Thank you for visiting our “REMAG” website at remag.gg (the “Website”).
If you have any questions regarding the collection, storage, use, or disclosure of your Personal Information, please contact the Company’s privacy team at firstname.lastname@example.org.
- The types of Personal Information that may be collected and why such information is collected.
- The purposes for which Personal Information may be used.
- How Personal information can be accessed, updated, and deleted; and
- The types of third-party service providers to whom Personal Information may be disclosed.
When you access and use the Service, the Company may collect, store, use, and disclose certain information, including Personal Information, regarding you, your computing device, and your online activities.
The Company may automatically collect information such as logs and usage data when you access and use the Service. This may include your IP address, user-agent string, browser type, operating system, device information, pages visited, links clicked, and search terms.
Additional information regarding the types of Personal Information collected or that may be collected, and how such information is used or may be used, is referenced hereinafter:
- Account Details
- Contact Details
- Location Details
- Analytics Data
- Electronic Data
- Marketing Data
- Data Collected from Advertisers
- User-Generated Content
- Actions You Take
You can access certain features without requiring an account. However, if you decide to create a user account, you will have the option to select an ID of your choice. Your ID is publicly visible and does not necessarily need to be connected to your real or legal name. Other individuals authorized to access and use the Service, including access and use of the other features or functionalities of the Service, will identify you by your username. Please be advised that you should not use your actual name or any other Personal Information as your username or password. As part of the registration process, you will be requested to provide your full name, email address and date of birth. We also maintain records of your preferences and settings to enhance your experience by offering personalized content that aligns with your interests. The Company may also request additional Personal Information to enable us to more effectively manage the integrity and security of your account and related activities (e.g., to authenticate your identity or the identity of anyone else who uses your account, etc.).
The Company collects Personal Information regarding your contact details (e.g., first and last name, e-mail address, etc.) so that the Company can respond to your inquiries and electronic communications with the Company or any of the Company’s representatives, including, but not limited to, your communications by email, by means of any third-party social media, or as part of any other communications or submission methods that are made available by means of the Service. If you communicate with the Company’s representatives through social media, the Company will have access to the information that you make publicly available on any such platform or any related website(s). Contact details may also be collected if you subscribe to any newsletters that are made available by the Company. You may also provide, at your option, your mobile phone number, which may be used, along with your email address, to contact you and to communicate with you (e.g., recovery of lost or forgotten passwords for the Service).
With your consent, the Company may collect or track real-time geo-location information regarding your whereabouts in order to provide you with enhanced access to the Service, such as, for example, the ability to join a group nearby to your then-current location. Such information may be combined with an identifier associated with your device to enable the Company to recognize your device when you later access and use the Service while at a different location. You may choose, at your option, to update your device settings, to stop accessing and using the Service, or to uninstall an app version of the related Service, and such decisions will enable you to stop the collection of such information.
The Company may collect analytics data, including, but not limited to, (a) session statistics, (b) approximate geolocation, (c) browser and device information, (d) Ad Clicks (as defined on Google Platform), (e) app-related interactions, (f) device information such as Android Advertising ID (as defined on the Google platform), Advertising Identifier for iOS (as defined on the Apple platform) (on iOS, the Software Development Kit (“SDK”) collects the Advertising Identifier (“IDFA”) if it is available. If the Advertising Identifier is unavailable, the SDK collects the Vendor Identifier.), (g) age bracket, (h) gender, (i) approximate city, (j) country & continent from the IP addresses, (k) language settings, (l) platform, (m) OS, and (n) browser. When you access and use the Service, the time you spend accessing and using the Service, your unique device identifiers, and other diagnostic information and related data, all for analytics purposes. Please refer to Sections 4 and 5, below, to learn more about analytics cookies. The analytics data that the Company may collect is anonymized and aggregated so that it does not personally identify individual users, and such data is customarily stored, used, and disclosed in an aggregated, de-identified form that is not associated with specific individuals. Aggregated data or anonymous identifiers can, in theory, be combined with other information to identify an individual and, in such circumstances, could constitute Personal Information. The Company typically uses analytics data to better understand and to confirm the existence of any material bugs or other defective code in the Service, to identify which pages of our Website are popular, in connection with the Company’s efforts to improve the Service, and for similar purposes. However, the Company reserves the right to process, aggregate, analyze, benchmark, share, disclose, distribute, and otherwise use any Personal Information for all lawful purposes and in such manner as the Company deems appropriate, at its sole discretion subject to compliance with all applicable laws regarding any Personal Information.
Electronic data regarding your activities online is automatically collected when you navigate the Internet, including, for example, when you choose to access and use the Service. Electronic data may include information such as your device’s IP address, browser type, browser version, and webpages of or concerning the Service that you, at your option, elect to visit. Electronic data is collected because it is necessary in order to provide you with access to and use of the Service (e.g., to recognize your browser default language, to provide you with your selected language preference, to provide localized content (as may be required under applicable law), to maintain the Service, and for other similar purposes).
The Company may use “cookies” and other comparable technologies (e.g., web beacons, device graphs, etc.) in order to remember your preferences, to help authenticate you when you access and use the Service to enable a shopping cart, to customize content for you, and to provide you with advertising and marketing materials that are believed to be of interest to you (aka, “interest-based advertising”). However, please be advised that the Company will request your consent before undertaking any interest-based advertising.
