Version Date: September 1, 2021
Your privacy is critically important to us.
The Children's Online Privacy Protection Act ("COPPA") protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Platform represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from a user under 13 years of age on or through the Platform, then we will take the appropriate steps to cause this information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Platform or has otherwise transferred personal information to the Platform, please contact Company using our contact information below to have that child's account terminated and information deleted.
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING INFORMATION
Users of the Platform Generally
“Non-Personally-Identifying Information” is information that, without the aid of additional information, cannot be directly associated with a specific person. “Personally-Identifying Information,” by contrast, is information such as a name or email address that, without more, can be directly associated with a specific person. Like most website operators, Company gathers from users of the Platform Non-Personally-Identifying Information of the sort that Web browsers, depending on their settings, may make available. That information includes the user’s Internet Protocol (IP) address, operating system and browser type, and the locations of the Web pages the user views right before arriving at, while navigating, and immediately after leaving the Platform. Although such information is not personally identifiable, it may be possible for Company to determine from an IP address a user’s Internet service provider and the geographic location of the visitor’s point of connectivity as well as other statistical usage data. Company analyzes Non-Personally-Identifying Information gathered from users of the Platform to help Company better understand how the Platform is being used. By identifying patterns and trends in usage, Company is able to better design the Platform to improve users’ experiences, both in terms of content and ease of use. From time to time, Company may also release the Non-Personally-Identifying Information gathered from Platform users in the aggregate, such as by publishing a report on trends in the usage of the Platform.
Third Party Advertisers
We may use third-party advertising companies to serve ads when you visit the Platform. These companies may use information (not including any Personally-Identifying Information) about your visits to this and other websites that are contained in Web Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third party ad servers’ and networks’ Web Cookies simultaneously. If you would like more information about this practice and to know your choices about not having this information used by these companies, please follow the following links: https://optout.networkadvertising.org, https://preferences-mgr.truste.com, or https://optout.aboutads.info. Please contact us if you would like to know the identity of the third-party advertising companies we are currently using to serve ads.
We may allow advertisers to choose the characteristics of users who will see their advertisements and we may use any of the non-personally identifiable attributes we have collected (including information you may have decided not to show to other users, such as your birth year or other sensitive personal information or preferences) to select the appropriate audience for those advertisements. We do not identify you to the advertiser.
A “Web Beacon” is an object that is embedded in a web page or email that is usually invisible to the user and allows website operators to check whether a user has viewed a particular web page or an email. Company may use Web Beacons on the Platform and in emails to count users who have visited particular pages, viewed emails, and to deliver co-branded services. Web Beacons are not used to access users’ Personally-Identifying Information; they are a technique Company may use to compile aggregated statistics about Platform usage. Web Beacons collect only a limited set of information including a Web Cookie number, time and date of a page or email view, and a description of the page or email on which the Web Beacon resides. You may not decline Web Beacons, however, they can be rendered ineffective by declining all Web Cookies or modifying your browser setting to notify you each time a Web Cookie is tendered and permit you to accept or decline Web Cookies on an individual basis.
We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to provide analytics services, inform, optimize, and serve ads based on your past activity on our websites and applications, including Google Analytics for Display Advertising. These vendors may use Web Cookies, Web Beacons and other technologies to collect information about your use of the Platform, our service and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our service and other websites and better understand your online activity. If you do not want any information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network. You can do so by using Google’s Ads Settings (www.google.com/settings/ads). For more information about interest-based ads, or to opt out in general of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.
Aggregated and Non-Personally-Identifying Information
We may share aggregated and Non-Personally Identifying Information we collect under any of the above circumstances. We may also share it with third parties and our affiliate companies to develop and deliver targeted advertising on our Platform and on websites of third parties. We may combine Non-Personally Identifying Information we collect with additional Non-Personally Identifying Information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our Platform and the most popular features or services accessed. This information does not contain any Personally-Identifying Information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
Mobile Device Additional Terms
- Mobile Device. If you use a mobile device to access our Platform or download any of our applications, we may collect device information (such as your mobile device ID, model and manufacturer), operating system and version information, and IP address.
