PLAYWORKS PRIVACY POLICY KIDS
Welcome to PlayWorks! PlayWorks services are brought to you by PlayWorks Digital Ltd. (formerly TransGaming Interactive Ltd.), its related and parent companies, subsidiaries and affiliates (collectively, “PlayWorks” or “We” or “Us” or “Our”). We recognize the need to provide additional privacy protections when and if children visit and use any online service.
The purpose of this Privacy Policy - Kids (the “Supplement”) is to supplement our general Privacy Policy (incorporated here by reference) and 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 you use the PlayWorks services through your TV (the “Service”). Please refer to the Privacy Policy for additional information and definitions where applicable.
“Personal Information” means any information about a person from which that person can be identified.
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 refer to a legal guardian of such a child.
Access to Children's information
While some elements of the Service are directed at Children, the Service only has limited, temporary access to any Personal Information, including from Children, in compliance with applicable law. Such access is limited to Internet Protocol (“IP”) addresses and is for the sole limited purpose of our internal operations so that we may provide advertising content through our third-party advertising partners (Such as Super Awesome and PlayWire). The IP address information that we access is only accessed temporarily in order to provide advertising content at the time you use the Service, and we do not store, collect, or sell any Personal Information.
The Service collects general usage data, such as, without limitation, your TV service, content accessed, times of use, language preference, etc., which is generally not Personal Information as it does not allow us to identify the individual user of the Service. To the extent that such general usage data contains data regarding Children’s usage of the Service, we are unable to identify or distinguish such data regarding Children’s usage of the Service, because we have no access to the types of Personal Information that would allow one to do so:
- The Service does not require or collect any personal contact information (e.g., full name, date of birth, phone number, or home address). The only user-generated information that the Service collects is a user screen name for the purpose of game play; this screen name is stored locally via a Cookie on the user’s device and is not uploaded to, stored, or shared by the Service in any way, and there is no requirement, expectation, or suggestion of any kind that the user should enter any Personal Information as part of a screen name.
- The Service does not involve the sharing of any players’ or users’ information with other players or users.
- We do not have any access to any Personal Information that allows us to contact a user directly, such as an email address, mail address, or telephone number.
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.
PlayWorks and COPPA:
Protecting children's privacy is especially important to us - this is why we have received iKeepSafe's Children's Online Privacy Protection ("COPPA") Safe Harbor seal, signifying that this Privacy Policy and our practices with respect to the operation of the Service have been reviewed and approved for compliance with iKeepSafe's COPPA Safe Harbor program. COPPA protects the online privacy of children under the age of 13 ("Child" or "Children"); for more information about COPPA and generally protecting Children's online privacy, please visit https://www.ftc.gov/news-events/topics/protecting-consumer-privacy-security/kids-privacy-coppa
The statements that we make regarding the information we collect from or about Children and how we use this information applies to children under 13 years of age. Accordingly, where this Privacy Policy references Children or any information collected from or about Children our privacy policy applies to children under 13 years of age.
Playworks collects the minimal amount of information from Children necessary to use our Service. This information is necessary given our legitimate interest in being able to provide and improve the Service and for security and safety purposes. Please see the section regarding “ Access to Children's information” for information regarding user-generated information and IP address of the user/customer.
If you are a parent or legal guardian and would like to request the ability to review, delete or refuse further collection or use of a child’s information, please contact us at support@play.works, with the subject line ”Attention: Privacy Officer,” or by legal mail address referenced in the Playworks Privacy Policy. As stated earlier except for the user's IP address, 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.
Protecting Children’s and student’s privacy is especially important to Us. We participate in the iKeepSafe Safe Harbor program. We have been granted the iKeepSafe COPPA Safe Harbor seal signifying that PlayWorks Free Games a Hub Portal deployed on various CTV platforms as well as PW Kids, an AVOD APP have been reviewed and approved for having policies and practices surrounding the collection, use, maintenance and disclosure of personal information from Children consistent with the iKeepSafe COPPA Safe Harbor program guidelines. COPPA protects the online privacy of Children under the age of 13; below is an email and phone number for IKeepSafe Safe Harbor program.:
Email: privacy@ikeepsafe.org
The use of Cookies
Some data on the Service 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 service that are stored locally on your device. Cookies help us to improve your user experience on the Service.
Some of our Cookies usage is done through third-party providers which provide us with analytics services, e.g. Google analytics.
To learn more about the Cookies usage in the Service and/or the Website, please see under the "Cookies" section in our privacy policy.
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 can be guaranteed to be 100% secured from any intrusion or malfunction.
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. We will provide advance notice of any such changes in a commercially reasonable manner, but please note that we do not have any access to 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.
ADS
Our [Site] may display contextual advertisements served by SuperAwesome Trading Limited (“SuperAwesome”), a provider of kid-safe advertising services that are designed specifically for the compliance requirements of younger audiences, including those aged under the age of digital consent..
SuperAwesome is certified as COPPA-compliant by the kidSAFE Seal Program, an FTC-Approved COPPA Safe Harbor Program. Please go to www.kidsafeseal.com for more information.
SuperAwesome also provides advertising services in compliance with the General Data Protection Regulation (EU 1996/679) and the California Consumer Privacy Act (CCPA). Adopting an approach of ‘privacy by design and by default’, SuperAwesome utilizes proprietary technologies so that it neither collects, stores nor shares your personal data to provision advertisements or target advertising to you. SuperAwesome acts as a service provider, as defined by the CCPA, and does not use data collected from children under the age of 16 for any purpose other than to provide contextual advertising for PlayWorks.
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.
Last updated: December 19, 2022