Even without the use of such advertising and marketing cookies (aka, retargeting cookies), you would still receive advertising and marketing materials, but they would not be personalized for you. Using retargeting cookies allows you to receive news, special offers, information about events, and general information about other goods, services, and/or content which the Company, subsidiaries, and affiliates make available based on your interactions with the Service that may be similar to items that you have previously viewed or purchased.
Information collected from advertisers includes but is not limited to the following: AdMob Mediation, Ad Networks, Google AdMob, InMobi, etc. These advertisers collect the following (a) IP address, which may be used to estimate the general location of a device, (b) non-user-related crash logs, which may be used to diagnose problems and improve the Software Development Kit (“SDK”). The diagnostic information may also be used for advertising and analytics purposes, (c) user-associated performance data such as app launch time, hang rate, or energy usage, which may be used to evaluate user behavior, understand the effectiveness of existing product features, and plan new features. Performance data may also be used for displaying ads, including sharing with other entities that display ads, (d) Device ID, such as the device’s advertising identifier or other app or developer-bounded device identifiers, which may be used for the purpose of third-party advertising and analytics, (e) advertising data, such as advertisements the user has seen, may be used to power analytics and advertising features, (f) other user product interactions like app launch taps, and interaction information, like video views, may be used to improve advertising performance. Note: All of the user data collected by Google Mobile Ads SDK is encrypted in transit using the Transport Layer Security (TLS) protocol.
When you choose to access and use the Service and elect to participate in the social media activities, communications features (e.g., chat, comments, posting, squads, looking for a group (“LFG”), communities, etc.), contents you provide through camera, gallery which includes photos, videos, hashtags you use, messages that you send and receive via 1v1, squad chat or LFG chat, and other content-sharing features, you will be sharing and otherwise disclosing various information and data with the Company and, potentially, with others who also use the Service, which information and data may include Personal Information. Please be advised that the Company reserves the right (but is under no obligation), at any time and from time to time, to monitor, moderate, filter, delete, and otherwise remove any user-generated content that is illegal under applicable law or that the Company, at its sole discretion, believes is illegal or is deemed to be offensive to any other individuals or otherwise inappropriate.
The Company gathers data regarding your activities while using the Service. This encompasses your engagement with content, such as reactions, saving, hiding, reporting, profile views, community views, and other actions you perform while using the Service.
The Company uses both first-party and third-party cookies:
• First-Party Cookies.
First-party cookies are produced by the Company or its subsidiaries or affiliates, and such cookies are implemented, retrieved, used, and deleted only by the Company. First-party cookies are used for purposes that are specific to the Service, such as, for example, to personalize your activities and experiences while using the Service.
• Third-Party Cookies.
Third-party cookies are produced by third parties that are not subsidiaries or affiliates of the Company in connection with new features, functionalities, or content relating to the Service, and for other lawful purposes (e.g., to provide interest-based advertising to you and to other intended recipients), and such cookies are implemented, retrieved, used, or deleted only by such third parties or by the Company in accordance with the Company’s agreements with any such third parties.
The Company uses the following types of cookies as part of the Service:
• Essential Cookies
Essential cookies are those that are necessary for the Service to function as intended, and to ensure the integrity and security of your access to and use of the Service. Without these cookies, the Service may not be available to you, or may not function securely or in the manner intended by the Company.
The Company also collects device identifiers that specifically relate to each device that you elect to use to access and use the Service, and that enables you to select from multiple devices when accessing and using Service.
The Company also generates an access-token when you register an account on a particular device and when you log-in to your account on a new device. Such tokens are saved in the preferences settings of each device that you select to access and use the Service. Each such token is used to verify your account, to authenticate your device, and to authorize and enable you to access and use the Service in accordance with the terms and subject to the conditions set forth in the TOS. Please be advised that such tokens are randomly generated and, therefore, do not contain Personal Information.
• Functional Cookies
Functional cookies are required for specific features or functionalities of the Service to work in the manner intended by the Company (e.g., chats, forums, etc.). Functional cookies also include preference cookies that are used to customize and personalize your interactions and activities with respect to the Service (e.g., recognizing your preferred language, browser type, consent settings, etc.).
• Analytic and Performance Cookies
Analytic and performance cookies are used to track information about your use of the Service, and, in general, traffic involving the Service, including, for example, your social media and other activities when accessing and using the Service. The information gathered by means of these types of cookies is typically linked to a pseudonymous identifier associated with the device you select to access and use the Service. The Company may also use such cookies to obtain information and related data regarding the performance and effectiveness of the Company’s advertisements, webpages, the features and functionalities of the Service, and to assess how you and other users react and interact with the audiovisual content that the Company makes available as part of, and by means of the Service.
• Targeting Cookies
Targeting cookies are used to identify and provide advertising and marketing materials, including interest-based advertising, based on your self-identified interests, and your prior interactions and activities in connection with the Service. Targeting cookies are also used to limit the number of times that you see any particular advertising or marketing materials, as well as to help the Company measure and evaluate the effectiveness of particular advertising or marketing campaigns.
