PlayWorks Digital Ltd. (formerly TransGaming Interactive Ltd.), it's related and parent companies, subsidiaries and affiliates (collectively, “PlayWorks” or “We”or “Us”) recognize the need to provide additional privacy protections when and if children visit and use any online service or website.
The purpose of these Children's Privacy Policy supplement our general Privacy Policy https://www.play.works/privacy-policy, is to outline our policy with regard to the processing of Personal Information of children. The policy applies to the potential collection, use and disclosure of Personal Information acquired by us in the course of our ongoing conduct, for example when someone uses the GameTree TV services through your TV (the “Service”)or while browsing our online Websites (the “Website”).
When we use the term “child” or “children” we mean an individual under 13 years of age or the appropriate age for services directed toward children as defined under applicable laws in other relevant jurisdictions or an individual under 18 years of age where the collection, use or disclosure of personal information about such an individual is restricted by applicable law. When we use the term “parent” below, we mean to the legal guardians of such child.
Collection of Children's information
We do not develop or publish any content or services designated specially for Children. We do not knowingly collect personal information from Children. Yet, our content and services are family friendly, i.e. Children can enjoy the Service or incidentally visit the Website.
Given that, some of the Personal Information collected by us, as explained in our Privacy Policy, may contain some Children information, but we cannot differ or identify such data as Children related. Therefore, our commercial collection and use of Personal Information on the Service in herently protects the privacy of Children:
- The Service does not collect, and it is not mandatory to provide the Service with, any personal contact information (e.g., full name, date of birth, phone number or home address).
- The Service collect only some technical information which might be deemed under law as Personal Information (like IP address, mobile device UDID, operating system, etc.) automatically and use technology like cookies to provide functionality and support our operations.
- The Service does not involve the sharing of player's or user's information with other players or users.
- Any user of the Service or visitor of the Website can ask us to delete their information, so parents can ask us to update or delete their Children’s information.
If we knowingly collect, use, or disclose contact information collected from a Child, we will provide notice and obtain parental consent in accordance with applicable law.
We do not condition a child’s participation in an online activity on the child’s providing more contact information than is reasonably necessary to participate in that activity.
Information we collect
When you use the Service through your TV, we collect the IP through which you are connected to the Service. In addition we may collect some general and non-identified usage information, e.g., technical information regarding your TV device, times of use, preferences regarding language and other features which does not allow us to identify the certain user of the Service.
Some of the games in the Service, allow the user to provide a “NickName”. This nickname which is recorded through a Cookie, used only with respect to the same user - we do not publish or share that nickname with any other user of our services or any other third-party.
We may collect some additional information through other interfaces in the Website, as detailed in our Privacy Policy, but those interfaces are not Children oriented at all.
The use of Cookies
It should be noted that some of this data may be collected and processed through the use of Cookies or any other similar technology, as detailed under the Cookies section in our Privacy Policy. Cookies are small data files containing information about your use of a site that are stored on our hard drive. Cookies help us improve your user experience, and allow us to analyze the use of the Service and our Website and manage our advertising.
Some of our Cookies usage is done through third-party providers which provide us with analytics services or customized advertisement services. Advertising networks may use this Cookies information to serve targeted ads for products and services that, based on user's activities, are likely to be of interest to him. We do not permit such interest-based advertising where we have actual knowledge that a child is under 13.
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 in the Service does not mean that you will no longer receive embedded ads. Opting-out, deleting or disabling Cookies only means that such ads will no longer be tailored to your specific viewing habits or interests, but you will continue to see ads on these sites or within the games accessed by you through the Service.
Further, if you delete or disable Cookies, you may not have access to certain features of the Service or the PlayWorks site and some of our other services may not function properly.
To learn more about the Cookies usage in the Service and/or the Website, please see under the "Cookies" section in our privacy policy.
Use of information
We use any Personal Information we collect (to the extent collected) in consistency with the purposes it was provided for. For example, we may use such Personal Information to:
- For fulfillment of a contract we have – e.g., to provide any user of the Service with our services upon his choice.
- To customize the advertising and content on the Service or on the Website and to ensure that it is presented in the most effective manner.
- To improve products and services, to conduct research and to provide software updates and any dynamically served content, product support and other services to customers.
- To address any legal obligation we have under any applicable law.
- To protect our rights and legitimate interests, including defend against any lawsuit, legal claim or complaint.
If we will knowingly collect any Children information, we may also use a parent’s contact information to communicate with the parent regarding the child’s activities on the Service.
We will not sell or rent any Personal Information collected through the Service or in the Website to anyone.
Disclosure of information to third parties
Information collected from any user of the Service or the Website(which might include some incidental Children information) will be disclosed in the same ways described in the "Sharing your Personal Information with third-parties" section of our general Privacy Policy. As detailed there, we may share some Personal Information with third-party suppliers assisting our commercial activities, with legal authorities when we have a legal obligation todo so, or indirectly in connection with the use of Cookies through a third-party service as explained above. In general, any such transfer shall be made only in accordance with the requirements of applicable law.
Security of Personal Information
We are committed to protecting any Personal Information collected by us. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect Personal Information from loss, misuse, unauthorized access, and alteration. However, no data transmission over the
Internet or website can be guaranteed to be 100% secured from any intrusion or malfunction.
Parents’ choices and access to children’s information
Parents have the option not to consent to the disclosure of their child’s contact information to third parties. In Addition, parents may review the contact information collected from their child, refuse to permit us to collect further contact information from their child, and request that any contact information which have been collected be deleted from our records.
As explained above, we do not collect any Children's Information knowingly and / or intendedly. However, as explained in the "Your rights under data protection laws" section in our General Privacy Policy, similar rights are provided to any user of our system under the privacy laws (such as GDPR and CCPA, to the extent applicable). So any parent can exercise that right by sending an inquiry to support@play.works.
Please note that certain information cannot be deleted because of other legal obligations, such as FCC requirements.
Changes to this Children's 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. 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 published in our general Privacy Policy, and we will be happy to assist you.