ANCILLARY PRIVACY DISCLOSURE DOCUMENT FOR CALIFORNIA RESIDENTS
Last updated: 08/05/2020
The California Consumer Privacy Act of 2018 (CCPA), as amended, establishes specific rights for California residents, for the control of their personal data, and requires businesses to provide specific information to California residents regarding how their personal data is collected, used, and shared.
1. Your rights
Under the CCPA, California residents have certain rights to their personal data. If You are a California resident, You may exercise these rights as explained below.
When You submit a request to exercise Your rights, We are required to verify that You are the consumer to whom the request for personal data relates, or a person authorized to act on that consumer's behalf. If You submit Your request by using automated tools that may be provided in Our Games, We may not need additional information to verify Your request. For requests submitted by other means (for example, by email), We may ask You to provide additional information about the account to which the request relates to, in order to enable Us to confirm that You are the account holder or acting on their behalf.
Right to Know. You have the right to know what personal data We collect about You, from which sources, for which purposes, and with whom We share it. You also have the right to request the specific pieces of personal data that We have collected about You. This request can be made free of charge, twice within any 12-month period. Moreover, You have the right to know which categories of personal data We may have "sold", or disclosed for a business purpose.
For information on what personal data We collect, from which sources, for which purposes, with whom We share it, and whether We disclose it for business purposes, please refer to clause 2 of this Disclosure. In addition, clause 3 of this Disclosure describes the extent to which We may "sell" Your personal data within the meaning of the CCPA.
Deletion. You have the right to request that We delete any personal data about You, that We have collected from You, subject to certain exceptions provided in the CCPA (including, for example, where We need to keep Your personal data to protect against malicious, deceptive, fraudulent, or illegal activity or to comply with a legal obligation).
Following Your deletion request, We may either erase or de-identify Your personal data.
Non-Discrimination. You have the right to not be discriminated against, for exercising Your rights under the CCPA.
2. How We collect, use, and share Your personal data
We regularly collect the following categories of personal data specified in the CCPA:
|Category of personal data||Examples||Sources|
|Identifiers||In-game alias, IP address, hardware or operating system based identifiers, email address, or identifiers We assign to Your account.||Directly from You (including automatically when You interact with our Services), Our advertising partners (to the extent You interact with Our ads outside of Our Services), third-party account providers (if You link a third-party account to Our Services), or third-party payment service providers (if You make purchases in Our Services).|
|Commercial data||Data regarding Your virtual items or currency in Our Services, including records of purchases You may have made.||Directly from You (including automatically when You interact with Our Services) and third-party payment service providers (if You make purchases in Our Services).|
|Internet or other electronic network activity data||Data on Your activity in Our Services (for example, Your game progress or Your interactions with ads in Our Games).||Directly from You (including automatically when You interact with Our Games), Our advertising partners (to the extent You interact with Our ads outside of Our Games).|
|Geolocation data||Your coarse location (for example, country, state, or city), determined based on Your IP address.||Directly from You (including automatically when You interact with Our Games).|
|Inferences drawn from this data to create a profile about You||Your geolocation or preferences used to personalize Our Games for You.||We make these inferences based on the other categories of data.|
We shall use this data for the following business purposes specified in the CCPA:
We will share the data with recipients such as Our service providers to achieve these business purposes. This means that We will disclose the categories of personal data listed above for a business purpose.
In addition, some features of Our Games (for example, in-game chat, surveys, or tools used to contact Our player support) may allow You to submit to Us data about Yourself. We will collect any data You choose to submit to Us using these features. Additional to the personal data listed in the table above, this may include other categories of personal data specified in the CCPA, including:
We only collect these categories of personal data directly from You, and You may choose not to submit this data to Us at Your discretion. We may use the personal data You choose to submit for performing Our Services (for example, to handle your support enquiries) and short-term, transient uses, and We may share the data with recipients such as Our service providers to achieve these business purposes. This means that We may disclose these categories of personal data for business purposes.
3. How We may "sell" Your personal data
Under the CCPA, a business is required to provide notice to a consumer before the business sells the consumer's personal data to third parties. The CCPA defines a "sale" as not only exchanges for monetary consideration, but also disclosures of personal data for other valuable consideration.
We do not sell Your personal data in exchange for money. However, when We request Our advertising partners to show You an ad in Our Services or Games, We disclose a limited amount of Your personal data to the advertising partners, to enable them to deliver an ad that is relevant to You. This includes the following categories of Your personal data:
Because this disclosure of data could be deemed a "sale" in the meaning of the CCPA, We provide the means for You to direct Us not to disclose Your personal data to Our advertising partners for this purpose. To learn how to exercise Your right to opt-out, please see clause 1 of this disclosure.
If We have actual knowledge that you are under the age of 14, We shall not sell your personal data without affirmative authorization.