With respect to the Website, you can disable cookies by managing your preferences settings. You can access a webpage describing the preferences settings for the Website by clicking on the following link: https://remag.gg/. NOTE: When you disable cookies by changing browser settings or using the “anonymous browsing,” cookies will no longer collect your information.
Third-party web browsers and devices also offer tools and preferences settings that allow you to control cookies, that usually include the right to block cookies, to manage and control the cookies that are stored on your device, and notification when the browser or device that you choose to use are subject to cookies. Please be advised, however, that if you choose to block all cookies, you may not be able to access all of the features and functionalities of the Service.
Depending on the browser that you elect to use, different instructions are applicable for managing your cookie preferences. You may access such information by clicking on the link referenced hereinafter that corresponds to the particular browser that you use:
You may also use third-party software applications to help you with your cookie preferences, such as, for example, AdChoices, which provides additional solutions and explanations to control and even block cookies, as well as plug-ins to retain opt-out cookie preferences (even if you delete your cookies), and/or WebChoices, which is a browser-based tool for opting out of interest-based advertising.
If you elect to use a smartphone or other mobile device to access and use the Service, you can choose to opt-out of receiving interest-based advertising and obtain additional information regarding your particular type of mobile device by clicking on the link referenced below that corresponds to your device:
Mobile device app stores (e.g., the Apple App Store, the Google Play store, etc.) may also provide interest-based advertising, and you may elect to opt-out of such activities and related content by managing the app store’s preferences. Mobile phone users can also elect to download the Digital Advertising Alliance App Choices tool at Apple App Store or Google Play Store to change and otherwise manage your consent to interest-based advertising in connection with your access to and use of the Service by means of any such mobile device.
The Company, and the third parties with which the Company contracts for the provision of certain services of or concerning the Service, may use Personal Information regarding your device, which information you choose to provide, and that may otherwise be collected by the Company or any such third party, for the following purposes:
- To collect information and data regarding the network to which your device is connected (whether wired or wireless) in order to diagnose and optimize the operation, security, and performance of your connection to the Service;
- To collect device/hardware-related information and data regarding your device in order to optimize the operation, security, and performance of your device with respect to the Service; and
- To collect software-related information and data regarding your device in order to optimize the operation, security, and performance of your device with respect to the Service.
The Company may disclose your Personal Information to third parties that are contracted by the Company to provide certain services that relate to the Service (e.g., data-hosting, purchase transactions, payment gateways, analytics, etc.). Please be advised, however, that the Company is not a data broker and the Company does not sell your Personal Information to third parties. In addition to the Company’s sharing of your Personal Information with such third-party service providers, the Company may also disclose such Personal Information in connection with the following:
- Law Enforcement. Under certain circumstances, the Company may be obliged to disclose your Personal Information in response to a request received from a government authority, an administrative agency, or a court of competent jurisdiction. Please be advised that it is the Company’s policy to disclose Personal Information to such third parties only when the Company is legally required to do so, and only after the Company has made its own verification of the legality and scope of the requested disclosure of any Personal Information.
- Business Transactions. The Company may disclose your Personal Information in connection with, or during negotiations regarding, for example, a potential acquisition of all or a portion of the Company’s business, or a merger, sale of assets, or other proposed transaction with another entity or potential group of investors, etc.
- Other Legal Requirements. The Company may be obliged to disclose your Personal Information if the Company is required to do so by any applicable legal requirement, such as, by way of example, and not as a limitation upon the generality of the foregoing, in connection with any of the following events or circumstances:
- to protect the Company’s rights and interests, and to defend the Company in a lawsuit or other legal proceeding; and
- to comply with any legal obligation that may be incurred by or otherwise imposed on the Company or any of its subsidiaries or affiliates.
Requesting Copy of Your Information
You can request a copy of all your personal and posted data that the Company holds about you, by sending an email to email@example.com. This request will be forwarded to the Database Administrator responsible for extracting the data from the database. The data will be provided in JSON format, which is a portable format. Please note that this process is subject to a one-month timeframe, as approved by applicable laws.
Changing Your Information Directly in the Platform
- You have the option to edit any of your posted content on the Platform by selecting the 'Edit' option from the three-dot menu associated with that specific post.
- You can update your gaming preferences from your menu screen by going to Edit Preferences page.
- You can update your account information from the Account Settings screen.
Deleting Your Account and Contents
- You can delete all the posted contents individually from the platform.
- You may delete your account information at any time from the account settings screen.
- When you delete your account, your profile is no longer visible to other users and all your posted contents also gets deleted and becomes invisible to others except the message conversations.
- After you submit a request to delete your account, the Company will delete all the data instantly but there might be few data backups which still contains your data and since the retention period for those data is 15 days, the company may still retain the data until then. The Company may also retain certain information about you as required by law or for legitimate business purposes.
Opt-out of Personalized Ads
- Some ad providers the Company partners with may provide specific opt-out mechanisms and the Company may provide, as needed and as available, additional tools and third-party services that allow you to better understand cookies and how you can opt out.
- You can also opt out of personalized ads by going to your account settings screen and disabling “Show Personalized Ads” settings.
