Privacy Policy

Dazzle, Inc., a Delaware corporation (“Dazzle,” “we,” “us,” or “our”), is committed to protecting your privacy. This Privacy Policy (the “Policy”) explains how we collect, use, disclose, and safeguard personal information when you access or use our website at www.dazzle.tv, our mobile applications, and related services that link to this Policy (collectively, the “Service”). Dazzle operates a mobile platform for live interactive shows.

By accessing or using the Service, you acknowledge that you have read and understood this Policy. If you do not agree, please do not use the Service. This Policy is incorporated by reference into our Terms and Conditions.

1. Scope of This Policy

This Policy applies to personal information processed by Dazzle in connection with the Service. It does not apply to information collected by third parties whose websites, applications, or services may be linked to or accessible through the Service. We encourage you to review the privacy policies of those third parties before providing them with personal information.

If you are located in California, the European Economic Area, the United Kingdom, Canada, Brazil, Australia, or another jurisdiction with specific data protection laws, additional disclosures and rights may apply to you. Please see Section 12 (Region-Specific Disclosures).

2. Information We Collect

We collect personal information in the following ways:

2.1 Information You Provide to Us

• Account information. When you create an account, we collect your name, email address, username, password (stored in hashed form), date of birth (to confirm age eligibility), and, if you sign in through a third-party identity provider (such as Apple, Google, or Facebook), the basic profile information that provider shares with us.
• Profile information. Photos, avatars, display names, bios, preferences, and other content you choose to add to your profile.
• Live show and user-generated content. Livestream broadcasts, recorded video, audio, photos, chat messages, comments, reactions, polls, virtual gifts, tips, and other content you create, upload, share, or transmit through the Service (collectively, “User Content”).
• Communications. When you contact us for support, respond to surveys, or otherwise communicate with us, we collect the information you choose to share, including the contents of your messages.
• Payment information. When you purchase subscriptions, virtual goods, or other paid features, payment is processed by Apple (App Store) or Google (Google Play). We do not receive or store your full payment card details. We do receive limited transaction information (such as a transaction identifier, the product purchased, and renewal status) from the applicable app store.

2.2 Information Collected Automatically

• Device and connection information. Device model, operating system and version, unique device identifiers, advertising identifiers (such as Apple’s IDFA or Google’s AAID, subject to your device permissions), mobile network information, browser type, and time zone.
• Usage information. Pages or screens viewed, features used, actions taken, content viewed, livestream watch and broadcast activity, the dates and times of your interactions, referring URLs, and similar interaction data.
• Approximate location. We infer approximate location (city or region) from your IP address. We do not collect precise GPS location unless you grant the relevant operating-system permission.
• Log information. IP address, access times, crash reports, performance data, and diagnostic information.
• Cookies and similar technologies. We and our partners use cookies, pixels, software development kits (SDKs), and other tracking technologies. See Section 6.

2.3 Information from Third Parties

• Identity providers. If you sign in using a third-party identity provider, we receive the information you authorize that provider to share.
• Advertising and analytics partners. We may receive information about your engagement with our advertising from partners such as Meta, Google, and TikTok.
• Other users. Other users may share information about you (for example, by mentioning you, sending you a virtual gift, or inviting you to the Service).

3. How We Use Personal Information

We use personal information to:

• Provide, maintain, secure, and improve the Service, including livestream delivery, chat, virtual gifting, and discovery features;
• Create and manage your account and authenticate users;
• Process transactions and provide subscription and virtual-goods benefits (in coordination with Apple and Google);
• Communicate with you about your account, transactions, security alerts, and policy updates (these are transactional and you cannot opt out while you maintain an account);
• Send marketing and promotional communications, subject to your consent where required and your right to opt out at any time;
• Send push notifications (subject to your operating-system permissions) and, where you have provided express written consent, SMS or text messages;
• Personalize content, recommendations, and advertising;
• Measure the effectiveness of advertising, including with third-party advertising partners;
• Conduct analytics, research, and product development;
• Detect, investigate, prevent, and address fraud, abuse, security incidents, copyright infringement, and violations of our Terms or Acceptable Use Policy;
• Comply with legal obligations, respond to lawful requests, and enforce our agreements; and
• For any other purpose disclosed to you at the time of collection.

We do not use your User Content to train generative artificial intelligence models for third parties. If we develop or deploy machine-learning features that use your information for new purposes, we will provide notice and, where required by law, obtain your consent.

