Watchers™ is committed to doing business with the highest ethical standards and appropriate internal controls. Our Privacy Policy applies to all users of watchertcg.com (the “Site”). Out Terms of Service (“Terms”) is incorporated herein. All defined terms in the Privacy Policy shall have the same meaning as defined in the Terms. Watchers™ adheres to the following policies with regards to Your privacy.

1. Definitions
   1. “Non-Personal Information” is information that is in no way personally identifiable and that is obtained automatically through Your simple use of the Site with a web browser or the Service.
   2. “Personally Identifiable Information” is non-public information that is personally identifiable and obtained in connection with providing a product or service to you. It may include information such as name and address.
2. Information Collected

When you enter the Site, we collect non-personal information such as your browser type and IP address. Likewise, in order to offer you meaningful products and services and for other reasons, we may collect personally information about you from the following sources:

1. Information you give us on applications or other forms on the Site and/or Software; or
2. Information you send us via any medium, including, but not limited to email, telephone, and social media interaction; or
3. If you use a mobile device platform to access the Services or communicate with Watchers™, information transmitted from your mobile device; or
4. Information purchased from third parties.
5. Registration

In order to become a User (as defined in the Terms), You may be asked to provide us the following information to create an account: name, email address, mailing address, phone number, credit card information, and possibly more.

Watchers™ may request other information from you during or after the registration process that Watchers™ uses to provide better and more customized services to users. You acknowledge that this information is personal to you, and by creating an account on Watchers™, you may allow others, including Watchers™, to identify you and to allow Watchers™ to use your information in accordance with the Terms.

6. Customer Service

We collect information when you interact with Watchers’s customer service in order to accurately categorize and respond to customer inquiries and investigate breaches of Our terms.

7. Using Third Party Services and Visiting Third Party Sites

Information you provide to third-party sites/websites through the service are not within the control of Watchers™ and you provide such information at your own risk. The terms and conditions of use and the privacy policies of those websites that You provide information to through the Service will govern their use of such information. Any information You share with a third-party site through the Service will be collected by Watchers™. Watchers™ will use such information in compliance with this Privacy Policy.

8. Use of Cookies

The Site may send a “cookie” to Your computer. A cookie is a small piece of data that is sent to Your browser from a web server and stored on Your computer’s hard drive. A cookie cannot read data off Your hard disk or read cookie files created by other sites. Cookies do not damage Your system. Cookies allow us to recognize You as a user when You return to the Watchers™ website using the same computer and web browser. We use cookies to identify which areas of Our site You have visited, so the next time You visit the site, those pages may be readily accessible. We also may use this information to better personalize the content that You see on the Site. Most browser software can be set to reject Cookies. However, if You reject Our Cookies, certain functionality on the Site may not work correctly or at all. We do not link Non-Personal Information from Cookies to Your Personally Identifiable Information.

In the course of optimizing the Service to Our Users, we may allow authorized third parties to place or recognize a unique cookie on Your browser. Any information provided to third parties through cookies will not be personally identifiable, but may provide general segment information for the enhancement of Your user experience by providing more relevant advertising. Watchers™ does not store unencrypted personally identifiable information in the cookies.

If you send us notice that you object to our use of cookies, a “disagree” cookie will be stored in your browser and Watchers™ will not collect any session data. you can object to the collection and analysis of this anonymous data by emailing your request to opt out to privacy@watcherstcg.com.

9. Web Beacons

Watchers™ also may use web beacons, pixels, anonymous ad network tags, and cookies to collect Non-Personal Information about Your use of the Site and the websites of selected sponsors and advertisers, to collect anonymized, aggregated auditing, research and reporting for advertisers, and to collect data related to Your use of special promotions or newsletters. The information collected by Web Beacons also allows us to statistically monitor how many people open Our emails and for what purposes these actions are being taken. Our Web Beacons are not used to track Your activity outside of the Site or the websites of Our sponsors. We do not link Non-Personal Information from Web Beacons to Personally Identifiable Information without Your permission. However, because Your web browser requests advertisements and web beacons directly from ad network servers, these networks can view, edit or set their own cookies, just as if You had requested a web page from their site. If You are a non-registered Visitor to the Site, the only information We collect will be Non-Personal Information through the use of cookies or web beacons.

10. Log files, IP Addresses and information about Your computer and mobile device

Due to the communications standards on the internet, when You visit the site we automatically receive the URL of the site from which You came and the site to which You are going when You leave Watcher’s Site. Watchers™ also receives the internet protocol (“IP”) address of Your computer (or the proxy server You use to access the World Wide Web), Your computer operating system and type of web browser You are using, email patterns, your mobile device (including Your UDID) and mobile operating system (if You are accessing the Site using a mobile device), as well as the name of Your ISP or Your mobile carrier. Watchers™ may also receive location data passed to it from third-party services or GPS-enabled devices that You have enabled. Also, as described above in Section 2.D. Watchers™ receives information when You access third-party web pages through the Service. The link between Your IP address and your personally identifiable information is not shared with third parties without Your permission, except as described in Section 8. (“When We May Disclose Your Information”), below.