Controlling Mobile Notifications
- With your consent, the Company may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
Controlling Promotional Communications
You may opt out of receiving some or all categories of promotional communications from the Company by reaching out to the Company at firstname.lastname@example.org. If you opt out of promotional communications, the Company may still send you non-promotional communications, such as information about your account or your use of the Services.
If you have questions or are not able to submit a request to exercise your rights using the mechanisms above, you may also email the Company at email@example.com from the email address that you have verified with your account.
You may exercise your rights to access, delete, or correct your Personal Information as described above. When you make a request, the Company will verify your identity by requesting additional information from you. You may also make a rights request using an authorized agent. If you submit a rights request from an authorized agent who does not provide a valid power of attorney, the Company may ask the authorized agent to provide proof that you gave the agent signed permission to submit the request to exercise rights on your behalf. In the absence of a valid power of attorney, the Company may also require you to verify your own identity directly with the Company or confirm that you otherwise provided the authorized agent permission to submit the request. If you have any questions or concerns, you may reach the Company using the methods described under Your Rights and Choices or by emailing the Company at firstname.lastname@example.org.
The Company will store and retain your Personal Information for as long as necessary or as otherwise deemed appropriate by the Company, in its sole discretion, (a) in order to provide you with your authorized access to and use of the Service; (b) to enable the Company, in good faith, to attempt to resolve any dispute that may arise between you and the Company; and (c) to comply with the Company’s obligations under applicable law.
The Company restricts access to your Personal Information to authorized users only, regularly evaluates new security technologies to protect the security of your Personal Information and strives to adopt and implement security measures based on industry standards to maintain the confidentiality, integrity, and availability of your Personal Information. However, please remember that it is also important that you take precautions when you use your gaming device to connect to the Internet and choose to access and use the Service, and especially whenever you choose to use any public Wi-Fi network in connection with any of your activities online (e.g., don’t share or disclose your username, password, etc.). It is your responsibility to guard your Personal Information and do not share it with any other users of the Service. When you share Personal Information online, including, for example, when you interact with other users or any other individuals in any of the publicly visible areas of the Platform and the Websites (e.g., any chat room, or voice or text communications feature, etc., that is made available to you as part of the Service, such information can be viewed by others and may be copied, and subsequently shared, posted, disclosed, and further distributed (both within and outside of the Platform and the Websites) without your knowledge or authorization. Please remember that any such use or disclosure of any of your Personal Information is not an act for which the Company has any obligation or responsibility (legally or otherwise), and the Company hereby expressly disclaims any obligation or liability of any kind or nature with respect to any such matter, including, without limitation, any acts or failures to act by any other persons or entities with respect to your public communications and/or postings, chat, or any other content that you choose to publicly disclose in connection with the Service.
The laws of various States in the U.S.A. may provide you with specific rights with respect to your Personal Information (e.g., California, Colorado, Connecticut, Utah, and Virginia). However, please be advised that your rights will vary depending on the laws that apply to you in the State in which your primary residence is located. Some of the personal rights that may apply to you (depending upon where you lawfully reside) include the following:
- the right to request the Company to provide information to you regarding the Company’s collection and use of your Personal Information,
- the right to request the Company to correct, amend, or otherwise modify your Personal Information if such information is or becomes inaccurate, ambiguous, incomplete, invalid, or outdated,
- the right to have your Personal Information deleted (subject to certain exceptions),
- the right to limit the use and disclosure of Sensitive Personal Information (e.g., debit/credit card, driver license, etc.) in certain circumstances,
- the right to obtain a portable copy of Personal Information,
- the right to opt out of targeted advertising or sharing of Personal Information; and
- the right to appeal our decision about your requests.
Verifiable Consumer Requests.
In order to initiate any of the above-referenced rights (if applicable to you), you must provide the Company with a written request for the desired action, using the following email address: email@example.com, with the subject line “State Privacy Rights,” or you can choose to mail your request to OneXP UK Ltd., Unit A12 Tileyard London 105 Blundell Street, King’s cross, London, England, N7 9BN, Attn: “State Privacy Rights.” Please be advised that only you (if you are 18 years of age or older), is entitled to submit a verifiable consumer request that relates in any manner to your Personal Information.
In order to be validly effective, a “verifiable consumer request” needs to provide the Company with sufficient, reasonably detailed information that will enable the Company (a) to take appropriate steps to verify your identity and to confirm that you are, in fact, the individual whose Personal Information was collected by or for the Company, or that you are a legally authorized representative of the individual whose Personal Information was collected; and (b) to sufficiently understand, reasonably evaluate, and to respond to your request in a reasonable and appropriate manner.
Please understand that the Company will not be able to respond to your request, nor to take appropriate action with respect to the particular Personal Information referenced in such request, if the Company is unable to verify your identity or the identity and legal authority of your representative (e.g., a parent or legal guardian) to submit such request, or is otherwise unable to confirm that the affected Personal Information specifically relates to you.
If you are entitled to exercise any of above-referenced rights with respect to your Personal Information, and applicable law and the specific circumstances regarding your request allows for such exercise, the Company will accommodate your request without imposing any additional charge. However, please be advised that if you request a transcription, reproduction, or transmission of any or all of your Personal Information, the Company reserves the right (subject to applicable law) to charge a reasonable fee to process and fulfill your request, and, in such case, the Company will contact you regarding any applicable charges before fulfilling your request.
