Privacy Policy

Effective date: September 1, 2021

Sixty Four Squares, LLC (“Sixty Four Squares”, "us", "we", or "our") operates the sixtyfoursquares.com website (the "Service").

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Definitions

Service

Service means the sixtyfoursquares.com website and, including all its components.

Personal Data

Personal Data means data about a living individual who can be identified from that data (or from that and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information is, or is to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor means any natural or legal person, including Service Providers, who processes the data on behalf of the Data Controller. We may use the services of various Data Processors in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

Required Information (Sixty Four Squares username and an email address)
Optional Information (First name, last name, and other personal descriptors)
Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amounts of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies.
We use Session Cookies to keep you logged into our Service.
Preference Cookies.
We use Preference Cookies to remember your preferences and various settings.
Security Cookies.
We use Security Cookies for security purposes.

Use of Data

Sixty Four Squares uses the collected data for various purposes:

To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Service
To monitor the usage of our Service
To detect, prevent and address technical issues
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
To conduct research, and provide aggregated, anonymized reporting about our general user community for internal and external clients.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Sixty Four Squares legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. Sixty Four Squares may process your Personal Data because:

We need to perform a contract with you
You have given us permission to do so
For payment processing purposes
To comply with the law

Retention of Data

Sixty Four Squares will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Sixty Four Squares will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Sixty Four Squares will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Retention of Data

Disclosure of Data

Business Transaction

If Sixty Four Squares is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Sixty Four Squares may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Sixty Four Squares may disclose your Personal Data in the good faith belief that such action is necessary to:

To comply with a legal obligation
To protect and defend the rights or property of Sixty Four Squares
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

"Do Not Track" Signals

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Sixty Four Squares aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

You can edit your Sixty Four Squares account information at any time. In certain circumstances, you have the following data protection rights:

The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Sixty Four Squares relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers

We may employ third party companies and individuals to facilitate our Service ("Service Providers"), including Data Processors, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Sixty Four Squares does not target anyone under the age of 18 ("Children") for use of our Service.

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this notice.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. For purposes of the Privacy Notice for California Residents, personal information includes "Personal Data", "Usage Data", and "Cookies" as those terms are defined in this Privacy Policy. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months that is not otherwise subject to an exception under the CCPA.

Deletion Request Rights

You also have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

Email: info@sixtyfoursquares.com

Postal Address:

Sixty Four Squares

857 Post Road, Box 185

Fairfield, CT 06824

To be verifiable your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

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. You may also make a verifiable consumer request on behalf of your minor child.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: (i) deny you goods or services; (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; (iii) provide you a different level or quality of goods or services; or (iv) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Selling Your Personal Information

We do not sell, and have not sold your personal information to third parties for a business or commercial purpose in the 12 months preceding the effective date of this Privacy Policy, as we understand the term “sell” to mean under the CCPA.

Personal Information we Collect, Use and Disclose

The CCPA specifies categories of personal information protected under the CCPA. The following chart provides information about the personal information we collect relative to each category and the sources from which we collect such data. For additional information regarding the personal information we collect and have collected in the 12 months preceding the effective date of our Privacy Policy see the heading "Types of Data Collected" of our Privacy Policy. We may use personal information for the business/commercial purposes described under the heading "Use of Data" of our Privacy Policy. For information about how we share your personal information see the headings "Disclosure of Data", "Service Providers", "Analytics" and "Advertising" of our Privacy Policy.

Personal Information Category	PI we collect in this Category	Sources of PI
A. Identifiers	A real name or alias Age Gender Internet Protocol address(es) Email address Account name (username), or other similar identifier Mobile push tokens Specific third-party identifiers relating to chess services (e.g., USCF or FIDE ID number) may be collected for some accounts	Information you provide us Information we collect from you automatically 3rd Party Service Provider
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	• not applicable	• not applicable
C. Protected classification characteristics under California or federal law	• not applicable	• not applicable
D. Commercial information	• not applicable	• not applicable
E. Biometric information	• not applicable	• not applicable
F. Internet or other similar network activity	• Browsing history on sixtfoursquares.com only	Information we collect from you automatically 3rd Party Service Provider
G. Geolocation data	• not applicable	• not applicable
H. Sensory data	• not applicable	• not applicable
I. Professional or employment-related information	• not applicable	• not applicable
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	• not applicable	• not applicable
K. Inferences drawn from other personal information	• not applicable	• not applicable

CONTACT INFORMATION

If you have any questions or comments about this notice or the ways in which Sixty Four Squares collects and uses your information as described in the Privacy Policy or you wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: info@sixtyfoursquares.com

Postal Address:

Sixty Four Squares

857 Post Road, Box 185

Fairfield, CT 06824

CHANGES TO THIS PRIVACY POLICY NOTICE

We reserve the right to amend our Privacy Policy at our discretion and at any time. When we make changes to our Privacy Policy, we will (i) let you know via email and/or a prominent notice on our Services and (ii) post the updated Privacy Policy on the website and update the Privacy Policy's effective date. You are advised to review this Privacy Policy periodically for any changes.

Your continued use of our website following the posting of changes constitutes your acceptance of such changes.