Privacy Policy

This Privacy Notice for Mahjong Meetup LLC (doing business as Hoptoi) ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at mahjongmeetup.com, or any website of ours that links to this Privacy Notice
• Download and use our mobile application (Hoptoi), or any other application of ours that links to this Privacy Notice
• Use Hoptoi. Hoptoi is a mobile application and digital platform designed to help users connect, schedule, and organize local, in-person mahjong games and events. The app allows users to create profiles, discover nearby players, coordinate match times, and manage group communications. The platform offers premium features, interactive location-based services via mapping APIs, and secure transaction processing for in-app subscriptions and service upgrades
• Engage with us in other related ways, including any marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@mahjongmeetup.com.

Summary of Key Points

1. What Information Do We Collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal information provided by you. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names
• Email addresses
• Usernames
• Passwords
• Phone numbers
• Location / geolocation data
• Winning history and previous opponents

Sensitive information. We do not process sensitive information.

Payment data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is handled and stored by the Apple App Store, Google Play Store, and RevenueCat, Inc. You may find their privacy notices here: Apple, Google, and RevenueCat.

Application data. If you use our application(s), we may also collect the following information if you choose to provide us with access or permission:

• Geolocation information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. You can change our access or permissions in your device's settings.
• Mobile device data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, internet service provider and/or mobile carrier, and IP address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device's operating system or platform, the type of mobile device you use, your mobile device's unique device ID, and information about the features of our application(s) you accessed.
• Push notifications. We may send you push notifications regarding your account or certain features of the application(s). You can turn these off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In short: Some information, such as your IP address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

• Log and usage data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services, recorded in log files. Depending on how you interact with us, this may include your IP address, device information, browser type and settings, information about your activity in the Services (such as date/time stamps, pages and files viewed, searches, and other actions), and device event information (such as system activity, error reports, and hardware settings).
• Device data. Information about the computer, phone, tablet, or other device you use to access the Services, including your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location data. Information about your device's location, which can be precise or imprecise. We may use GPS and other technologies to collect geolocation data based on your IP address. You can opt out by refusing access to this information or disabling your location settings, though doing so may limit certain features of the Services.

Google API. Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

2. How Do We Process Your Information?

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including to:

• Facilitate account creation and authentication and otherwise manage user accounts, so you can create and log in to your account and keep it in working order.
• Deliver and facilitate delivery of services you have requested.
• Respond to user inquiries and offer support to resolve issues with the requested service.
• Send administrative information such as details about our products and Services, changes to our terms and policies, and similar information.
• Fulfill and manage orders, payments, returns, and exchanges made through the Services.
• Enable user-to-user communications, if you choose to use offerings that allow communication with another user.
• Request feedback and contact you about your use of our Services.
• Protect our Services, including fraud monitoring and prevention.
• Identify usage trends to better understand how our Services are used so we can improve them.
• Save or protect an individual's vital interest, such as to prevent harm.
• Customize or personalize your experience based on location, such as finding local mahjong meetups nearby.

3. What Legal Bases Do We Rely On?

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law, such as your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. These may include:

• Consent. We may process your information if you have given us permission to use it for a specific purpose. You can withdraw your consent at any time.
• Performance of a contract. We may process your information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, such as to analyze how our Services are used so we can improve them, diagnose problems and prevent fraudulent activity, and understand how our users use our products so we can improve user experience.
• Legal obligations. We may process your information where necessary for compliance with our legal obligations, such as cooperating with a law enforcement body or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in litigation in which we are involved.
• Vital interests. We may process your information where necessary to protect your vital interests or those of a third party, such as situations involving potential threats to safety.

If you are located in Canada

We may process your information if you have given us specific permission (express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions, provided certain conditions are met
• If contained in a witness statement and necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
• If it is reasonable to expect that collection with consent would compromise the availability or accuracy of information, and collection is reasonable for investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of court relating to the production of records
• If produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which it was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and specified by the regulations
• We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments

4. When Do We Share Your Information?

In short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, consultants, and other third-party service providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with these third parties designed to safeguard your personal information; they cannot use your personal information except as we instruct, will not share it with anyone else, and commit to protect it and retain it only for the period we instruct.

The categories of third parties we may share personal information with include:

• Cloud computing services
• Data analytics services
• Data storage service providers
• Payment processors
• Performance monitoring tools
• User account registration and authentication services
• Website hosting service providers

We may also need to share your personal information in the following situations:

• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (such as the Google Maps API and Places API) to retrieve information when you make location-specific requests, including your geolocation data and device location details. Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location; GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, such as indoors. This data helps Google Maps provide directions but is not always perfectly precise. The Google Maps Platform APIs we use store and access cookies and other information on your devices. If you are located in the European Economic Area, Iceland, Liechtenstein, Norway, or the United Kingdom, please also see our Cookie Policy.
• Business partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Other users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, that information may be viewed by all users and may be made publicly available outside the Services in perpetuity. Other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

5. Cookies & Tracking Technologies

In short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, tailor advertisements to your interests, or send abandoned shopping cart reminders, depending on your communication preferences. These third parties use their technology to provide advertising about products and services tailored to your interests, which may appear on our Services or on other websites.

To the extent these online tracking technologies are deemed a "sale" or "sharing" (which includes targeted advertising as defined under applicable laws) under applicable US state laws, you can opt out as described in section 12 below.

Specific information about how we use these technologies and how you can refuse certain cookies is set out in our Cookie Policy.

Google Analytics. We may share your information with Google Analytics to track and analyze use of the Services. To opt out of being tracked by Google Analytics, visit the Google Analytics opt-out page. For more on Google's privacy practices, see the Google Privacy & Terms page.

