Last Updated July 1, 2020
This California Online Privacy Protection Act Notice (this Section) is part of the VUXIA Privacy Policy and specifically provides information on how we collect, use, disclose and otherwise process personal information of our players who are individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (the CCPA).
Terms in this California Notice section of the VUXIA Privacy Policy mean the same as they are defined elsewhere in our Privacy Policy or as defined in the CCPA. We refer below to “players” and this is meant to include players of our games as well as people who access our websites or other services.
Collecting Personal Information
The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household” and the use of Personal Information in this Section has this meaning.
We have provided below the categories of Personal Information we have collected about our players in the preceding 12 months, as well as the source of the Personal Information and our business purposes for collecting the Personal Information:
Category of Personal Information |
Source of the Personal Information |
Identifiers in (A)
(for example: real name, alias, postal address, unique personal identifier, online identifier, IP address, device or WiFi location) |
- Our players
- Our players’ devices
- Social networks
(for example, Facebook)
- Third parties (e.g., marketing partners, data or analytics services)
|
information defined in Cal. Civ. Code 1798.80(e)
(for example from the statute: name, address, telephone number) |
- Our players
- Our players’ devices
- Social networks
(for example, Facebook)
- Third parties (e.g., marketing partners, data or analytics services)
|
protected classifications
(for example in the statute: age, gender) |
- Our players
- Our players’ devices
- Social networks
(for example, Facebook)
- Third parties (e.g., marketing partners, data or analytics services)
|
commercial information
(records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) |
- Our players
- Our players’ devices
- Social networks
(for example, Facebook)
- Third parties (e.g., marketing partners, data or analytics services)
|
internet or other electronic network activity information
(browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) |
- Our players
- Our players’ devices
- Social networks
(for example, Facebook)
- Third parties (e.g., marketing partners, data or analytics services)
|
geolocation data
(examples as already mentioned above such as IP address) |
- Our players
- Our players’ devices
- Social networks
(for example, Facebook)
- Third parties (e.g., marketing partners, data or analytics services)
|
electronic information
(in the sense, for example, that “electronic information” includes data as a result of the player’s interaction with the device to play the game) |
- Our players
- Our players’ devices
- Social networks
(for example, Facebook)
- Third parties (e.g., marketing partners, data or analytics services)
|
inferences drawn from the above |
- Our players
- Our players’ devices
- Social networks
(for example, Facebook)
- Third parties (e.g., marketing partners, data or analytics services)
|
We use the Personal Information collected above for the following business purposes:
- improving and optimizing our games and our player’s experiences in our games (incl. analytics and reporting)
- creating player accounts and allowing our players to play our games
- identifying and suggesting connections with other players and personalize our games for our players and enable players to communicate with each other
- communicating in-game updates and notifications, new games and new websites, and promotional offers that we think might be of interest to our players
- protecting the safety and security of our games, websites and company (e.g., debugging, auditing & testing)
- making our games available to our players
- protecting our rights and property in connection with our games as well as complying with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties
- preventing fraud or potentially illegal activities, and to enforce our terms of use
- managing and delivering customized advertising and marketing (e.g., user acquisition, direct marketing)
- research & development (including game and feature development, improvement, optimization and refinement)
- administering promotional activities or events sponsored or managed by us or our partners
- enabling our various teams within VUXIA and our partners to work on development of our games and websites and better understanding of players’ needs and wants
- player services and support (e.g., responding to player inquiries, quality assurance, enhancements, & monitoring/auditing)
Pursuant to CCPA, Personal Information does not include publicly available information. For these purposes, “publicly available” means information that is lawfully made available from federal, state, or local government records, if any conditions associated with such information. “Publicly available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge. Information is not “publicly available” if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained. “Publicly available” does not include consumer information that is deidentified or aggregate consumer information.
