PLAYWORKS PRIVACY POLICY

Privacy Policy Kids

PlayWorks is committed to Protecting your Privacy

PlayWorks Digital Ltd. (formerly TransGaming Interactive Ltd.), it's related and parent companies, subsidiaries and affiliates (collectively, “PlayWorks” or “We ”or “Us”) recognize the sensitive nature of personal information and respects your privacy. This Privacy Policy governs PlayWorks’ collection, use and disclosure of “Personal Information” in the course of our commercial activities.

“Personal Information” or personal data, means any information about an individual from which that person can be identified.

This Policy applies to the collection, use and disclosure of Personal Information acquired by PlayWorks in the course of our ongoing conduct, for example when you use the GameTree TV services through your TV (the “Service”) or when you visit and use our online Websites (the “Website”).

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

 

Who we are and how to contact us

PlayWorks Digital Ltd.

Audley House

12-12aMargaret Street London, United Kingdom

Phone: +972 3769 1770

You can contact our Privacy Officer by email at: support@play.works, marked ‘Attention: Privacy Officer’, and by mail at:

Attention: Privacy Officer

PlayWorks Digital Limited

Audley House

12-12aMargaret Street

London,W1W 8RH

United Kingdom

 

Under the European General Data Protection Regulation (”GDPR”), we are the Data Controller of our European Service users and Website’s visitors Personal Information (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 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 through:

-       Direct interactions - You may give us your information by filling in any form in our Website (e.g. "Contact Us", “Newsletter Registration” or “Customer Service” etc.) or by corresponding with our customer services by phone, email or otherwise.

-       Automated technologies or interactions - As you interact with the Service through your TV or through any other device, we may automatically collect Personal Information through the use of the Service’s features and tools or cookies (please refer to the description below, under "Cookies Usage").

-       Third parties or publicly available sources – we may receive Personal Information about you from various third parties and public sources, e.g. advertising and social networks, analytics providers, search information providers and the cable service provider through which you have purchased the Service .

Type sof Information we may collect about you

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

When you visit and use our Website, we will collect technical and related information that identifies your computer, such as an internet protocol address and serial key and other cookies data (please refer to the part bellow addressing our Cookies usage).

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but does not reveal your identity.

 

Cookies and other tracking technologies

Like many other websites and services, the Service and the Website, whether directly and/or through third parties (including the Third Party Advertising Providers, as defined below) may use "cookies" (which are small data files containing information about your use of a site that are stored on your hard drive), "web beacons" (also known as image tags, GIF or web bugs) and other similar tracking technologies (collectively, “Tracking Technologies” or simply “Cookies”) to collect information automatically as you use the Service, browse the Website, or access or use other products or services provided by PlayWorks.

We may use various types of Cookies:

Session Cookies – used to support the functionality of the Service and Website – such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser.

Essential Cookies – which are necessary for the Service and Website to work properly(usually appears under ours, or the TV service provider’s, cookie tag);

Functional Cookies – designated to save your settings on the site - your language preference or other view preferences (also, under our, or the TV service provider’s, Cookie tag);

Targeting Cookies - these cookies are used to collect information from you to help us to improve our products and services as well as serve you with targeted advertisements that we believe will be relevant to you (e.g. Google’s Cookies).

Social networks Cookies - Social Plug-In Cookies (e.g. Facebook, Twitter, Linked In Cookies or pixels etc.) enabling the sharing of your usage information with your social network’s accounts.

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

Third party services used by us – for example, an external service which allows us to screen short videos in our website (e.g. YouTube or Vimeo).

Please note that the data collected by use of Cookies may be linked to and combined with any other data, including Personal Information, like IP.

  

 Managing Cookies and opting out

Opting-out of, deleting or disabling Third Party Advertising Service Providers' Tracking Technologies does not mean that you will no longer receive online or embedded ads. Opting-out, deleting or disabling Third Party Advertising Service Providers' Tracking Technologies only means that such ads will no longer be tailored to your specific viewing habits or interests, but you will continue tosee ads on these sites or within the games accessed by you through the Service.

Further, if you delete or disable Tracking Technologies, 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.

 

How do we handle Do Not Track signals?

We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

 

Do we allow third-party behavioral tracking?

Wed do not allow third-party behavioral tracking.

The purposes of Personal Information processing

Play Works will not sell or rent your Personal Information to anyone.

 

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

Where the GDPR applies (i.e. when we process Personal Information 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 "Contact" form filled 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 Information 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.

 

Sharing your Personal Information with third-parties

We may disclose Personal Information to third parties in the following circumstances:

PlayWorks will only use or disclose Personal Information for the purpose for which it was collected and in accordance with this Privacy Policy, unless the individual consents, or if the use or disclosure is authorized a legal authority.

 

Opting Out of Third-Party Behavioral Advertising

If you are interested in more information about behavioral advertising and your choices to prevent behavioral web and mobile web advertising from third parties, you may visit the following websites:

If you do not want to receive behavioral in-application advertisements from third parties that relate to your interests on your mobile device, you may adjust the ad tracking settings on your device (such as turning on “Limit Ad Tracking”). You can also reset the “Advertising Identifier” (such as an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to your previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you maybe able to download apps, such as the Digital Advertising Alliance’s “App Choices” app, that offer to provide you with control regarding the collection and use of cross-app data for behavioral advertising.

All of the opt-out tools described in this subsection are provided by third parties, not by PlayWorks. PlayWorks does not control or operate these tools or the choices that advertisers and others provide through these tools.

Please note that you may still receive third-party advertisements in PlayWorks’s Services after using these opt-out tools, but the advertising you see may be less relevant to your interests.

You can opt out of third-party behavioral advertising through your device settings and other third-party opt-out tools.

 

Personal Information Retention

We will only keep your Personal Information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law. Certain transaction details and correspondence may be retained until the time limit for claims in respect of the transaction has expired.

 

Information Processing Location

We will always keep and store your 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 incompliance 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.

It is important to 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 or website can be guaranteed to be 100% secured from any intrusion or malfunction.  

   

Links to other sites

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third partie sto collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave the Website, we encourage you to read the privacy policy of each one of those other websites before you browse them.

 

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 such rights under the CCPA (to the extent applicable). Those rights might include:

·        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;

·        Right to correct your Personal Information- 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") - 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. You can also ask for such erasure in any casein 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);

·        Right to restrict our use in your Personal Information - 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 - you can object to any use of your Personal Information which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information;

·        You can always require us to refrain from using your data for direct marketing purposes;

·        You can ask us to transfer your information to another organization and/or provide you with a copy of your Personal Information ("Portability Right");

·        You have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we will appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact using the first instance.

We may not always be able to do what you have asked. In addition, not all of those apply in all cases. 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 of those rights apply in every jurisdiction, e.g., the Portability Right doesn’t apply under the CCPA. So not always we will be able or obliged to provide you with those rights.  However, we encourage you to contact us with any such request, and we will be happy to assist you.

 

 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 or on-line resources. We do not knowingly collect Personal Information from children under the age of 13.No information should be submitted to or posted through the Service or on PlayWorks sites by users under 13 years of age. If a child under the age of 13submits 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

We do not sell your Personal Information for the intents and purposes of the CCPA. We can use your personal data for our purposes, but only as described above or after the anonymization of such data, including aggregate data which can no longer associated to you.

We will not discriminate against you for exercising any of the rights described in this policy. Specifically, 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 the use of 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. 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.

 

Effective as for November 2020