3. Do-Not-Track

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this Privacy Policy (e.g., by disabling cookies, or using ‘private’ browsing modes).

4. Exemptions from Privacy Policy

Our Privacy Policy does not apply to any information you may send to Watchers™ by email or instant messaging programs (i.e. AOL, Yahoo, etc.), as email and instant messages are not recognized as secure communication forms. As such, we request that you do not send any information, which you consider private, to us by email or instant message. Furthermore, Our Privacy Policy does not apply to any information you may post from our Software to other websites (i.e. Twitter, Facebook, etc.), due to the public nature of such postings.

5. Use of Personally Identifiable Information

Watchers™ uses and/or intends to use Personal Information to:

1. Operate and improve the Site;
2. Provide Users with the Service and other products and services that a User may request or that a User has expressed interest in;
3. Facilitate subscription processing, reviews and analysis;
4. Evaluate User interest and needs in order to improve the Service and make available other offers, products or services;
5. Evaluate the types of offers, products or services We make available to Users and potential Users;
6. Track use of the Services;
7. Provide customer support;
8. Communicate and provide additional information that may be of interest to Users through email or other means, such as special offers, announcements, and marketing materials;
9. Send You reminders, technical notices, updates, security alerts and support and administrative messages, service bulletins, or marketing;
10. Provide advertisements to You through email messages; and
11. Manage Our everyday business needs such as Site administration, forum management, fulfillment, analytics, fraud prevention, enforcement of Our corporate reporting obligations, Terms of Use or to comply with the law.

6. Links/Postings to Other Sites

The Site and/or Software may contain links to other websites. Watchers™ is not responsible for the actions, practices, or content of such websites linked to or from the Site and/or Software. You understand that such websites may have their own legal documents to which You must agree to prior to using and that We have no control over these legal documents. As always, you understand that it is Your responsibility to verify Your legal use of a website as well as use of information from the website with the corresponding website owner.

7. Market Research

Watchers™ may conduct online research surveys in order to gather feedback about the Site and opinions on important issues, through email invitations. When participating in a survey, we may ask You to submit Personally Identifiable Information. This Personally Identifiable Information is used for research purposes, and is not used for sales solicitations. Personally Identifiable Information collected through market research will be used only by Watchers™ and will not be given or sold to a third party without Your consent or as otherwise permitted by this Privacy Policy.

8. Use of Aggregate Data

Watchers™ may combine Non-Personal Information you provide through the Site with information from other users to create aggregate data that may be disclosed to third parties. Aggregate information does not contain any information that could be used to identify You and does not include Your personal contact information.

9. When We May Disclose Your Information

Except as set forth below or as specifically agreed to by you, Watchers™ will not disclose any Personally Identifiable Information as gathered from you on the Site.

1. We may share Personally Identifiable information in limited fashion to Our contractors and service providers that perform services on our behalf, including, but not limited to, operation of the Site technology, marketing services, and other related services. Unless you have opted-out (see Section 8.D. below) of such sharing, these contractors also may have access to your email address to send newsletters or special promotions to you on our behalf or to send emails to you for purposes such as conducting market research on our behalf. Access to your personally identifiable information by such contractors and service providers is limited to the information reasonably necessary for the contractor to perform its limited function for Watchers™. We also contractually require that such contractors and service providers: 1) protect the privacy of your personally identifiable information consistent with this Privacy Policy, and 2) not use or disclose your personally identifiable information for any purpose other than providing us with products and services as required by law.
2. We may share personally identifiable information we collect, as permitted by law, to companies such as credit reporting agencies, or servicing and processing companies, or when required or advised to do so in response to a valid legal requirement to release this information such as a state or federal law, regulation, search warrant, subpoena, or court order; or (2) in special cases, such as in response to a physical threat to you or others, to protect property, or defend or assert legal rights, to defend ourselves in litigation. In the event that we are legally compelled to disclose your personally identifiable information to a third party, we will attempt to notify you unless doing so would violate the law or court order.
3. Finally, Watchers™ may provide content and services to you through websites other than our own. Watchers™ will not disclose your personally identifiable information to these 3rd party websites without your consent, but you should be aware that any information you disclose on such sites is NOT subject to this Privacy Policy.
4. If you prefer that we do not share certain information with our contractors and service provider, as described above, you can direct us not to share that information by contacting us (support@watcherstcg.com). Please note that an opt-out with respect to information sharing will not apply to information sharing arrangements described Sections 8.A, B or C.
5. You may request that we provide you with a list of third-parties we have shared your personal data with by contacting us at support@watcherstcg.com.

If your access to the service is terminated based upon your request that we do not share your personal data with a third-party and that requests results in your inability to use some or all of the service, your resulting inability to use the service shall not be a basis for a refund or to avoid charges for the service that you previously agreed to.

10. Access, Correction and Deletion of Personally Identifiable Data

You may request access to a report of the personally identifiable information we maintain concerning your use of the service and you may request that the personally identifiable information that we have collected and maintain be corrected or deleted. In order to make this request, please contact us at support@watcherstcg.com. Please be aware that if you request that we delete your personally identifiable information, you may no longer have access to the Service. If your access to the service is terminated based upon your request that we delete your personally identifiable information, please be advised that your resulting inability to use the service shall not be a basis for a refund or to avoid charges for the service that you previously agreed to.

