard your information.

However, we do not guarantee that our Technology will be secure, error-free, or continuously available at all times. And, when it comes to digital information, including digital information flowing over the Internet or other networks that we may or may not control, no one can guarantee 100% security, including BHT. By consenting to this Privacy Policy, you understand this limitation.

Further, you may find links to 3rd party content outside of the control of our Technology, and by consenting to this Privacy Policy, you also understand that any information you provide to such outside content is subject to that 3rd Party's privacy and security policies. As such, we take no responsibility for your information for activities outside of the control of our Technology. We are not responsible for the practices, content, or security of any third-party services, including survey providers and payment processors. BHT does not control and is not responsible for how third parties collect, use, or share your information. Any interactions you have with such third parties are at your own risk and subject to their respective terms and policies.

In the event of a data breach that is reasonably likely to result in harm to affected individuals, BHT will notify affected users and applicable regulatory authorities as required by law.

A Note About the California Consumer Privacy Act ("CCPA") and the European Union General Data Protection Regulation ("GDPR")

BHT is a Public Benefits Corporation and does not sell or share your Personal Information as those terms are defined under applicable privacy laws, including for cross-context behavioral advertising. BHT maintains commercially reasonable administrative, technical, and physical safeguards designed to align with the principles of the California Consumer Privacy Act (CCPA), the European Union General Data Protection Regulation (“GDPR”), and similar laws, to the extent such laws apply to our operation and role in processing data, including our specific role as a service provider or processor.

This includes honoring applicable rights and maintaining appropriate data handling practices consistent with our size and business model. If you are a California resident, or are in another applicable jurisdiction, you may have certain rights under the CCPA, GDPR, or similar laws, including the right to request access to, correction of, or deletion of your personal information, subject to certain legal exceptions and operational considerations. You may also have additional rights regarding portability, objection to certain processing, opting out of certain data sharing (as defined under applicable law), and limiting the use of sensitive personal information, where applicable. To exercise these rights, please contact us at Legal@BigHeartTrivia.org. We will respond in accordance with applicable law. Our Technology does not currently respond to “Do Not Track” signals or similar browser-based controls.

By the way, all players have other ways in which they can control their personal information as well, for example, limiting ad tracking altogether using the settings in your mobile device.

Governing Law And Jurisdiction

Our Technology is operated in the United States. If you access our Technology from outside the United States, you understand that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. Where applicable, BHT takes commercially reasonable measures intended to support lawful international data transfers under applicable privacy laws.

Our Privacy Policy is governed by United States federal law and the laws of the State of California, including the Federal Arbitration Act. Any disputes arising out of or relating to this ToU and Privacy Policy or your use of our Technology will be resolved through binding arbitration administered by the American Arbitration Association (AAA) in San Mateo, California, in accordance with its applicable rules on an individual basis, and you waive any right to participate in a class action lawsuit or class-wide arbitration. Opt-Out for Consumers: If you are using the Technology as an individual consumer, you may opt out of this arbitration agreement by sending written email notice to Legal@BigHeartTrivia.org within 30 days of first accepting these Terms. If you do so, neither you nor BHT will be required to resolve disputes through arbitration. This opt-out right does not apply to entities or users governed by a separate Partner Agreement. This arbitration provision shall survive termination of your relationship with BHT.

Should any court of arbitration, or any other competent authority, find any of the provisions in the Terms of Use or Privacy Policy to be void or unenforceable, it shall not affect the rest of the terms in the ToU and Privacy Policy.

To the extent permitted by law, any limitations of liability set forth in the applicable Terms of Use shall apply to all claims relating to this Privacy Policy.

Privacy Policy Changes

BHT may at its sole discretion, applied in a reasonable and good faith manner, revise and amend this Privacy Policy from time to time. If we do this, we will inform you about Privacy Policy updates in our Technology, and the updated version will be effective as of the revised date indicated above.

If You Don't Agree With Our Privacy Policy

It is your prerogative to not agree with some or all of our Privacy Policy or Terms of Use. In this situation, however, please immediately stop using our Technology and delete your account as applicable. Because by continuing to use our Technology, you agree to be bound by the entirety of our Privacy Policy and ToU, including any updates.