Privacy Policy

Privacy
Policy

TitleScreen LLC ("we," "us," or "our") operates the online marketplace located at titlescreen.com and related services (collectively, the "Service"). This Privacy Policy explains how we collect, use, disclose, and protect information about individuals ("you" or "your") who visit or use the Service, and describes your rights and choices.

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, you must not use the Service.

We may update this Privacy Policy from time to time as described in Section 14 below.

Scope and Roles
Information We Collect
How We Use Personal Information
How We Disclose Personal Information
International Data Transfers
Data Retention
Cookies and Similar Technologies
Security
Children's Privacy
Your Choices and Rights
Additional Information for California Residents
Additional Information for EEA/UK/Swiss Residents
Additional Information for Other U.S. States
Changes to This Privacy Policy
Contact Us

1. Scope and Roles

1.1 Scope. This Privacy Policy applies to information we process about:

(a) visitors to our website;
(b) registered users of the Service, including Sellers and Buyers; and
(c) individuals who communicate with us or otherwise interact with the Service.

1.2 Controller / Business. For purposes of:

(a) EU/EEA/UK data protection laws (e.g., GDPR), we are the "controller" of personal data we collect and process under this Privacy Policy; and
(b) California and other U.S. state privacy laws, we act as a "business" (or equivalent term) with respect to the personal information we collect and determine the purposes and means of processing.

1.3 Marketplace Role. We provide a platform that enables Sellers and Buyers to connect and transact. We are not responsible for privacy practices of Sellers or Buyers acting independently of us; they are responsible for complying with applicable privacy laws in their own processing of your information.

2. Information We Collect

We collect information that identifies, relates to, describes, or can reasonably be linked to an individual ("Personal Information"). The categories of Personal Information we collect depend on how you use the Service.

2.1 Information You Provide Directly.

(a) Account and Profile Information. Name, username, password, email address, country or region, and optional profile details (e.g., avatar, bio, company name, role).
(b) Seller and Buyer Information. Information related to your use of the marketplace, such as portfolio links, game descriptions, company details, payment preferences, and communications with other users.
(c) Transaction-Related Information. Information you provide when negotiating or concluding transactions via the Service (e.g., deal terms summaries, non-confidential elements of your listings, messages to other users).
(d) Payment Information. If you pay us fees (e.g., listing or marketplace fees), we or our payment processors collect billing details, such as name, billing address, payment card number, bank account or other payment data. Payment card details are typically processed directly by our third-party payment processors and not stored in full by us.
(e) Communications. Information contained in your communications with us (e.g., support requests, feedback, email correspondence) and in communications you send through the Service (e.g., messages between Sellers and Buyers to the extent routed via our systems).

2.2 Information Collected Automatically. When you use the Service, we automatically collect certain information, including:

(a) Device and Usage Information. IP address, device identifiers, browser type, operating system, referring URLs, pages viewed, links clicked, approximate location (based on IP), and timestamps.
(b) Cookies and Similar Technologies. We use cookies, web beacons, and similar technologies to operate and improve the Service, remember your preferences, analyze usage, and personalize content. For more information, see Section 7 (Cookies and Tracking).

2.3 Information from Third Parties. We may receive information about you from:

(a) Third-Party Accounts. If you choose to sign in or connect via a third-party account (e.g., GitHub, Google), we may receive basic profile information as authorized by that provider.
(b) Service Providers and Partners. Payment processors, analytics providers, anti-fraud services, and integration partners may provide us with information related to your use of their services in connection with the Service.
(c) Other Users. Sellers and Buyers may provide information about you (e.g., your business contact details or content you created) in connection with marketplace activities.

2.4 Sensitive Information. We do not seek to collect sensitive personal information (such as health data, precise geolocation, or biometric identifiers) through the Service, and you should not provide it. If you do so, you do so voluntarily and at your own risk, and we will process it in accordance with this Privacy Policy and applicable law.