If you request that the Company correct, amend, or otherwise modify your Personal Information, then, promptly after the Company receives such a request from you and the Company confirms your identity, account, and the information contained in the verifiable consumer request that you choose to submit, the Company will use its commercially reasonable efforts to fulfill your request (subject to certain exceptions under applicable law), and in any event within forty-five (45) days after the date on which the Company receives your verifiable consumer request (which timeframe may be subject to extension taking into account the nature of your affected Personal Information and the purposes for which such Personal Information was collected, used, and disclosed by the Company to any third-party service providers and other business partners, if and to the extent applicable) or within the required response time under applicable law, whichever occurs first.
If you request that the Company delete your Personal Information in connection with the Service, then promptly after the Company receives such a request from you and the Company confirms your identity, account, and the information contained in the verifiable consumer request that you choose to submit, the Company will use its commercially reasonable efforts to fulfill your request, including, without limitation, the issuance of appropriate instructions to any third-party service providers and business partners (if applicable) to delete the Personal Information referenced in your request from such third parties’ records (subject to certain exceptions under applicable law) and in any event within forty-five (45) days after the date on which the Company receives your verifiable consumer request (which timeframe may be subject to extension taking into account the nature of your affected Personal Information and the purposes for which such Personal Information was collected, used, and disclosed by the Company to any third-party service providers and other business partners, if and to the extent applicable) or within the required response time under applicable law, whichever occurs first. Please be advised that the requested deletion of your Personal Information may not need to be fulfilled if retention of your Personal Information is required to be maintained by the Company, or any third-party service providers or business partners, in connection with any of the following events or circumstances:
- to help ensure the integrity and security of the Service (in the event and to the extent that your Personal Information is reasonably required and proportionate to the integrity and security of the Platform and the Websites),
- to identify, debug, and repair programming errors or other defects in the Service, which errors or defects adversely affect the intended and proper functioning of the Service,
- to enable internal uses (only by the Company) that are consistent with user expectations that reflect the relationship between you and the Company and that are not inconsistent with the context in which your Personal Information was originally collected,
- to engage in public or peer-reviewed historical, scientific, or statistical research that is in the interest of the public and that abides by applicable ethics and privacy laws, and, if you previously provided your consent, in the event that the deletion of your Personal Information would foreseeably make such research impossible or materially and adversely affect the likelihood that such research can be successfully completed,
- to exercise free speech rights or the exercise of another right protected by applicable law, including, but not limited to, the free speech rights of any other person who is authorized to access and use the Service,
- to complete a transaction that required the Company to collect your Personal Information, or to complete the Company’s provision of any particular services that you requested, or for the Company to otherwise perform its obligations pursuant to any of the agreements with you,
- to perform or to comply with the terms and conditions of any written warranty agreement, or to fulfill any product recall obligation required to be performed under applicable state or federal law,
- to perform or to comply with any of the Company’s other legal obligations,
- to comply with the California Electronic Communications Privacy Act.
Please be advised that the Company will take reasonable steps, in accordance with applicable law, to respond and fulfill the action that is specifically referenced in your verifiable consumer request; provided, however, if the Company has a legitimate interest in retaining any particular Personal Information (e.g., to prevent illegal activity, or as may be needed to create reasonable documentation of your verifiable consumer request and of the Company’s activities in response to such request, etc.), the Company may not be required to comply with a request to delete all instances of your Personal Information. In addition, there are particular circumstances that, under applicable law, relieve and may actually prohibit the Company from complying with a request regarding any or all of your Personal Information (e.g., if the Company is unable to confirm your identity, or the requested action adversely affects others who are authorized to access and use the Service, or the Company receives excessive requests regarding your Personal Information, etc.).
In the event that the Company is entitled to deny your request, the Company will notify you in writing and provide you with information regarding how you can contest such decision. The Company will retain the relevant Personal Information that is the subject of your verifiable consumer request until such time as you have exhausted any right of appeal to which you may be entitled under applicable law. In any event, the Company will respond to your written request regarding your Personal Information within forty-five (45) days of the date of receipt of your written request or within the response period set by applicable legislation, whichever occurs first.
If you have any questions or concerns with respect to regarding what Personal Information the Company actually collects, or how the Company collects, stores, uses, or discloses your Personal Information, or regarding the manner or substance of the Company’s response to your verifiable consumer request, please contact the Company’s support team, at firstname.lastname@example.org, or by writing to the Company using the information referenced in Section 20 (Contact Us), below.
Please be further advised that, under applicable law, you may be entitled to submit a complaint to the privacy regulator in the State in which your primary residence is located.
California’s Online Privacy Protection Act
The Company does not track users of the Service over time and/or across any third-party websites or online services, and, accordingly, the Company does not take action in response to web browser “Do Not Track” signals or other mechanisms that provide consumers the ability to exercise choices regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online activities.
