PlayWorks is committed to Protecting your Privacy
“Personal Information” (or, pursuant to the General Data Protection Regulation (“GDPR”), “Personal Data”)means any information about a person from which that person can be identified.
This Policy applies to the collection, use, and disclosure of Personal Information acquired by PlayWorks when you use the PlayWorks services through your TV (the “Service”).
Who we are and how to contact us
PlayWorks Digital Ltd.
12-12a Margaret Street
London, United Kingdom
Phone: +972 3769 1770
You can contact our Privacy Officer by email at firstname.lastname@example.org, with the subject line ”Attention: Privacy Officer,” and by mail at:
Attention: Privacy Officer
PlayWorks Digital Limited
12-12a Margaret Street
London, W1W 8RH
Under the European General Data Protection Regulation (”GDPR”), we are the Data Controller of our European Service users’ Personal Data (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 the 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, without limitation:
- Direct interactions - You may give us your information by corresponding with our customer service by email or otherwise.
- Automated technologies - As you use the Service through your TV, the Service may access your Internet Protocol (“IP”) address.
Types of Information we may collect about you
By using the Service or contacting us otherwise, you agree to the collection of the information set out below:
● When you use the Service through your TV, we may collect some general usage information. Such data generally does not allow us to identify the individual user of the Service, e.g., technical information regarding your TV service, content accessed, times of use, language preference, etc., and such non-identifying data is generally not Personal Information. We may also access your IP address, which is considered Personal Information under some privacy laws.
● When you submit an inquiry to our customer service, we may collect your name, email, relevant service (platform), and any other information regarding your inquiry as provided by you. In addition we will record and retain any further correspondence and interaction with us.
● Some of our games in the Service allow the user to provide a screen name for saving score history, etc. (saved locally on your device only; we do not upload, publish, or share that screen name with anyone).
We also collect, use, and share Aggregated Data such as statistical or demographic data (e.g. location of devices in use, time those devices were used, etc.). Aggregated Data may be derived from your Personal Information but does not reveal your identity.
What types of Personal Information do we access and why?
The only types of Personal Information that we access are (a) your IP address, which allows us to provide advertising content via our third-party advertising partners, and (b) any information that you voluntarily provide us if you contact our customer service (for example, if you email us, you will be giving us whatever email address you choose to use).
Do we store, retain, or sell any Personal Information?
No. We do not store, retain, or sell any Personal Information. The IP address information that we access is only accessed temporarily in order to provide advertising content at the time you use the Service.
Any general usage information that we store or retain is Aggregated Data that does not reveal your identity and is used solely for analytics purposes to help us improve the Service. In the event of a sale, merger, or other change of control of PlayWorks, this Aggregated Data may be transferred to another entity.
Cookies and other tracking technologies
We may use various types of Cookies:
Functional Cookies – designated to save your settings on the Service, including, without limitation, your language preference and game play data (progression, points or other statistics, etc.).
Analytics Cookies - give us aggregated information which enables us to improve the way our Service works, e.g. Google analytics.
Managing Cookies and opting out
You may opt out of any such Cookies usage in the Service by sending an inquiry to email@example.com. However, please note that opting out of, deleting, or disabling the Cookies may result in a loss of access to certain features of the Service, and some aspects of the Service may not function properly.
"Lawful Basis" for processing of your Personal Data under the GDPR
Where the GDPR applies (i.e. when we process Personal Data 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 communication initiated 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 Data 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.
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 in compliance 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.
Please note that we are head quartered 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 can be guaranteed to be 100% secured from any intrusion or malfunction.
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 of 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 in which we have justified by 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");
We will do our best to fulfill your request but may not always be able to so. 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 rights apply in every jurisdiction, e.g., the Portability Right doesn’t apply under the CCPA. So we may not be obligated 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
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.
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.
If you need further assistance, please contact us through firstname.lastname@example.org, or any of the other means of contact listed above, and we will be happy to assist you.
Last updated: January 27, 2021