3. How We Use Personal Information

We use Personal Information for the following purposes and legal bases:

3.1 To Provide and Operate the Service.

(a) Creating and managing your account;
(b) Enabling listings, searches, messaging, and other marketplace features;
(c) Processing payments for Marketplace Fees and other charges;
(d) Providing customer support and responding to your requests.

Legal bases (where applicable): performance of a contract, legitimate interests (to operate our business), and, when required, consent.

3.2 To Facilitate Marketplace Interactions.

(a) Displaying your listings and profile information;
(b) Enabling communications between Sellers and Buyers;
(c) Supporting negotiation and tracking of transactions initiated via the Service.

Legal bases: performance of a contract, legitimate interests.

3.3 To Improve and Develop the Service.

(a) Analyzing usage and performance of the Service;
(b) Developing new features, products, and services;
(c) Debugging and repairing errors.

Legal bases: legitimate interests (to improve our services).

3.4 To Personalize the Service.

(a) Customizing content and recommendations;
(b) Remembering your preferences and settings.

Legal bases: legitimate interests and, where required, consent (e.g., for certain cookies).

3.5 To Communicate with You.

(a) Sending administrative messages (e.g., account notices, changes to our terms and policies, security alerts);
(b) Sending transactional or marketplace-related messages;
(c) Providing marketing or promotional communications (subject to your choices; see Section 10).

Legal bases: performance of a contract, legitimate interests, and, where required, consent (e.g., email marketing).

3.6 To Protect Security and Prevent Abuse.

(a) Monitoring for and preventing fraud, abuse, and security incidents;
(b) Enforcing our Terms of Service and other policies;
(c) Protecting our rights, property, users, and the public.

Legal bases: legitimate interests, compliance with legal obligations.

3.7 To Comply with Legal Obligations.

(a) Responding to lawful requests and legal process;
(b) Keeping records required by law;
(c) Complying with applicable laws, including tax, accounting, and sanctions/export control laws.

Legal bases: compliance with legal obligations.

3.8 With Your Consent. We may use your information for any other purpose that we disclose at the time of collection and that you consent to.

4. How We Disclose Personal Information

We may disclose Personal Information as described below, in accordance with applicable law.

4.1 Service Providers. We share Personal Information with third-party vendors, consultants, and other service providers that perform services on our behalf, such as:

(a) hosting and infrastructure;
(b) payment processing;
(c) analytics and usage measurement;
(d) customer support;
(e) email delivery and communications tools;
(f) security and anti-fraud services.

These service providers are authorized to use Personal Information only as necessary to provide services to us and are subject to appropriate contractual obligations.

4.2 Other Users of the Service.

(a) Public Information. Certain profile elements and listing content you choose to provide may be visible to other users or to the public, consistent with the functionality of the Service (e.g., your display name, bio, game descriptions, images).
(b) Direct Interactions. When you communicate or transact with other users (e.g., Sellers and Buyers), they may receive Personal Information about you that you choose to share or that is necessary for the transaction (e.g., contact information, company information).

4.3 Affiliates and Corporate Transactions. We may disclose Personal Information to our affiliates for purposes consistent with this Privacy Policy. We may also disclose or transfer Personal Information in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction.

4.4 Legal and Safety. We may disclose Personal Information if we believe in good faith that such disclosure is reasonably necessary to:

(a) comply with any applicable law, regulation, legal process, or governmental request;
(b) enforce our Terms of Service or other agreements;
(c) protect the rights, property, or safety of us, our users, or others;
(d) detect, prevent, or otherwise address fraud, security, or technical issues.

4.5 With Your Consent. We may disclose Personal Information for any other purpose disclosed at the time of collection and with your consent.

4.6 De-identified or Aggregated Data. We may use and disclose de-identified or aggregated information that does not reasonably identify you for any lawful purpose.

5. International Data Transfers

5.1 United States and Other Jurisdictions. We are based in the United States and the information we collect is processed in the United States and other countries. These countries may have data-protection laws that are different from those in your country of residence and may not be deemed to provide an equivalent level of protection.