11. Security Policy & User ID/Password

Our site utilizes various information security measures such as internet firewalls, an intrusion detection system, encrypted data transmission, and operating procedures to protect your personal data, accounts, passwords, etc. This information is kept completely separate and confidential, unless you have given someone else your user ID and password. As such, you should protect your user ID and password and NOT share it with anyone. If you believe your user ID and password have been compromised and you have trouble changing your user ID/password on the site or within the application, please contact our technical support department (support@watcherstcg.com).

12. CAN-SPAM Compliance Notice

Watchers™ and its affiliates fully comply with the federal CAN-SPAM Act. You can always opt out of receipt of further email correspondence from us.

13. Transfer of Ownership

If the entire or substantial ownership of the Site were to change, your user information may be transferred to the new owner so the service can continue operations. In any such transfer of information, your user information would remain subject to the promises of Our then current Privacy Policy.

14. Notice to Residents of Countries outside of the United States of America

Watchers™ is headquartered in the United States of America. Personal information may be accessed by us or transferred to us in the United States or to our affiliates, business partners, merchants, or service providers elsewhere in the world. By providing us with personally identifiable information, you consent to this transfer in compliance with applicable law (in the case of data transfers from the EEA or Switzerland, these data transfers are covered under the EU Safe Harbor Framework). We will protect the privacy and security of personally identifiable information according to our Privacy Policy, regardless of where it is processed or stored.

15. California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personally identifiable information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of personally identifiable information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Watchers™ pursuant to Section 1798.83 of the California Civil Code, please contact us via email to support@watchers.com.

16. EU Safe Harbor & Switzerland Safe Harbor

To the extent required by applicable statute related to your use of the site and/or the Services, we comply with the US-EU Safe Harbor Framework and US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. We have certified that we adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit www.export.gov/safeharbor.

On October 6, 2015, the European Court of Justice issued a judgment declaring as “invalid” the European Commission’s Decision 2000/520/EC of 26 July 2000 “on the adequacy of the protection provided by the safe harbor privacy principles and related frequently asked questions issued by the US Department of Commerce.”

Watchers will continue to abide by the Safe Harbor principles. In light of the ECJ’s decision, however, please be advised that transferring data to the United States under Safe Harbor is no longer adequate. If you relied on our Safe Harbor certification to send data from Europe to us, please contact us to discuss an alternative data transfer mechanism.

17. BBB EU Safe Harbor Program: Privacy Complaints by EU & Swiss Citizens

To the extent required by applicable statute related to your use of the Site and/or the Services, in compliance with the US-EU and US-Swiss Safe Harbor Principles, Watchers™, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Us at support@watcherstcg.com.

To the extent required by applicable statute related to your use of the Site and/or the services, we have further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Watchers Inc., please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

18. Information and Other Rights, Contact

Upon written request, we would be happy to provide you with information as to whether – and if so, which – personal data Ww store in relation to you. Should your personal data be incorrect, you may have this rectified immediately. Any such information or modification is free of charge.

Moreover, you are entitled to revoke your consent to use of data in the future, in whole or in part. Should you desire this, we will delete or block your relevant data; however, doing so may result in your inability to use the Service in whole or in part.

In order to assert such rights, please contact Watchers at privacy@watcherstcg.com.

19. Watcher’s Access to Your Account

You agree that Watchers™ can access your account information in order to respond to your service requests and/or as necessary, in our sole discretion, to provide you with the Services.

20. Your Acceptance of This Privacy Policy

This is our entire Privacy Policy and it supersedes any earlier version. You agree to it every time you use the Site and/or Software.

If we make any material changes to this Privacy Policy, We will notify you by email or by posting a prominent notice on the Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Site or Service constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Site and Service.

21. Questions About This Privacy Policy

Should You have a privacy question about the Site and/or Software, please email our customer service department (support@watcherstcg.com).

Infrastructure

Watchers utilizes both cloud and physical servers in our infrastructure. Our cloud is provisioned by a well-known top tier provider. Our physical servers are located in Tier-4 datacenters with full power, cooling, and network redundancy.

Security

We value your data, and we work hard to protect it. We store it on multiple hosts in multiple locations and back it up regularly, as often as four times per day per datastore. Data stored on our physical servers is protected by biometric locks, multiple layers of access security, and 24×7 interior and exterior surveillance.

Host Security

Only our Engineering team has access to our production environment. SSH keys or Kerberos tokens are required for console access to servers in all our environments. We have automated processes in place that monitor each host for unauthorized login attempts, and offending IP addresses are automatically blacklisted and alerted.

Data Rights

Watchers uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run Watchers. Although Watchers owns the code, databases, and all rights to the Watchers application, you retain all rights to your data.

How to Contact Watchers about Security Questions

support@watcherstcg.com

How to Report a Security Incident

To report an incident of suspected abuse, misuse, or a security issue you have discovered please contact us at support@watcherstcg.com

Thank You