Disclosure of Personal Information
We disclose in this Privacy Policy that we share personal information within the VUXIA group (and among our joint controllers) as well as with certain third parties. More specifically, we may allow the following categories of recipients to access Personal Information:
- entities within our corporate group
- cloud-based software providers (e.g., storage providers)
- distribution channels
- payment processors)
- analytics providers
- security providers
- advertising and marketing partners (e.g., user acquisition partners and ad monetization partners)
- as required by law
VUXIA does not sell and has not sold Personal Information of California residents to third parties for a commercial purpose in the preceding twelve months, regardless of a player’s age.
We do not sell personal information of California players to third parties, regardless of the player’s age. We offer advertising in some of our games; if you want to opt out of personalized advertisements in our games, please do so within the game. You can read more about this as well in the Privacy Policy section here: Opting In or Out of marketing communication with VUXIA.
Your California Privacy Rights
In addition to any other rights under the law or elsewhere in the Privacy Policy, you have the right to the following:
Right to Know
California residents have the right to request that we disclose certain information about our collection and use of your personal information over the past 12 months.
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
- identifying the personal information categories that each category of recipient obtained.
We can only provide you with this information if you send us a verified request, which we explain further below.
Right to Delete
You have the right to request that we delete your Personal Information that we have collected from you and that we have retained, subject to certain exceptions.
Once we receive and confirm your verified request, we will delete (and request to our service providers the same) your Personal Information that we have collected and retained, unless an exception applies.
We can only delete your Personal Information if you send us a verified request, which we explain further below.
Other Rights
You also have the right to designate an authorized agent to make a request under the CCPA on your behalf and the right not to be discriminated against if you exercise any of your rights with us under the CCPA.
In order to be authorized to act on your behalf, your authorized agent will need to provide us with proof that they have written permission to act on your behalf. The request will also need to be a verified request.
Making a Verified Request
In order to exercise your rights under the CCPA, we will need to get from you a verified request. There are two ways to send us a verified request:
The first way is to send us the request through our games. This is the preferred method because then your PlayerID comes to us automatically. Please reference “CCPA” in your request.
The second way is to send an email to dpo@vuxia.com. When you send us the request, you will need to include your Player ID. Please reference “CCPA” in your request.
Please make sure that you include sufficient information in your request as to what you want from us. For example, if you want us to delete your data, please tell us that. If you want to request a copy of your data, please tell us that.
We may need to verify your identity before processing any request; but we will try to limit the additional Personal Information that we collect in order to process your request. We reserve the right to decline a request to exercise rights under CCPA, particularly if we are unable to verify your identity.
If you are using an authorized agent, the authorized agent will still need to submit a request as above along with proof of the authorization.
You can make a request up to twice every twelve months.
California Civil Code Section 1798.83 & Do Not Track Signals
A company that is subject to California Civil Code Section 1798.83 is required, if engaged in sharing data with third parties for direct marketing requests, upon request from a user, to disclose to its users the identity of any third parties to whom the business has disclosed personal information within the previous calendar year, along with the type of personal data disclosed. The company is required to respond to this request once per calendar year. Inasmuch as the above information is not already provided by us, our California-resident players should make any such request through the Contact Us link found in our games or by contacting the DPO using the contact information in this Privacy Policy. When you contact us, please make sure to reference “Shine the Light” in your request.
A company subject to California Business and Professions Code Section 22581 is required to allow any California resident under age 18 who is a registered user of an online site, services or applications to request and obtain removal of content or information they have publicly posted. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances. Inasmuch as the above information is not already provided by us, our California-resident players should make any such request through the Contact Us link found in our games or by contacting the DPO using the contact information in this Privacy Policy. When you contact us, please make sure to reference “Shine the Light” in your request.
Additional Important Information
We do not currently respond to Do Not Track signals (e.g., from mobile devices, web browsers).
We may update our Privacy Policy, including or excluding this Section, from time to time with or without notice. When we make changes to the Privacy Policy, we will change the “Last Updated” date. All changes shall be effective from the date of publication unless otherwise provided in any notification of the changes.
If you access our games or websites from a third-party application or connect our games or websites to a third-party application (e.g., if you link your account with us to your Facebook account), you should also read that third-party application’s terms of use and their privacy policy.