5.2 Data Transfers from the EEA/UK/Switzerland. If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we will protect your Personal Information when it is transferred outside of those regions by:

(a) relying on an adequacy decision by the European Commission, UK Government, or Swiss authorities (where applicable); and/or
(b) implementing appropriate safeguards such as Standard Contractual Clauses approved by the European Commission (and any UK or Swiss addenda, as applicable).

You may contact us using the details in Section 15 to obtain more information about the safeguards we use for international transfers.

6. Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law, including for:

(a) providing and improving the Service;
(b) maintaining business and financial records;
(c) resolving disputes and enforcing our agreements;
(d) complying with legal obligations.

We may retain de-identified or aggregated information indefinitely.

7. Cookies and Similar Technologies

7.1 What Are Cookies? Cookies are small text files stored on your device that allow us or third parties to recognize your browser and collect certain information.

7.2 Types of Cookies We Use.

(a) Strictly Necessary Cookies. Required for the operation of the Service (e.g., to keep you logged in, to provide basic security).
(b) Functional Cookies. Help remember your preferences and settings.
(c) Analytics Cookies. Help us understand how the Service is used so we can improve it (e.g., page views, session duration).
(d) Advertising / Marketing Cookies (if used). Help deliver relevant ads or measure the effectiveness of advertising campaigns.

7.3 Your Choices.

(a) Browser Settings. Most web browsers allow you to control cookies through their settings. If you disable cookies, some features of the Service may not work properly.
(b) Additional Controls. Where required by law (e.g., in certain EEA/UK contexts), we will provide a cookie banner or similar mechanism allowing you to manage non-essential cookies.

For more details, we may provide a separate cookie notice or tool accessible through the Service.

8. Security

We use reasonable administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, destruction, loss, alteration, or misuse. However, no system or transmission is completely secure, and we cannot guarantee absolute security of your information.

You are responsible for keeping your account credentials confidential and for notifying us promptly of any actual or suspected unauthorized access to your account.

9. Children's Privacy

The Service is not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under 13 (or a higher age threshold where required by local law). If we become aware that we have collected Personal Information from a child in violation of applicable law, we will take steps to delete it. If you believe we may have collected information from a child, please contact us using the details in Section 15.

10. Your Choices and Rights

Depending on your location and applicable law, you may have certain rights and choices regarding your Personal Information.

10.1 Account Information. You can review and update certain account information by logging into your account settings.

10.2 Marketing Communications. You may opt out of receiving marketing emails by following the unsubscribe instructions in those emails or by contacting us. You may continue to receive transactional or service-related messages.

10.3 Do Not Track. Some browsers include a "Do Not Track" (DNT) setting. At this time, we do not respond to DNT signals, as there is no agreed-upon standard for doing so.

11. Additional Information for California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), provides you with specific rights regarding your Personal Information (as defined by those laws).

11.1 Categories of Personal Information Collected. In the 12 months preceding the effective date of this Privacy Policy, we may have collected the following categories of Personal Information, as defined by California law:

(a) Identifiers (e.g., name, username, email address, IP address, device identifiers);
(b) Customer records information (e.g., billing address, payment information – processed primarily by our payment processors);
(c) Commercial information (e.g., records of purchases, fees paid, transaction-related information as visible to us);
(d) Internet or other electronic network activity information (e.g., browsing history, usage data, log data);
(e) Geolocation data (approximate location based on IP address);
(f) Professional or employment-related information (e.g., if you provide company role/title);
(g) Inferences drawn from the above (e.g., to personalize content or understand usage).

We do not intend to collect "sensitive personal information" as defined under California law, and if we do, we use it only for purposes permitted by law.

11.2 Sources of Personal Information. We obtain these categories of Personal Information from the sources described in Section 2.

11.3 Business and Commercial Purposes. We use Personal Information for the purposes described in Section 3.

11.4 Disclosure of Personal Information. We may disclose the categories of Personal Information listed in Section 11.1 to the categories of recipients described in Section 4 for business purposes.