California’s Shine the Light Law
Residents of California may request the Company to provide information regarding disclosures of Personal Information that may have been provided to third parties during the prior calendar year in connection with direct marketing purposes. If your primary residence is located in California and you would like to request information regarding the Company’s privacy-related activities, including the Company’s compliance with the California Shine the Light Law, please submit your request via email to email@example.com , with the subject line “California Shine the Light Law” or send your request by pre-paid mail to OneXP UK Ltd., Unit A12 Tileyard London 105 Blundell Street, King’s Cross, London, England, N7 9BN.
California Consumer Privacy Act of 2018
For purposes of this CCPA Privacy Notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household, or as otherwise defined by the CCPA.
Personal Information does not include information that is: (a) lawfully made from government records; (b) de-identified or aggregated information that does not identify and cannot reasonable be linked to a particular consumer or household; or (c) otherwise excluded from the scope of the CCPA.
As used herein, the term “Consumer” does not include a natural person acting as a job applicant, employee, owner, director, officer, medical staff member, or contractor of the Company to the extent such person’s Personal Information is collected within the context of any such person acting in any of such role or capacity.
California Consumers’ Rights and Choices:
If you are a Consumer, the CCPA may permit you to request information regarding the following:
- the categories of your Personal Information (as defined by the CCPA) collected, sold or disclosed by the Company,
- the categories of purposes for which your Personal Information was collected, sold or disclosed,
- the categories of sources from which Personal Information was collected,
- the categories of third parties to whom Personal Information was sold or disclosed; and
- the particular items of Personal Information that have been collected (including, in some cases, Personal Information of or concerning your household).
In addition, if you are a Consumer, you may elect to:
- Opt out of receiving marketing communications from the Company; provided, however, you may still receive administrative communications regarding the Company’s services,
- opt in to receive certain financial incentive programs that the Company may offer related to the collection, retention, or sale of your Personal Information; and
- request that the Company, and any applicable third-party service providers and business partners, delete your Personal Information (subject to certain limitations in some circumstances).
Further, the CCPA provides Consumers with the right not to receive discriminatory treatment by a business for the exercise of the above-referenced privacy rights, subject to certain limitations.
Collection and Disclosure of Personal Information of or concerning Consumers:
The tables referenced below summarize the categories of Personal Information, and how the Company handles Personal Information collected from and about Consumers, in the preceding twelve (12) months from the date of the Company’s receipt of a verifiable Consumer request.
Category of personal information we may collect: Identifiers
The personal information contains:
The Identifiers may contain the following information: IP addresses, names, email addresses, players IDs, and device information.
Whether we have sold or otherwise disclosed the Personal information in the previous 12 months:
We have not sold Personal Information in the previous 12 months. However, we may have otherwise shared the Personal Information with third parties in the previous 12 months.
Categories of Third Parties to whom the Personal Information was disclosed:
We may have shared this Personal Information with the following categories of third parties: operating systems and platforms, social networks, affiliates, third parties integrated into our services, third parties as required by law and similar disclosures.
Category of personal information we may collect: Internet/Electronic Activity
The personal information contains:
The Internet/Electronic Activity may contain the following information: IP addresses, names, email addresses, players’ IDs, and device information.
Whether we have sold or otherwise disclosed the Personal information in the previous 12 months:
We have not sold Personal Information in the previous 12 months. However, we may have otherwise shared the Personal Information with third parties in the previous 12 months.
Categories of Third Parties to whom the Personal Information was disclosed:
We may have shared this Personal Information with the following categories of third parties: our service providers, third parties integrated into our services, third parties as required by law and similar disclosures.
Use of Personal Information:
Collection of Personal Information:
In the preceding twelve (12) months from the date this CCPA Privacy Notice was last reviewed, the Company has collected Personal Information from the following categories of sources: directly from you (e.g. forms you complete, products and services you purchase, etc.) and other Consumers, and from third-party operating systems, browsers, devices, and platforms.
Sales of your Personal Information:
The Company is not in the business of selling Personal Information and has not sold your Personal Information in the preceding twelve (12) months from the date of the last review of this CCPA Privacy Notice.
If you have any questions or concerns with respect to what Personal Information the Company actually collects, or how the Company collects, stores, uses, or discloses your Personal Information, or regarding the manner or substance of the Company’s response to your verifiable Consumer request, please contact the Company’s support team, at firstname.lastname@example.org. Please be advised that the Company does not accept or process requests regarding Personal Information through any other means (e.g., via fax, social media, etc.).
The Company will review the information provided and may request additional information to ensure the Company is interacting with the correct Consumer. If you have a password-protected online account with the Company, you may be required to log-in to your account for identity verification. If you do not have an account with the Company, additional information to verify your identity may be required by law before the Company may take action upon such a request. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, the Company may also be required by law to obtain a signed declaration under penalty of perjury from you or, if applicable, from a parent or legal guardian, that you are the subject of the request being made. If the Company suspects fraudulent or malicious activity by means of or otherwise in connection with your account, the Company will delay taking action on your request until the Company can appropriately verify your identity and your verifiable Consumer request as authentic.
By law, the Company is not required to collect Personal Information that the Company otherwise would not collect in the ordinary course of our business or retain Personal Information for any period longer than the Company would otherwise retain such information in the ordinary course of the Company’s business or re-identify or otherwise link information that is not maintained in a manner that would be considered Personal Information. If the Company has not requested specific additional information from you to confirm your verifiable Consumer request, please do not send such information.