4. Legal Bases (EU/UK Users)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under the General Data Protection Regulation (“GDPR”) and UK GDPR:

• Contract (Art. 6(1)(b)): To provide the Service and perform our agreement with you.
• Legitimate interests (Art. 6(1)(f)): To operate, secure, and improve the Service; to prevent fraud and abuse; to conduct analytics; and to send certain non-marketing communications. You may object to processing based on legitimate interests; see Section 8.
• Consent (Art. 6(1)(a)): For marketing communications where required, non-essential cookies, certain advertising activities, and other processing where we ask for your consent. You may withdraw consent at any time without affecting prior lawful processing.
• Legal obligation (Art. 6(1)(c)): To comply with our legal obligations.
• Vital interests (Art. 6(1)(d)) and public interest (Art. 6(1)(e)): In rare circumstances such as emergencies.

5. How We Share Personal Information

We share personal information as follows:

• Service providers. With vendors that perform services on our behalf, including cloud hosting (e.g., Amazon Web Services), payment-adjacent services, email and SMS providers (e.g., SendGrid, Twilio), analytics providers (e.g., Google Analytics, Amplitude, Mixpanel, PostHog), customer support tools, content moderation services, and security services. These providers are bound by contract to process personal information only on our instructions and to safeguard it.
• Advertising partners. With advertising and measurement partners (e.g., Meta, Google, TikTok) to deliver and measure advertising. This activity may constitute “sharing” or a “sale” of personal information under certain U.S. state privacy laws; you have the right to opt out. See Section 12.
• Other users and the public. Information you share publicly—for example, your profile, livestream broadcasts, on-air chat, comments, reactions, and gifts sent or received—is visible to other users and may be accessed by anyone, including via search engines and third-party clipping or recording tools.
• Affiliates. With our parent, subsidiaries, and other affiliates, who will use the information consistent with this Policy.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, bankruptcy, receivership, or sale or transfer of all or a portion of our assets. We will require any successor to honor commitments made in this Policy.
• Legal and safety. With law enforcement, regulators, courts, or other parties when we believe disclosure is necessary or appropriate to (a) comply with applicable law, lawful requests, or legal process; (b) protect the rights, property, or safety of Dazzle, our users, or others; (c) enforce our Terms or agreements; or (d) detect, investigate, or prevent fraud or security issues.
• With your direction or consent. With other parties when you direct us to do so or have consented.

We do not sell personal information for monetary consideration. However, some of our advertising activities may constitute a “sale” or “sharing” under California or other U.S. state privacy laws because they involve disclosing personal information for cross-context behavioral advertising. See Section 12.

6. Cookies and Similar Technologies

We and our partners use cookies, pixels, SDKs, and similar technologies for purposes including authentication, security, preferences, analytics, and advertising. Where required by law (including in the EU/UK), we obtain consent for non-essential cookies through a consent banner. You may control cookies through your browser settings; on mobile, you may control advertising identifiers through your device settings. We honor Global Privacy Control (“GPC”) signals as an opt-out request for the “sale” and “sharing” of personal information for users in jurisdictions where GPC is recognized.

7. Push Notifications and SMS Messages

With your permission, we send push notifications to your mobile device. You may disable push notifications through your device settings at any time.

If you provide your phone number and expressly consent, we may send you SMS or text messages, including transactional messages and, separately, marketing messages. Consent to receive marketing texts is not a condition of purchase. Message and data rates may apply. Message frequency varies. Reply STOP to unsubscribe and HELP for help.

8. Your Choices

• Account. You may access, update, or delete your account through your account settings or by contacting us.
• Marketing emails. You may unsubscribe at any time by clicking the link in any marketing email.
• SMS. Reply STOP to any marketing text to unsubscribe.
• Push notifications. Manage through your device settings.
• Advertising. Manage ad personalization through your device settings (e.g., “Limit Ad Tracking” on iOS, “Opt out of Ads Personalization” on Android), and through industry opt-out pages at optout.aboutads.info and optout.networkadvertising.org.
• Mobile permissions. You may grant or revoke permissions (camera, microphone, photos, location, contacts) through your device settings. Disabling camera or microphone permissions will prevent you from broadcasting live.

If you are in a jurisdiction that grants you additional rights, see Section 12.

9. Data Retention

We retain personal information for as long as necessary to provide the Service and fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law (for example, for tax, accounting, dispute resolution, fraud prevention, or legal-compliance purposes). Account information is generally retained for the life of your account plus a reasonable period thereafter. Recorded livestream content and chat logs are retained as needed to provide the Service and to enforce our Terms. When we no longer need personal information, we will delete, anonymize, or aggregate it.

10. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your account credentials confidential.

11. International Data Transfers

Dazzle is headquartered in the United States, and our service providers may be located in other countries. By using the Service or providing us with information, you understand that your information may be transferred to and processed in the United States and other jurisdictions that may have different data-protection laws than your home country. Where required, we implement appropriate safeguards for international transfers, including Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Addendum.

