Privacy-Policy

Last Updated: 5/2/2025

Varolo, Inc. (DBA Scavenger Quest) (“Varolo,” “we,” “our,” or “us”) values your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use the Scavenger Quest mobile application (the “App”) and related services.

By using the App, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the App.

1. Information We Collect

We collect and store only the minimum data necessary to operate the App safely and effectively. For users under 13, we collect no personal data, as outlined below.

a. Information You Provide or Authorize

Users 13 and Older: When you sign in using “Sign in with Google” or “Sign in with Apple,” we receive your name, email address and profile picture as permitted by those services. If that information is missing, you may be asked to provide your name or email manually. During gameplay, the App may record progress, puzzle completion, or activation code validation. This information remains tied to your account but is not shared externally.
Users Under 13: If you select the “I’m under 13” option during registration or login, you will create a non-personalized username. No personal information (e.g., name, email, or other identifying data) is collected or stored. Gameplay progress for users under 13 is stored locally on your device and is not tied to any account with personal information or transmitted to our servers.

b. Information Stored Locally

All Users: When you take photos during quests, they are saved only on your device. Varolo does not access, upload, or store these images on our servers. The App uses location services to guide you during gameplay. This data is processed locally on your device and is not transmitted or stored by Varolo.

c. Automatically Collected Technical Data

All Users: We may automatically collect limited technical data such as device type, operating system, app version, and anonymized performance logs to improve reliability and user experience. No personally identifiable location or tracking data is collected. We do not use third-party analytics tools, cookies, pixels, or device fingerprinting for tracking purposes.

2. How We Use Your Information

We use the data we collect solely to:

Provide and operate the App’s features;
For users 13 and older, authenticate users via Google or Apple sign-in and verify activation codes and quest access;
For users under 13, enable gameplay without collecting or storing personal data;
Maintain security, functionality, and technical performance;
Communicate essential updates or support responses (for users 13 and older, via email if provided).

We do not sell, rent, trade, or otherwise use your personal information for advertising or marketing purposes.

3. Data Storage and Security

Your privacy and data protection are core to our design.

Data at Rest: For users 13 and older, all data stored within our systems is protected using Google Cloud’s native AES-256 encryption. Google-managed encryption keys are used by default, with optional Customer-Managed Encryption Keys (CMEKs) available through Google Cloud KMS. For users under 13, no personal data is stored on our systems.
Data in Transit: All data transmitted between your device and our servers (applicable to users 13 and older) is encrypted using TLS/SSL/HTTPS protocols.
Access Control: Access to our systems is restricted to authorized personnel only, under strict confidentiality and security requirements.

Despite our strong safeguards, no system is entirely secure. You acknowledge that you provide and store information at your own risk (applicable to users 13 and older).

4. Data Breach Notification

In the event of a data breach that compromises personal information (applicable to users 13 and older), we will notify affected users without undue delay, typically within 72 hours of becoming aware of the breach, in accordance with applicable laws such as GDPR and CCPA. Notifications will include details on the nature of the breach, the data affected, potential risks, and steps we are taking to mitigate harm. We will also provide guidance on protective actions you can take. For users under 13, as no personal data is collected, no breach notifications will apply.

5. Data Retention

For users 13 and older, we retain only the information necessary to maintain your user account and gameplay records. Personal information (name and email) is retained as long as your account is active. Technical logs are retained for up to 12 months for debugging and performance improvement purposes. If you delete your account or request removal, your personal information will be permanently deleted from our systems within 30 days, except as required by law or legitimate business purposes (e.g., fraud prevention).

For users under 13, no personal data is collected or stored, so no retention policies apply. Gameplay progress is stored locally on your device and remains under your control.

6. Sharing and Disclosure

We do not sell or share personal data with advertisers or third parties for marketing.

For users 13 and older, we may share information only in the following limited cases:

Legal Compliance: If required by law, subpoena, or court order.
Service Providers: Limited access for trusted vendors and partners including providing infrastructure or security services (e.g., Google Cloud), under strict confidentiality agreements and data processing agreements (DPAs).
Business Transfer: In the event of a merger or acquisition, your data would remain protected under this same Privacy Policy or an equivalent one.

For users under 13, no personal data is collected, so no sharing occurs.

7. International Data Transfers

For users 13 and older, your data may be processed or stored on servers located in the United States or other regions where Google Cloud operates. By using the App, you consent to such transfer and processing in accordance with this Policy. We ensure appropriate safeguards are in place for all international data transfers consistent with applicable privacy laws, including the GDPR and similar frameworks, such as reliance on the EU-U.S. Data Privacy Framework (where certified) and Standard Contractual Clauses.

For users under 13, no personal data is collected or transferred.

8. Your Rights

For users 13 and older, depending on your location, you may have the right to:

Access, correct, or update your personal data;
Request deletion of your data;
Withdraw consent to processing;
Receive a copy of your data in a portable format;
Object to processing or restrict it in certain circumstances.

For California residents under CCPA/CPRA, you have additional rights such as opting out of data sales (though we do not sell data) and limiting use of sensitive personal information. Virginia residents under CDPA have similar rights to access, correct, delete, and opt out. You may appeal any denial of a rights request by contacting us.

Requests can be sent to support@scavenger-quest.com, and we will respond in accordance with applicable law, typically within 30-45 days.

For users under 13, as no personal data is collected, these rights do not apply.

9. Children’s Privacy

Scavenger Quest is designed to be accessible to users of all ages, including those under 13 (or the minimum age required by local law). For users under 13, we do not collect or store any personal information. Users under 13 must select the “I’m under 13” option during registration or login, which allows them to use a non-personalized username without providing any personal data. If we learn that a child under 13 has provided personal data (e.g., through a standard login), we will promptly delete it. Parents or guardians who believe their child has submitted data may contact us at support@scavenger-quest.com for assistance.

10. Changes to This Policy

We may update this Privacy Policy periodically. Any material changes will be communicated via the App or posted at www.scavenger-quest.com/privacy. Continued use of the App after updates constitutes acceptance of the revised Policy.

11. Contact Us

For questions, data access, deletion requests, or other privacy concerns, please contact us:
Varolo, Inc. (DBA Scavenger Quest)
Email: support@scavenger-quest.com
Website: www.scavenger-quest.com
Address: 13530 S. Aintree Ave, Draper, UT 84020

12. Dispute Resolution

Any dispute arising under this Privacy Policy shall be resolved through binding arbitration in Utah, United States, in accordance with the American Arbitration Association rules.