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PLAYWORKS PRIVACY POLICY

https://www.play.works/privacy-policy-kids

PlayWorks is committed to Protecting your Privacy

Welcome to PlayWorks!  PlayWorks services are brought to you by PlayWorks Digital Ltd. (formerly TransGaming Interactive Ltd.), along with its related and parent companies, subsidiaries and affiliates (collectively, “PlayWorks” or “We ”or “Us” or “Our”).  We recognize the sensitive nature of personal information and respect your privacy.  This privacy policy (the “Privacy Policy” or “Policy”) governs our collection, use, and disclosure of “Personal Information” in the course of our commercial activities.

“Personal Information” (or, pursuant to the General Data Protection Regulation (“GDPR”), “Personal Data”) means any information about a person from which that person can be identified.

This Policy applies to the collection, use, and disclosure of Personal Information acquired by PlayWorks when you use the PlayWorks services through your TV (the “Service”).

By using the Service or by submitting your Personal Information to PlayWorks in any other way, you hereby agree and consent to the processing, uses, and disclosures of Personal Information set out in this Privacy Policy.

 

Who we are and how to contact us

PlayWorks Digital Ltd.

Audley House

12-12a Margaret Street

London, United Kingdom

Phone: +972 3769 1770

You can contact our Privacy Officer by email at support@play.works, with the subject line ”Attention: Privacy Officer,” and by mail at:

Attention: Privacy Officer

PlayWorks Digital Limited

Audley House

12-12a Margaret Street

London, W1W 8RH

United Kingdom

We are not responsible for mislabeled or misdirected requests.

 

Under the European GDPR, we are the Data Controller of our European Service users’ Personal Data (to the extent such data is being collected).  With respect to such data, we assume the responsibilities of Data Controller, as set forth in this policy.  Similarly, under the California Consumer Privacy Act ("CCPA") which may be relevant for California residents (if and where applicable), we are the Business with respect to the Personal Information processed by us.

Questions, comments, requests, and complaints regarding this policy and the information we hold are welcome and should be addressed to us by using the contact details above.  All requests will be dealt with promptly and efficiently.

 

How do we collect your Personal Information?

We use different methods to collect Personal Information from and about you, including, without limitation:

-       Direct interactions - You may give us your information by corresponding with our customer service by email or otherwise.

-       Automated technologies - As you use the Service through your TV, the Service may access your Internet Protocol (“IP”) address.

Types of Information we may collect about you

By using the Service or contacting us otherwise, you agree to the collection of the information set out below:

  • When you use the Service through your TV, we may collect some general usage information, e.g., technical information regarding your TV service, content accessed, times of use, language preference, etc.  Such data generally does not allow us to identify the individual user of the Service, and such non-identifying data is generally not Personal Information under the GDPR (but may be Personal Information under the CCPA).  We may also access your IP address, which is considered Personal Information under some privacy laws.
  • When you submit an inquiry to our customer service, we may collect your name, email, relevant service (platform), and any other information regarding your inquiry as provided by you.  In addition, we will record and retain any further correspondence and interaction with us.  
  • Some of our games in the Service allow the user to provide a screen name for saving score history, etc. (saved locally on your device only; we do not upload, publish, or share that screen name with anyone).

We also collect, use, and share Aggregated Data such as statistical or demographic data (e.g. location of devices in use, time those devices were used, etc.).  Aggregated Data may be derived from your Personal Information but does not reveal your identity.

What types of Personal Information do we access and why?

The only types of Personal Information that we access are (a) your IP address, which allows us to provide advertising content via our third-party advertising partners (Such as Super Awesome and PlayWire, which is obtained from the device through which you are accessing the Service (set-top box, smart TV, etc.) and shared with our third-party advertising partners), and (b) any information that you voluntarily provide us if you contact our customer service (for example, if you email us, you will be giving us whatever email address you choose to use), for the purpose of responding to your communication (which information is not shared with third parties except as reasonably necessary to respond to your communication or request).  

 

Do we store, retain, or sell any Personal Information?

No.  We do not store, retain, or sell any Personal Information.  The IP address information that we access is only accessed temporarily in order to provide advertising content at the time you use the Service.  

Any general usage information that we store or retain is Aggregated Data that does not reveal your identity and is used solely for analytics purposes to help us improve the Service.  In the event of a sale, merger, or other change of control of PlayWorks, this Aggregated Data may be transferred to another entity.

Cookies and other tracking technologies

Like many other services, the Service, whether directly and/or through third parties, may use "cookies" (which are small data files containing information about your use of a service that are stored locally on your device) and other similar tracking technologies (collectively, “Cookies”) to improve your user experience on the Service.

We may use various types of Cookies:

Functional Cookies – designated to save your settings on the Service, including, without limitation, your language preference and game play data (progression, points or other statistics, etc.).

Analytics Cookies - give us aggregated information which enables us to improve the way our Service works, e.g. Google analytics.

 

Managing Cookies and opting out

You may opt out of any such Cookies usage in the Service by sending an inquiry to support@play.works.  However, please note that opting out of, deleting, or disabling the Cookies may result in a loss of access to certain features of the Service, and some aspects of the Service may not function properly.

 

"Lawful Basis" for processing of your Personal Data under the GDPR

Where the GDPR applies (i.e. when we process Personal Data of European residents), we will only process and use your Personal Data when the law allows us to, i.e. when we have a Lawful Basis for such usage.  Such Lawful Basis can be any of the following:

  •        Processing actions which we need to take as part of a contract we have between us and you as our Customer, e.g., providing you with the Service or contacting you per communication initiated by you;
  •        Processing actions which are necessary to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities;
  •        Our use of your information is in our legitimate interest as a commercial organization.  For example, to operate and improve the Service and to keep people informed about our products and services.  In these cases, we will look after your Personal Data at all times in a way that is proportionate and respects your privacy rights, making sure our legitimate interest is not overridden by your interests or fundamental rights and freedoms.