12. Region-Specific Disclosures

12.1 California (CCPA/CPRA)

In the prior 12 months, we have collected the categories of personal information listed in Section 2, including identifiers, customer records, commercial information, internet/network activity, geolocation (approximate), audio/visual information, professional or employment-related information (limited), and inferences drawn from the foregoing. We collect this information from the sources described in Section 2, for the business and commercial purposes described in Section 3, and disclose it to the categories of recipients described in Section 5.

We do not sell personal information for monetary consideration. We disclose personal information to advertising partners for cross-context behavioral advertising, which constitutes “sharing” (and may be deemed a “sale”) under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”). California residents have the right to:

• Know what personal information we collect, use, disclose, and share;
• Request access to and a copy of their personal information;
• Request correction of inaccurate personal information;
• Request deletion of personal information, subject to certain exceptions;
• Opt out of the “sale” or “sharing” of personal information;
• Limit the use and disclosure of sensitive personal information (we do not currently use sensitive personal information for purposes that would require a “Limit the Use” link); and
• Be free from retaliation for exercising these rights.

To exercise these rights, visit www.dazzle.tv/privacy or email hi@dazzle.tv. To opt out of “sharing” or “sale,” you may also use our “Your Privacy Choices” link or send a GPC signal, which we honor. Authorized agents may submit requests on your behalf with written authorization and proof of identity. We retain personal information for the periods described in Section 9.

12.2 Other U.S. State Privacy Laws

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Tennessee, Indiana, Iowa, Delaware, Nebraska, New Hampshire, New Jersey, Minnesota, Maryland, Rhode Island, or another state with a comprehensive privacy law, you may have rights to access, correct, delete, and obtain a portable copy of your personal information; opt out of targeted advertising, the sale of personal information, and certain profiling; and appeal a denial of these rights. To exercise these rights or appeal, email hi@dazzle.tv. We will respond within the timeframes required by applicable law.

12.3 European Economic Area, United Kingdom, and Switzerland

If you are located in the EEA, UK, or Switzerland, you have the following rights under the GDPR and UK GDPR:

• Access to your personal information;
• Rectification of inaccurate or incomplete information;
• Erasure (“right to be forgotten”);
• Restriction of processing;
• Data portability;
• Objection to processing based on legitimate interests or for direct marketing;
• Withdrawal of consent at any time (without affecting prior lawful processing); and
• The right to lodge a complaint with a supervisory authority. A list of EEA supervisory authorities is available at edpb.europa.eu. UK residents may contact the Information Commissioner’s Office at ico.org.uk.

Dazzle, Inc. is the controller of personal information described in this Policy. To exercise your rights, contact hi@dazzle.tv. We are not currently required to appoint a Data Protection Officer or an EU/UK representative; if this changes, we will update this Policy.

12.4 Canada (PIPEDA)

If you are a Canadian resident, you may request access to and correction of your personal information and withdraw your consent to our processing, subject to legal and contractual restrictions. To exercise these rights, contact hi@dazzle.tv. You may also file a complaint with the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.

12.5 Brazil (LGPD)

If you are a Brazilian resident, you have rights under the Lei Geral de Proteção de Dados (“LGPD”) to confirm the existence of processing; access; correction; anonymization, blocking, or deletion of unnecessary data; data portability; deletion of data processed with consent; information about sharing; information about the possibility of refusing consent and the consequences of refusal; and withdrawal of consent. To exercise these rights, contact hi@dazzle.tv. You may also contact Brazil’s National Data Protection Authority (ANPD).

12.6 Australia (Privacy Act)

Australian users may contact us to access or correct personal information. Complaints may be addressed to the Office of the Australian Information Commissioner at www.oaic.gov.au.

13. Children

The Service is intended for users aged 13 and older. We do not knowingly collect personal information from children under 13 (or under the applicable minimum age in your jurisdiction, including 16 in some EEA jurisdictions). If you believe we have collected personal information from a child under 13, please contact us at hi@dazzle.tv and we will take steps to delete the information.

14. Third-Party Links and Services

The Service may contain links to third-party websites, applications, or services, and broadcasters or other users may include third-party links or content in their streams. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies.

15. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you by reasonable means (such as by email or by posting a notice within the Service) prior to the changes taking effect. Your continued use of the Service after the effective date of the updated Policy constitutes your acceptance of the changes.

16. Contact Us

If you have questions about this Policy or our privacy practices, contact us at:

Dazzle, Inc.
600 5th Avenue
Studio, Floor 2
New York, NY 10020
Email: hi@dazzle.tv
Website: www.dazzle.tv