PLAYWORKS PRIVACY POLICY

Committed to Protecting your Privacy

PlayWorks Digital Ltd. (formerly TransGaming Interactive Ltd.), its related and parent companies, subsidiaries and affiliates (collectively, “PlayWorks”) recognize the sensitive nature of personal information. PlayWorks adheres to rules governing the protection of confidential information and all personal Data is stored securely in accordance with the principles of the Data Protection Act 1998 and data protection rules of other countries where applicable to its processing. This Privacy Policy governs PlayWorks’ collection, use and disclosure of “Personal Information” (as defined below) in the course of our commercial activities.

WHAT DOES PROTECTION OF YOUR PRIVACY MEAN?

We have developed this Privacy Policy to outline our commitment to maintain your privacy when we collect, use and disclose Personal Information.

Scope and Purpose: This Policy applies to the collection, use and disclosure of Personal Information acquired by PlayWorks, for example when you use the GameTree TV service (the “Service”), are on the PlayWorks site or when you use other PlayWorks services and software. The PlayWorks site may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Information. Please check these policies before you submit any personal information to such third party websites.

By submitting your Personal Information to PlayWorks you agree and consent to the processing, uses and disclosures set out in this Privacy Policy. Further notices highlighting certain uses we wish to make of your Personal Information together with the ability to opt in or out of selected uses may also be provided to you when we collect Personal Information from you.

Definition of “Personal Information”: “Personal Information” is information about an identifiable individual.

When We Collect: We collect information at various times, including when:

Type of Information Collected: By using PlayWorks products or services you are deemed to have expressly consented to the collection of the information set out below:

Cookies and other tracking technologies: The PlayWorks site and/or 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 which allow information as to whether an email has been opened, as part of a Service or site has been accessed by your device, to ensure that compatible advertising formats are delivered to your device, or for general reporting purposes (collectively, “Tracking Technologies”) to collect information automatically as you use the Service, browse the PlayWorks site and the web, or access or use other products or services provided by PlayWorks.

We and Third Party Advertising Providers use Tracking Technologies to collect "click stream" data and additional information regarding your use of the games and other usage of the Service, visits to the PlayWorks site, use of our features, and purchasing history or preferences and may also collect your IP address or some other identifier unique to the device you use to access the Service and/or PlayWorks site ("Identifier"). Your Identifier is automatically assigned to the device you use to access the Service and/or PlayWorks site. The information collected through Tracking Technologies is used to better customise your experience and provide tailored advertisements and promotions relating to your specific interests.

The Service, PlayWorks sites and other unrelated third party websites may additionally use a variety of third party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties (collectively, "Third Party Advertising Service Providers") to serve advertisements on the PlayWorks site or Service, facilitate targeting of advertisements and/or measure and analyse advertising effectiveness and/or traffic on the PlayWorks site ("Targeting Services"), and in particular, to direct advertising content to you via the Service. These Third Party Advertising Service Providers may enable us to display advertisements based on your use of the Service and your visits to the PlayWorks site and other websites you have visited. Targeting Services enable us to, among other things, help deliver advertisements or other content to you for products and services that you might be interested in, to prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you.

Although these Third Party Advertising Service Providers do not have access to Tracking Technologies set by the PlayWorks Service and/or site, the Third Party Advertising Service Providers, as well as advertisers, may themselves set and access their own Tracking Technologies on your device if you choose to have Tracking Technologies enabled and/or they may otherwise have access to other information about you.

By using the Service and/or PlayWorks site, you will be deemed to consent to the use of the Tracking Technologies described above. However, you may opt out of the use of such Tracking Technologies as set out below:

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 to see 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?

We do not allow third-party behavioral tracking.

Personal Information may be used:

For statistical purposes we may collect, summarize and use customer information in a format that does not identify the individual. This anonymous aggregate data may be shared with our third party providers and business partners.

We may also use your information for marketing our own and selected third parties’ products and services to you by post, email, SMS, phone and fax and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.

We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you. Disclosure: PlayWorks will not sell or rent your Personal Information to anyone.

We may permit selected third parties and agents to use your personal information for the purposes set out above who will be subject to obligations to process such information in compliance with the same safeguards that we deploy and within the terms of this Privacy Policy.

We may also disclose your personal information to third parties in the following circumstances:

Limiting the Use, Retention, and Disclosure of Personal Information: 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. 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.

Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the United Kingdom or the European Economic Area in which data protection laws may be of a lower standard than in those countries.  Regardless of location or whether the person is an employee or a third party we will impose the same data protection safeguards that we deploy inside the United Kingdom.

Security of Personal Information: No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with the Data Protection Act 1998and/or other applicable data protection legislative requirements.

Our soft copy data storage will be protected by the appropriate technological measures (e.g. passwords and encryption) and any hard copies of Personal Information will be kept in locked filing cabinets or kept in offices with restricted access. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the PlayWorks site, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

Individual Access to Information: You have the right to access, verify and update your Account Information and preferences at any time, including whether you want PlayWorks to contact you about specials and new products. You may request deletion of your PlayWorks account by contacting the Privacy Officer at the address set out below.

Upon request and following appropriate identification of the requestor that is satisfactory both to PlayWorks and under the Data Protection Act 1998 or other applicable laws, an individual will be informed of the existence, use and any disclosure of his/her Personal Information. The individual will be given access to that information if requested. A reasonable administration fee may be charged to supply the information. The approximate cost of the administration fee will be communicated to the individual prior to the release of the information.

PlayWorks will use reasonable endeavours to ensure that your Personal Information is accurate. In order to assist us with this, you should notify us of any changes to the Personal Information that you have provided to us by updating your Account Information and preferences or by contacting the Privacy Officer at the address set out below.  

In limited circumstances, PlayWorks may refuse an individual access to their Personal Information; however, access will only be refused in accordance with the Data Protection Act 1998 or other applicable laws. For instance, if the Personal Information is protected by solicitor-client privilege, or would reveal confidential commercial information, PlayWorks may refuse access to such information.

Products Offered in Partnership with Third Parties and Third Party Links: This policy does not apply to the practices of companies that PlayWorks does not own or control, or to people that PlayWorks does not employ or manage, including without limitation, any of PlayWorks's affiliates or business partners.

PlayWorks has partnered with the following partners:

Children: We assume, in those cases in which you legally provide us with credit card information, that you are an adult or are otherwise authorized to do so. 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 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. Compliance and Complaint Resolution: PlayWorks is the data controller in respect of your Personal Information processed by us under this Privacy Policy. Our Privacy Officer ensures that we comply with this Privacy Policy, receives and responds to your questions, comments or complaints and deals with requests for access to, and rectification of, files. 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

12-12a Margaret Street

London, W1W 8RH

United Kingdom

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 may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” 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.