The Company will endeavor to avoid requesting additional information from you for verification purposes. However, if representatives of the Company cannot reasonably verify your identity or more information is needed for security or fraud-prevention purposes, the Company may consider any of the following factors, alone or in combination, in requesting additional information: the type, sensitivity, and value of the Personal Information collected and maintained about the Consumer, as applicable law requires a more stringent verification process for sensitive or valuable Personal Information, including, the following:
- The risk of harm to the Consumer posed by any unauthorized access or deletion,
- the likelihood that fraudulent or malicious actors would seek the Personal Information,
- whether the Personal Information to be provided by the Consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;
- the manner in which the Company interacts with the Consumer,
- available technology for verification; and
- other factors that may be reasonable in the circumstances, are consistent with industry practice, are recommended by California government officials, or which may be required by law or regulation following the effective date of this CCPA Privacy Notice
If your verifiable Consumer request specifically relates to household information, the same verification steps referenced above may be required before the Company can provide you with aggregate household information. In addition, if you do not have a password-protected online account with the Company, in order to process a request for access to or deletion of specific pieces of information regarding your household, the Company may need all members of the household to make the request and may need to individually verify each household member and that each member making the request is currently a member of the applicable house.
The Company reserves the right to charge a reasonable fee or take other appropriate action in response to requests from a Consumer or household that are manifestly unfounded or excessive, in particular because of their repetitive character.
Authorized Agent Requests
You may designate an authorized agent to make a verifiable Consumer request on your behalf in accordance with applicable law. The Company will accept documentation of your designation in the form of a valid power of attorney or other form of legally binding written authorization signed by you and your authorized agent. You may submit evidence of your designation of an authorized agent in writing to: email@example.com, or via postage prepaid mail to the Company at its address referenced in Section 20, below.
The Company may require verification of your authorized agent in addition to the information for verification that is referenced above with respect to Consumers and households.
Notice of Financial Incentives
Please be advised that the Company does not currently offer financial incentives to Consumers based upon the collection, retention or sale of a Consumer’s Personal Information.
This section applies where your Personal Information is handled subject to either the European Union (EU) and United Kingdom (UK) data protection law (the General Data Protection Regulation (EU) 2016/679 and as incorporated into UK law by the Data Protection Act 2018), or data protection laws that offer equivalent rights.
- You have the right to be informed about the collection and use of your Personal Information.
- You have a right to access and receive a copy of the Personal Information we hold about you.
- If your Personal Information is inaccurate or incomplete, you are entitled to have your Personal Information rectified.
- You have the right to ask us to erase/delete and stop handling your Personal Information where we no longer need it or where you withdraw your consent.
- You have a right to restrict and object to the processing of your Personal Data.
- You have a right to request a copy of your Personal Information in a structured, commonly used, machine-readable format ( “Portability” ). Where technically feasible, we can send a copy of your Personal Information to another information technology environment at your request.
- Where a decision is automated and significantly affects you, you have the right to object to it or ask for a person to review the automated decision.
- The Company will ask for your consent to handle your Personal Information for specific purposes which you can withdraw at any time.
- You can submit a complaint to the Company or the relevant data protection authority.
Data Privacy Framework (“DPF”)
Accountability for Onward Transfer of Personal Data
EU and UK Residents Privacy Rights
You have the following rights in relation to how the Company handles your Personal Information, some of which are subject to exceptions and conditions:
Refer to Section 8, for guidance on how to control your Personal Data in the Platform or contact us via firstname.lastname@example.org.
If you are located in the EU & the UK and provide Personal Data to the Company, the Company will transfer your Personal Information to the Amazon Web Services (“AWS”) data center located in the U.S.A.in Northern Virginia.
The Company has implemented organizational, physical, and technological measures designed to protect your information from unauthorized access, both during transmission and storage. If you have any questions about the security of your Personal Data, you can contact us at email@example.com.
However, please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, although the Company complies with its legal obligations regarding the security of your Personal Information, we cannot guarantee its absolute security.
The Company complies with the framework outlined in the EU-US Data Privacy Framework, which may be found at https://www.dataprivacyframework.gov/s/participant-search, but does not rely on the EU-US Data Privacy Framework as the legal basis for transfers of personal data into the United States. The Company included the applicable Standard Contractual Clauses (“SCCs”) in its standard data processing agreement as its primary data transfer mechanism. The Company will continue to rely on the SCCs as a legal basis for transferring personal data to and processing such data in the countries where the Company operates.
For personal data received or transferred under the EU-US Data Privacy Framework, the Company may be subject to the regulatory enforcement power of the U.S. Federal Trade Commission. In certain situations, the Company may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements where it operates.
If you have an unresolved privacy or data use concern that the Company has not addressed satisfactorily, please contact the applicable Data Protection Authority where you reside in your country of residence.
Under certain conditions, more fully described on the EU-US Data Privacy Framework website https: //www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
To ensure that your Personal Information does receive an adequate level of protection, the Company has put in place the Standard Contract Clauses to ensure that those parties in the United States and other countries where the Company operates to treat your Personal Information in a way that is consistent with, and which respects the EU and UK laws on data protection. If you require further information about this protective measure, you can request it from firstname.lastname@example.org.