11.5 "Sale" or "Sharing" of Personal Information.

(a) We do not sell Personal Information for money.
(b) We may engage in certain online advertising practices that could be considered a "sale" or "sharing" of Personal Information under California law (e.g., using third-party cookies for cross-context behavioral advertising).
(c) Where required, we will provide a mechanism for California residents to opt out of such "sale" or "sharing," such as a "Do Not Sell or Share My Personal Information" link.

11.6 Your California Privacy Rights. Subject to certain exceptions, California residents may have the right to:

(a) Know / Access. Request access to specific pieces of Personal Information we have collected about you and information about our data practices;
(b) Correction. Request that we correct inaccurate Personal Information;
(c) Deletion. Request that we delete Personal Information we have collected from you;
(d) Opt-Out of Sale or Sharing. Opt out of the sale or sharing of Personal Information for cross-context behavioral advertising;
(e) Limit Use of Sensitive Personal Information. If we process sensitive Personal Information beyond permitted purposes, limit such use and disclosure;
(f) Non-Discrimination. Not be discriminated against for exercising your rights.

11.7 Exercising Your California Rights.

(a) You may exercise your rights by contacting us as described in Section 15 and specifying your request (e.g., access, deletion, correction, opt-out).
(b) We may take reasonable steps to verify your identity before responding (e.g., by verifying information you provide against information we hold).
(c) You may designate an authorized agent to make requests on your behalf, subject to verification of the agent's authority and your identity.

12. Additional Information for EEA/UK/Swiss Residents

If you are located in the EEA, UK, or Switzerland, you have the following rights with respect to your Personal Data (as defined under applicable law), subject to certain conditions and limitations:

12.1 Rights.

(a) Access. Request access to the Personal Data we hold about you.
(b) Rectification. Request that we correct inaccurate or incomplete Personal Data.
(c) Erasure. Request deletion of your Personal Data in certain circumstances.
(d) Restriction. Request restriction of processing of your Personal Data in certain circumstances.
(e) Portability. Request to receive your Personal Data in a structured, commonly used, and machine-readable format and have it transmitted to another controller, where technically feasible.
(f) Objection. Object to our processing of your Personal Data where we rely on legitimate interests, including for direct marketing.
(g) Withdrawal of Consent. Where processing is based on your consent, withdraw your consent at any time (without affecting the lawfulness of processing before withdrawal).

12.2 Exercising Your Rights. You may exercise these rights by contacting us as described in Section 15. We will respond in accordance with applicable law.

12.3 Complaints. You also have the right to lodge a complaint with a data protection authority, such as the supervisory authority in your country of residence or where you believe an infringement occurred.

13. Additional Information for Other U.S. States

Residents of certain U.S. states (such as Virginia, Colorado, Connecticut, Utah, and potentially Illinois if applicable laws are enacted or updated) may have privacy rights similar to those described for California or EEA/UK residents, including rights to access, correct, delete, and opt out of certain processing such as targeted advertising or sales of personal data.

To the extent required by applicable law in your state, you may exercise such rights by contacting us as described in Section 15, and we will respond in accordance with the relevant state law. If we deny your request, you may have the right to appeal our decision; instructions for appeal will be provided where required by law.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice by updating the "Last Updated" date at the end of this Policy and, where appropriate, by providing additional notice (e.g., by email or through the Service). Your continued use of the Service after the effective date of any changes indicates your acceptance of the revised Privacy Policy.

15. Contact Us

If you have any questions or concerns about this Privacy Policy, or wish to exercise your rights, please contact us at:

TitleScreen LLC
Attn: Privacy
[ADDRESS]
Email: support@titlescreen.com

If you are a resident of the EEA, UK, or Switzerland, you may also contact our data protection representative or Data Protection Officer (if appointed) at:

[DATA PROTECTION OFFICER OR EU/UK REPRESENTATIVE DETAILS, IF APPLICABLE]

Last Updated: June 22, 2026