Last Updated March 29, 2022
1. Personal Information
When we say “Personal Information” we mean information that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with an individual, such as:
· Identifiers (e.g., name, address, telephone number, email address, username);
· Sensitive Personal Information (e.g., government IDs, precise geolocation, contents of messages where we are not the recipient);
· Protected classification information (e.g., race, citizenship, marital status, medical condition, sex, sexual orientation, veteran or military status);
· Biometric information (e.g., keystrokes, behavioral or biological characteristics);
· Internet or other similar activity (e.g., browsing history, content interactions);
· Employment-related information (e.g., current or past employment);
· Non-public educational information, including information protected under the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99);
· Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); and
· Inferences drawn from Personal Information to create a profile about preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, and aptitudes.
Personal Information does not include (a) publicly available information; (b) aggregate information, meaning data about a group or category of services or users from which individual identities and other Personal Information has been removed; or (c) deidentified information that cannot be easily linked back to the individual.
2. Collection and Use of Personal Information
We collect your Personal Information (a) with your consent; (b) if we have a legitimate interest in doing so; or (c) as authorized or required by law. We only collect, use, retain, and disclose Personal Information as reasonably necessary and proportionate to enable you to play Prize Kingdoms and use our related services or for other purposes that we disclose to you and are compatible with the context of how we collected the Personal Information.
a. Categories. During the preceding 12 months, we have collected these categories of Personal Information: (i) identifiers; (ii) commercial history; and (iii) internet and other similar activity.
b. Sources. We collect Personal Information from (i) you, when you provide it to us directly; and (ii) automatically when you play Prize Kingdoms. Our Personal Information collection practices are described in more detail below.
· Player Account. You must create an account to play Prize Kingdoms (“Player Account”) using an authentication method that may provide INK Games identifiers like your email and password, display name, profile picture and/or other information connected to your chosen authentication method. If you create your Player Account through a social media account or other platform, INK Games will receive your Player Account information from that other platform subject to your choices and permissions. We collect this information with your consent and we use it to provide you with gameplay and related features and services.
· Game Play. We automatically collect technical information, which may include some Personal Information, from your navigation and content interactions while playing Prize Kingdoms, such as your IP address, device hardware and operating system, ad clicks, and country location. We also collect data about your game engagement and outcomes like clicks, dice rolls, wins and losses, in-game purchases, currency in game, play sessions, league and club participation, and other data (collectively, “Event Data”). We collect this information to achieve our legitimate interest of improving and providing you with access to Prize Kingdoms.
· Your Communications with Us. If you send us an inquiry by email or contact us by any other means, we will collect your name, email, and other information as necessary to respond to your communication. We collect this information with your consent and we use it for the purposes stated at the time of collection, to improve the game and other services, and to communicate with you according to your preferences.
We also collect Personal Information and non-personal information with a legitimate interest from:
3. Children’s Privacy
To play Prize Kingdoms, you must be at least 16 years old, unless the law of your jurisdiction or the minimum age posted for the game rating requires you to be older than 16, in which case you must be at least the required older age. Parents/Guardians are responsible for monitoring their child’s online activity and are required to provide permission for a child under age 16 to install and play Prize KingdomS. If we discover that a child under 16 has provided us with Personal Information without parent or guardian permission, we will delete their information from our systems. If you believe we might have any information collected online from a child under 16, or if you become aware of any unauthorized submission of information to INK Games, please contact us at firstname.lastname@example.org.
We retain the Personal Information we collect about you for the minimum period necessary. For example, your Player Record is retained until you delete your Player Account. We store Event Data and other player analytics for at least 90 days and up to one year, depending on the purpose of collection. Other types of data are retained and disposed of according to our company policies. We may retain Personal Information for longer if it may be the subject of a legal claim or may otherwise be relevant for future litigation. We periodically review and delete or deidentify unnecessary data.
a. Categories; Recipients. INK Games discloses the Personal Information to certain third parties to achieve our business purposes. In the preceding 12 months, we have disclosed Personal Information from all categories of collection to one or more of the following recipients:
· Service Providers. INK Games uses a variety of service providers such as data storage providers, data analytics services, push notification providers, and analytics services to support Prize Kingdoms. These service providers may receive Personal Information related to their provision of services to us. The type of information that we disclose to a service provider will depend on the service that they provide. Our service providers are subject to contractual agreements that protect your Personal Information, and we require all service providers to maintain confidentiality standards that are commercially reasonable to ensure the security of your Personal Information.
· Law enforcement or other government agencies, as permitted or required by law.
· Other Third Parties, as permitted by applicable law, for example: if we go through a business transition (e.g., merger, acquisition, or sale of a portion of our assets); to comply with a legal requirement or a court order; when we believe it is appropriate in order to take action regarding illegal activities or prevent fraud or harm to any person; to exercise or defend our legal claims; or for any other reason with your consent.
b. Aggregated and Deidentified Information. We reserve the right to disclose aggregated, anonymized, or deidentified information about any individuals with nonaffiliated entities for marketing, advertising, research, or other purposes, without restriction.
6. Your Privacy Controls
You can control how we collect and use your Personal Information through:
· Player Accounts. To access, update, or delete Personal Information association with your Player Account, please contact our support team at email@example.com.
· INK Games Emails. If you opt-in to our mailing list, you may receive informational or marketing emails from INK Games about our Games and other news. You can unsubscribe from future emails by clicking the Unsubscribe link found in any of the emails we send you, or by contacting us at firstname.lastname@example.org to request to be removed from the mailing list.