Attention: Data Protection Officerprivacy@ptw.com
c/o PTW America, Inc.
1042 Princeton Drive
Marina Del Rey, CA 90292
The Company has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved EU-US Data Privacy Framework complaints concerning data transferred from the EU into the United States. The non-compliance with the EU-US Data Privacy Framework will result in the Company being subject to the investigatory and enforcement powers of the Federal Trade Commission (“FTC”).
In cases of onward transfer to third-party, the Company will notify you and provide an opportunity to opt-out of sharing with the third-party before disclosing your Personal Information. The Company will enter into a contract with each relevant party (Controller or Processor) to only process your Personal Information for limited and specified purposes consistent with your consent. The Company will obligate the third party to provide the same level of protection to your Personal Information as is required by the EU-US Data Privacy Framework.
In the context of an onward transfer, the Company is responsible for processing Personal Information it receives under the Data Privacy Framework and subsequently transferring to a third party acting as an agent on its behalf. The Company remains liable under the Framework if its vendors process such Personal Information in a manner inconsistent with the Framework unless it proves that it is not responsible for the event giving rise to the damage.
“Sensitive Personal Information” refers to Personal Information that once leaked or illegally used, may easily cause the infringement to the dignity of the natural person or harm to personal or property security, including but not limited to the information on biometric characteristics, religious beliefs, specially-designated status, medical health, financial accounts, individual location tracking, as well as the Personal Information of minors under the age of 14.
You understand that the Company may request and process your Sensitive Personal Information when you interact with us. Please take special note of the Sensitive Personal Information that the Company has indicated in bold in this Privacy Notice. The Company will make you aware of how and why your Sensitive Personal Information will be processed.
For the Sensitive Personal Information that the Company processes, the Company will take appropriate security measures that correspond to the risk level of such information to prevent unauthorized access to and public disclosure, use, modification, destruction, leakage, or loss of Personal Information.
You have the following rights in relation to how the Company handles your Personal Information, some of which are subject to exceptions and conditions:
- to be informed on how the Company processes your Personal Information
- to access your Personal Information
- to rectify your Personal Information in case of any error, omissions or incomplete record
- to erase/delete your Personal Information (in the case of one of the listed events below)
- the handling purpose has been achieved, is impossible to achieve, or the Personal Information is no longer necessary to achieve the handling purpose,
- Personal Information handlers cease the provision of products or services, or the retention period has expired,
- the individual rescinds consent,
- where Personal Information handlers have handled Personal Information in violation of laws, administrative regulations, or agreements; or
- other circumstances provided by laws or administrative regulations.
- to object/opt-out
- to request data Portability
- not to be subject to automated decision-making
- to copy your Personal Information and restrict processing of your Personal Information.
In terms of deceased individuals, their next of kin may, for the sake of their own lawful, legitimate interests, exercise the rights to consult, copy, correct, delete, etc., the Personal Information of the deceased, except where the deceased individuals have other arrangements before their death.
If you are accessing the Service from Canada, you have certain rights under the Personal Information Protection and Electronic Documents Act (“PIPEDA”) which is the federal privacy law for Canada; and the Quebec Law 25 which is the applicable regulation for private-sector organizations in Quebec.
The Company will retain any information you choose to provide to the Company until the earlier of: (a) you asking the Company to delete your Personal Information, (b) the Company’s decision to cease using the Company’s existing data providers, or (c) the Company decides that the value in retaining your Personal Information is outweighed by the costs of retaining it.
You have the right to request access to your Personal Information that the Company stores and the rights to either rectify or erase your Personal Information.
You have the right to seek restrictions on the processing of your Personal Information.
You have the right to object to the processing of your Personal Information and the right to the Portability of your Personal Information.
To the extent that you provided consent to our processing of your Personal Information, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the PIPEDA.
The Company requires only the information that is reasonably required to enter into a contract with you. The Company will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with the Company.
The Company retains Personal Information for as long as necessary to provide you with the Service, to perform the Company’s marketing campaigns effectively or as permitted or required by applicable laws, whichever is longer. If you wish to have all your Personal Information removed, you can do so by deleting your account through the account settings page. However, please be aware that this action is irreversible, and you will lose access to the Service and your Personal Information, with no possibility of logging in again or using the Service.
The Company’s advertising partners may retain your Personal Information for a period of approximately 18 to 24 months. But you do have an option to opt-in/opt-out of the personalized ads which you can set from the account settings page.
Google Analytics may keep your data for around 26 months. To opt-out of this tracking, you will have to reach out to the Company at email@example.com.
The Platform operates its service globally and collects and stores Personal Information on the cloud using AWS located in the United States in Northern Virginia. The Company may transfer your Personal Information to any country where the Company or its third parties, affiliates, subsidiaries, or service providers are located. Data protection laws in the United States or other countries may not be as recent and comprehensive as under the Canadian, the EEA and the UK. As such, your personal data may be collected, used and disclosed outside of Canada, the EEA and the UK by our service providers, such as in the United States.