In general, and as detailed above, we do not rely on consent as a legal basis for processing your Personal Data.  Yet, in any case in which you have provided your consent to our processing of your information (to the extent provided), you can withdraw this consent at any time by contacting us through the contact details provided above.

Information Processing Location

Although we do not currently store any Personal Information, we will always keep and store any Personal Information in accordance with requirements of applicable law.  Any transfer of data which originates in the European Union (including the United Kingdom - "EU") to a country outside of the European Economic Area (EEA), shall be made in compliance with the provisions of chapter 5 of the GDPR.  Such transfer can be made to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights, e.g. signing a Standard Contractual Clauses which were published and authorized by the relevant EU authorities.

Please note that we are headquartered in Israel, a country which is considered by the European Data Protection Board to be offering adequate level of Personal Data protection regulation.  

 

Security of Personal Information

We are committed to protecting your Personal Information.  We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your Personal Information from loss, misuse, unauthorized access, and alteration.  However, no data transmission over the Internet can be guaranteed to be 100% secured from any intrusion or malfunction.  

Your rights under data protection laws

Where the GDPR applies, EU residents and individuals have certain rights with regard to their Personal Information. Similarly, California residents have certain rights under the CCPA. Those rights might include, depending on the jurisdiction:

  •        Right to access your Personal Information – you can ask us to confirm whether or not we have your Personal Information, and if so, you can ask for a copy of your information. Although we do not store or sell your Personal Information and only access and share it to the extent set out in this privacy policy, where the CCPA applies, you can ask for the categories of information collected, the sources from which the information is collected, the purposes for which the information is used, the categories of third parties with which the information is shared or sold, and the categories of information that are shared or sold.
  •        Right to correct your Personal Information – although we do not store Personal Information at this time, you can ask us to correct any of your Personal Information which is incorrect, after verifying the accuracy of the data first.
  •        Right to erase your Personal Information (“the right to be forgotten” or “right to delete”) – although we do not currently store Personal Information, under the GDPR, you can ask us to erase your Personal Information if you think we no longer need to use it for the purpose we collected it from you, and under the CCPA, you can also ask that we delete Personal Information.  Although we do not collect Personal Information based on consent, under the GDPR, you can also ask for such erasure in any case in which the process of your data was based on your consent, or where we have used it unlawfully, or where we are subject to a legal obligation to erase your Personal Information.  Any request for such erasure will be subject to our obligations under the law (e.g. our obligation to keep some records for tax or customs purposes), and you may be required to provide your IP address or other identifying information (which will not be used for any purpose other than identity verification) so that we can confirm your identity and determine which information is personal to you or your household.
  •        Right to restrict our use of your Personal Information – under the GDPR, you can ask us to restrict our use of your Personal Information in certain circumstances.
  •        Right to object to how we use your Personal Information – under the GDPR, you can object to any use of your Personal Information in which we have justified by legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information.
  •        Under the GDPR, you can require us to refrain from using your data for direct marketing purposes; however, at this time, we do not use your data for direct marketing purposes.
  •        Under the GDPR, you can ask us to transfer your information to another organization and/or provide you with a copy of your Personal Information in our possession ("Portability Right");  however, at this time, we do not store any Personal Information.
  •        Under the CCPA, you have the right to opt out of the sale of your Personal Information; however, at this time, we do not sell any Personal Information.
  •        You have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we would appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us using the contact information included in this Privacy Policy.

To ask for a copy of your Personal Information or other information available under the CCPA, or to ask that we erase your Personal Information, please contact us at support@play.works, with the subject line ”Attention: Privacy Officer,” or by mail at the address set out above.  We will do our best to fulfill your request but may not always be able to so, for example, if the fulfillment of a right would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.  In addition, not all rights apply in every jurisdiction, e.g., the Portability Right doesn’t apply under the CCPA.  So depending on your jurisdiction and the circumstances, we may not be obligated to provide you with certain rights.  However, we encourage you to contact us with any such request, and we will be happy to assist you and will fully comply with our legal duties under any applicable laws.

 

Privacy protection of Children

We encourage parents and guardians to participate in their children's activities and to supervise them when they access the Service.  We do not knowingly collect Personal Information from children under the age of 13.  No Personal Information should be submitted to or posted through the Service by users under 13 years of age.  If a child under the age of 13 submits Personal Information to PlayWorks, we will delete the information as soon as we discover it was provided by a child under 13 years of age.  We will not and do not use such information for any purpose.  You can learn more about our privacy policy for children in our Children’s Privacy Policy at https://www.play.works/privacy-policy-kids

Special Notification for California Residents

Under the CCPA, we are required to give you notification of any Personal Information (as defined in the CCPA) that we sell to others.  We do not sell any such Personal Information.  We may use the personal data described above for our own purposes, but only as described above or after the anonymization of such data, including aggregate data which can no longer be associated with you or your household.

We will not discriminate against you for exercising any of the rights described in the CCPA.  We will not deny you any of our services including the Service or charge you different prices or rates for goods or services, including through discounts or other benefits or by imposing penalties.

 

Changes to this Privacy Policy

We reserve the right to change this policy from time to time at our sole discretion.  If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it.  We will provide advance notice of any such changes in a commercially reasonable manner, but please note that we do not maintain Personal Information that allows us to contact you directly, such as an email address, mail address, or telephone number.

By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree to this policy as modified.

Contact Us

If you need further assistance, please contact us through support@play.works, or any of the other means of contact listed above, and we will be happy to assist you.

 

Last updated:  December 19, 2022

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