6. International Transfers

In short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the United States. Regardless of your location, your information may be transferred to, stored by, and processed by us and the third parties with whom we may share your personal information (see section 4), including in facilities in the United States and other countries.

If you are a resident of the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, these countries may not have data protection laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses. We have implemented measures to protect your personal information, including using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require recipients to protect personal information originating from the EEA or UK in accordance with European data protection laws. Our Standard Contractual Clauses, and details of similar safeguards with third-party providers and partners, can be provided upon request.

7. How Long Do We Keep Your Information?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice, unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us to keep your personal information for longer than the period of time in which you have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if that is not possible (for example, because it has been stored in backup archives), we will securely store it and isolate it from further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

In short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly access, steal, or modify your information. Transmission of personal information to and from our Services is at your own risk; you should only access the Services within a secure environment.

9. Do We Collect Information from Minors?

In short: We do not knowingly collect data from or market to children under 18 years of age, or the equivalent minimum age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age (or the equivalent age as specified by law in your jurisdiction), nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18, or the equivalent age as specified by law in your jurisdiction, or that you are the parent or guardian of such a minor and consent to that minor dependent's use of the Services. If we learn that personal information from users under the relevant age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the relevant age, please contact us at hello@mahjongmeetup.com.

10. What Are Your Privacy Rights?

In short: Depending on your state of residence in the US or in some regions, such as the EEA, UK, Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right to: (i) request access to and obtain a copy of your personal information; (ii) request rectification or erasure; (iii) restrict the processing of your personal information; (iv) where applicable, data portability; and (v) not be subject to automated decision-making. If a decision producing legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request using the contact details in section 15.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to complain to your Member State or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent. If we are relying on your consent (express or implied) to process your personal information, you have the right to withdraw it at any time using the contact details in section 15 or by updating your preferences. Withdrawing consent will not affect the lawfulness of processing before the withdrawal, nor processing carried out in reliance on lawful bases other than consent.

Account information

If you would like to review or change the information in your account, or terminate your account, you can log in to your account settings and update your account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. We may, however, retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our legal terms, and/or comply with applicable legal requirements.

Cookies and similar technologies. Most web browsers accept cookies by default. You can usually set your browser to remove or reject cookies, though doing so could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at hello@mahjongmeetup.com.

11. Do-Not-Track Features

Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow, we will inform you in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there is currently no industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. US Resident Privacy Rights

In short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not necessarily reflect the personal information we collect from you specifically. For a full inventory, see section 1.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of receiving help through our customer support channels, participating in customer surveys or contests, and facilitating delivery of our Services and responding to your inquiries.

We use and retain collected personal information as needed to provide the Services. Categories A, B, D, F, G, and H are retained for as long as you have an account with us.

How we use and share personal information

Learn more about the sources of personal information we collect in section 1 and how we use it in section 2.

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. Learn more in section 4.

We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered "selling" of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months: Category A (Identifiers), Category B (California Customer Records), Category D (Commercial information), Category F (Internet or network activity), Category G (Geolocation data), and Category H (Audio, electronic, visual, and similar information). The categories of third parties to whom we disclosed this information can be found in section 4.

Your rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. These rights include the right to:

• Know whether or not we are processing your personal data
• Access your personal data
• Correct inaccuracies in your personal data
• Request the deletion of your personal data
• Obtain a copy of the personal data you previously shared with us
• Non-discrimination for exercising your rights
• Opt out of the processing of your personal data if it is used for targeted advertising (or sharing, as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending on the state where you live, you may also have the right to:

• Access the categories of personal data being processed (as permitted by applicable law, including in Minnesota)
• Obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including in California, Delaware, and Maryland)
• Obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including in Minnesota and Oregon)
• Obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including in Connecticut)
• Review, understand, question, and, depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including in Connecticut and Minnesota)
• Limit use and disclosure of sensitive personal data (as permitted by applicable law, including in California)
• Opt out of the collection of sensitive data and personal data collected through a voice or facial recognition feature (as permitted by applicable law, including in Florida)

How to exercise your rights

To exercise these rights, you can contact us by emailing us at hello@mahjongmeetup.com or by referring to the contact details in section 15.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request verification

Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we have information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from information already maintained by us, we may request additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity, and the agent will need to provide written and signed permission from you to submit the request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at hello@mahjongmeetup.com. We will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for our decision. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine the Light" law

California Civil Code Section 1798.83, also known as the "Shine the Light" law, permits California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit it in writing to us using the contact details in section 15.

13. Other Regions' Privacy Rights

In short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020.

This Privacy Notice satisfies the notice requirements defined under both Privacy Acts, including what personal information we collect from you, the sources we collect it from, the purposes for which we collect it, and the other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill the applicable purpose, it may affect our ability to provide our services, including to:

• Offer you the products or services that you want
• Respond to or help with your requests
• Manage your account with us
• Confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request using the contact details in section 16.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner, or a breach of New Zealand's Privacy Principles to the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request using the contact details in section 16.

If you are unsatisfied with how we address any complaint regarding our processing of personal information, you can contact the Information Regulator (South Africa):

• General enquiries: enquiries@inforegulator.org.za
• Complaints (POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

14. Updates to This Notice

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes, we may notify you by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to stay informed of how we are protecting your information.

15. Contact Us

If you have questions or comments about this notice, you may email us at hello@mahjongmeetup.com or contact us by post at:

Mahjong Meetup LLC
PO Box 61961
Ft. Myers, FL 33906
United States

16. Review, Update, or Delete Your Data

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at hello@mahjongmeetup.com.