- Geo-Location Information. Unless we have received your prior consent, we do not access or track any location-based information from your mobile device at any time while downloading or using our mobile applications or our services except that it may be possible for Company to determine from an IP address the geographic location of the user’s point of connectivity, in which case we may gather and use such general location data.
- Push Notifications. We send you push notifications if you choose to receive them letting you know when someone has sent you a message, or for other service-related matters. If you wish to opt-out from receiving these types of communications you may turn them off at the device level.
- Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any Personally-Identifying Information you submit within the mobile application.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION
As defined above, Personally-Identifying Information is information that can be directly associated with a specific person. Company may collect a range of Personally-Identifying Information from and about Platform users. Much of the Personally-Identifying Information collected by Company about users is information provided by users themselves when (1) registering for our service, (2) logging in with social network credentials, (3) participating in contests, polls, surveys or other features of our service, or responding to offers or advertisements, (4) communicating with us, (5) creating a public profile, or (6) signing up to receive newsletters. That information may include each user’s name, address, email address, and telephone number, and, if you transact business with us, financial information such as your payment method (valid credit card number, type, expiration date or other financial information). We also may request information about your interests and activities, your gender, age, date of birth, username, hometown and other demographic information, and other relevant information as determined by Company from time to time. Users of the Platform are under no obligation to provide Company with Personally-Identifying Information of any kind, with the caveat that a user’s refusal to do so may prevent the user from using certain Platform features.
BY REGISTERING WITH OR USING THE PLATFORM, YOU CONSENT TO THE USE AND DISCLOSURE OF YOUR PERSONALLY IDENTIFYING INFORMATION AS DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING INFORMATION” SECTION.
We may occasionally use your name and email address to send you notifications regarding new services offered by the Platform that we think you may find valuable. We may also send you service-related announcements from time to time through the general operation of the service. Generally, you may opt in or opt out of such emails at the time of registration or through your account settings, though we reserve the right to send you notices about your account and that relate to your participation in activities on the Platform, such as service announcements, and administrative messages, even if you opt out of all voluntary email notifications.
BY SIGNING UP FOR AN ACCOUNT AND PROVIDING YOUR PHONE NUMBER, YOU AGREE TO RECEIVE INFORMATIONAL TEXT MESSAGES FROM US RELATING TO USE OF THE COMPANY SERVICE.
If you do not want to receive such messages, you may opt out or change your preferences in your account. Opting out may prevent you from receiving messages regarding updates, improvements, or offers.
Company will disclose Personally-Identifying Information under the following circumstances:
- Marketing Communications. Unless users do not opt-in to receive Company marketing materials upon registration, Company may email users about products and services that Company believes may be of interest to them. If a user wishes to opt-out of receiving marketing materials from Company, user may do so by following the unsubscribe link in email communications, by going to your account settings (if applicable) or contacting us using the contact information below.
- Contest Sponsors. You may be participating in games and contests on our Platform that are operated by game and contest sponsors. We will allow such sponsors to have access to your account activity and information on the Platform and the use of such information by the sponsors will be subject to the privacy practices and policies of such sponsors.
- Third Party Service Providers. We may share your Personally-Identifying Information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting our website functionality, and supporting contests, sweepstakes, surveys and other features offered through our Platform. We may also share your name, contact information and credit card information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose.
Changing Personally-Identifying Information; Account Termination
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
We take security of your Personally-Identifying Information seriously and use reasonable electronic, personnel, and physical measures to protect it from loss, theft, alteration, or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for third party circumvention of any privacy settings or security measures.
We are dedicated to protect all information on our Platform as is necessary. However, you are responsible for maintaining the confidentiality of your Personally-Identifying Information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your account. If you lose control of your account, you should notify us immediately.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to our privacy officer as listed below.
DO NOT TRACK POLICY
Our Platform does not respond to “Do Not Track” signals or mechanisms.
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