· Privacy Requests. If you wish to exercise your rights under applicable privacy laws, or if you want to express concerns, lodge a complaint or request information, please submit a verifiable request to us at email@example.com. Upon receipt of your request, INK Games will verify your request, including the scope of your privacy request under applicable laws, and respond to your request within the period required by law. If we need more time to fulfill your request, we will notify you in writing of the reason and extension period. If we determine that we process your Personal Information as a processor or service provider to a third party, we will relay your request to the third party for fulfillment. We will deliver our written response by mail or electronically, at your option. We do not charge a fee to process or respond to a verifiable request unless we have legal grounds to do so, such as requests that are excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
7. Your Privacy Rights
Depending on where you reside, you may be entitled to additional controls over your Personal Information. This section provides required and courtesy disclosures and notices related to the General Data Protection Regulation and its counterpart regulation applicable to residents of the United Kingdom, U.S. state consumer privacy laws such as the California Consumer Privacy Act of 2018 and informational notices to residents of Virginia, Colorado, Nevada, and other U.S. states with laws providing similar protections, and Canada’s Personal Information Protection and Electronic Documents Act.
This section is offered as a courtesy to describe the rights afforded to residents of jurisdictions offering certain privacy protections (each a “Consumer“). Please note that certain privacy laws may not apply to INK Games or our provision of Prize Kingdom. Depending on where you live, your rights over your Personal Information may include some or all of the following:
· Right to access your Personal Information. You can request to access your Personal Information. Upon request, we will provide you with a copy of your Personal Information, along with details about the types of Personal Information we process, why we process it, and any third parties we work with to collect Personal Information on our behalf. We may have one or more legally valid reasons to refuse your request in whole or in part, for example to protect the rights of other individuals. If you are a California consumer, your request is limited to specific pieces of Personal Information we have collected about you over the past 12 months, and we only have to respond to two such requests within a 12-month period.
· Right to accuracy, and the right to correct your Personal Information. If you become aware that the Personal Information that we hold about you is incorrect, or if your situation changes (e.g., change of address), please inform us and we will update our records.
· Right to data portability. In some cases, we are required to provide your Personal Information to another organization at your request and in a structured, commonly used machine-readable format, so that the other organization can read and use it.
· Right to deletion or erasure (a.k.a. the “right to be forgotten”). Upon your request, and in certain circumstances and where we are required to do so by law, we are required to delete your Personal Information. This right is not absolute, and we may be entitled to retain and process your Personal Information despite your request. If you make this request, we balance certain legal, contractual, and business interests against your right to request the deletion of your Personal Information.
· Right to restrict processing of your Personal Information. You may have the right to request that we restrict the processing of your Personal Information if (i) the data is inaccurate, (ii) the processing is unlawful, (iii) we no longer need the Personal Information, or (iv) you exercise your right to object. Your right to restrict may be limited to Personal Information that is sensitive in nature, or that is sold or shared for certain purposes.
· Right to object to certain processing of your Personal Information. You may have the right to request, under certain circumstances and where we are required to do so by law, that we will limit our processing of your Personal Information as you request.
· Right to nondiscrimination. We will not discriminate against you for exercising any of your privacy rights. If you are a resident of the State of California, we will not (i) deny you goods or services, (ii) charge you different prices or rates for goods or services, (iii) provide you a different level or quality of goods or services, (iv) retaliate against you as an employee, applicant for employment, or independent contractor for exercising your privacy rights; or (v) suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, because you exercised a right under the CCPA.
· Right to disclosure of certain information about our collection and use of your Personal Information over the past 12 months. If you are a resident of the State of California, you may request that we disclose (i) the categories of Personal Information we have collected about you; (ii) the categories of sources for the Personal Information we have collected about you; (iii) our business purpose for collecting or selling that Personal Information; and (iv) the categories of third parties with whom we disclose that Personal Information. Additionally, if a business sells or shares Personal Information, the consumer may request two separate lists stating (a) sales, identifying the Personal Information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained. Ink Games is only required to respond to two disclosure requests within a 12-month period.
· Right to disclosure of marketing information. If you are a resident of the State of California, note that California’s Shine the Light Act (Civil Code sections 1798.83-1798.84) entitles California consumers to request certain disclosures regarding Personal Information sharing with affiliates and/or third parties for marketing purposes.
You can exercise these rights as they apply to you based on where you reside by following the instructions under Your Privacy Controls, subject to any exceptions and limitations that may apply. Please contact us at firstname.lastname@example.org if you have questions about your specific privacy rights.
8. Cross-Border Data Transfers
INK Games is an international gaming company owned and operated in the United States. We are proud to offer Prize Kingdoms to players around the world. Prize Kingdoms is hosted in an AWS environment designed to support cross-border data transfers in compliance with the strictest privacy and security standards. You can read more about AWS standards and practices at https://aws.amazon.com/compliance/gdpr-center/. If you install or play Prize Kingdoms, Personal Information we collect about you may be transferred to our servers located outside of your country of origin. This may cause your data to be subject to laws governing data collection that differ from those governing your home country, or may result in governments, courts, law enforcement or regulatory agencies having access to or obtaining disclosure of your Personal Information pursuant to the laws of the applicable foreign jurisdiction. By allowing us to collect Personal Information about you, you consent to the transfer and processing of your Personal Information as described in this paragraph.
9. Data Security
We implement reasonable and appropriate security procedures and practices to help protect your Personal Information from unauthorized or illegal access, destruction, use, modification, or disclosure. We use technical safeguards to protect information online and stored on our systems. We maintain internal policies to govern the collection, processing, access, and handling of data. Access to Personal Information is limited to employees and contractors as needed to perform their job functions. We also ensure that our employees, contractors, and agents responsible for handling privacy inquiries are informed of applicable legal requirements and we restrict access to those who need that information to process it. Please note, however, that no transmission of data over the Internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.
10. Social Networking
11. Third-Party Links