Updated: 8th June 2020
Effective date of California and CCPA Privacy Rights and Disclosures: 1st July 2020
Finally, we note that California law requires us to provide certain information about how we collect and use the personal information of California residents and to grant those California residents certain rights with respect to their data. If you are a California resident, please see the California and CCPA Privacy Rights and Disclosures section of this Policy for these disclosures and a description of your privacy rights, including a right to access, delete, or opt out of the sale of your personal information.
Registration, account, and sign-up information: We collect Information in the course of your use of, or registration with, us. For example, when you create an account, register for, or download an application, or sign-up for a product or service, you provide us with certain personal information. This type of personal information can include: name, postal address, telephone number or email address. We can also receive Information about your interest in and use of various products, programs, services, and content available.
Chat conversation: When you use the in-game chat feature, we collect Information relating to your conversations, such as who you message, the time and date of your message and the contents of your message.
Product/service purchase: Where you make a purchase on one of our sites, we will also collect certain payment information (e.g. credit/debit card, billing information and delivery address).
Information about others/inviting friends: In certain situations, we collect Information you submit about other people. For example, you can submit Information to invite a friend to participate in an offering, make recommendations, share content, or you have multiple players sharing the same video game session. By processing these requests, we can receive the other person’s Information, including details such as his/her name, postal address, email address, telephone number, or information about the recipient’s interest in and use of various products, programs, services, and content. In certain situations, we also allow you to invite your friends to participate in activities by providing their contact details or importing contacts from your address book or from Social Media Sites (as defined below).
Location information: We have access to certain Information about your location, such as your country or address, when you provide it or via device information (such as an IP address). With your consent (where required by law), we can also collect Information about your device’s precise location (e.g. geolocation via mobile devices).
Technical and usage information: We also collect certain technical and usage information such as the type of device, browser, and operating system you are using, your Internet service provider or mobile carrier, unique device identifier, IDFA or IDFV, MAC address, IP address, device and browser settings, the webpages and apps you use, advertisements you see and interact with, and certain site usage information. See our Cookies and Other Technical Information section for more information on how we may use these technologies to collect this Information.
Customer enquiries: Where you contact us through one of our customer helpdesks or customer call centres, we can have access to the application, or product/service that you have purchased, your purchase history, your previous correspondence with us or your contact details. Calls to customer call centres may be recorded.
We use the Information we collect about you, to fulfill your purchase, or to fulfill your requests for, and otherwise provide or analyse your use of our products, application, services, video games and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalise, protect, and improve your experience and our offerings. For example, we use Information collected on our sites to enable you to do things like (i) watch trailers and video clips, (ii) get entertainment news and updates, (iii) get information about our products, services, and content, (iv) locate and access personalised information, ads or functionality based on your interests and location (e.g., find stores, theaters, or show times), (v) buy digital content, products/services or movie tickets, (vi) play games, (vii) engage with interactive features, activities, and Social Media Sites, (viii) read and post comments, content, and reviews, or (ix) enter promotions, contests, and sweepstakes. We also use Information for your payment of any products/services you purchase, to prevent fraud or to offer, market, and advertise products, programs, and services from us and our affiliates, trusted partners, and select third parties that we believe can be of interest to you.
We use Information about you to communicate with you, such as (i) to notify you when you win one of our contests or sweepstakes, or when we make changes to our policies or user agreements, (ii) to respond to your inquiries, (iii) to communicate with you about your purchases or transactions, (iv) to contact you about your account, or (v) to send you information about promotions, offerings, and our features. You can also choose to receive push notifications from us on your mobile device. If you choose to submit content for publication online or in other forums, we can publish your screen name and other Information you have provided to us, the Internet, or elsewhere. If you choose to contact one of our call centres we can record such calls. We use Information that you provide about others to enable us to send them invitations, promotions, or other content on your behalf or through our sites. From time to time, where permitted by law, we also use this Information to offer, market, or advertise products, programs, or services to them from us and our affiliates, business partners, and select third parties.
To ensure a safe in-game chat environment, we monitor your in-game chat communications.
We use your Information when you interact with third party social networking features to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.
We use technical and usage information to improve our design, functionality and content and to enable us to personalise your experience with our content and offerings. We use this Information (i) to provide, develop, maintain, personalise, protect, and improve our products, applications, services and video games, and to operate our business, (ii) to perform analytics, including to analyse and report on usage and performance, (iii) to protect against, identify, and prevent fraud and other unlawful activity, (iv) to create aggregate data about groups or categories of our users, and (iv) for us and our affiliates, business partners, and select third parties to target, offer, market, or advertise products, programs, or services.
We share and disclose Information in the following ways or for any other purpose disclosed at the time of collection: Joint-controllers. Two FlipFlop. entities jointly control your Information. See the end of this policy for further details.
We transfer Information in the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganisation.
Our agents and contractors have access to Information to help carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of products and services, conduct marketing, handle payments, email and order fulfillment, administer contests, conduct research and analytics, or customer service.
Some of our sites contain links to other sites, including Social Media Sites, whose information practices can be different from ours. You should consult the other sites' privacy disclosures and terms before submitting any Information, as we have no control over Information that is submitted to, or collected by, these third parties.
We sometimes offer content or programs (e.g., contests, sweepstakes, promotions, games, applications or Social Media Site integrations) that are sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties collect or obtain Information from you when participating in the activity. We have no control over these third parties' use of this Information. We encourage you to look at the privacy disclosure of any such third party to learn about their data practices.
We share certain Information with third parties to provide advertising to you based on your interests. For more information, please see our (i) Cookies and Other Technical Information and (ii) Ad Choices sections below.
Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of Information with trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can submit a request through our individual rights request portal here. If you previously chose to receive push notifications on your mobile device from us, but no longer wish to receive them, you can manage your preferences through your device or app settings, depending on the type of device.
For more information about interest-based advertising on your desktop or mobile browser, and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit Your Online Choice and/or the EDAA Self-Regulatory Initiative for Online Behavioral Advertising. Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You can continue to receive advertising, but that advertising will be less relevant to your interests.
You can have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You can review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.
Precise location information. To disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection.
See also Cookies and Other Technical Information for more choices about managing other technical and usage information.
Cookies and other technologies. We, and our affiliates, third party service providers, and trusted partners send "cookies" to your device or use similar technologies to understand and enhance your online experience with us and through our advertising and media across the Internet including Social Media Sites, mobile apps, and video games.
Websites and mobile applications
Strictly necessary cookies or similar technologies: They are essential in order to enable you to move around our sites or apps and use its features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.
They collect information about how you use our sites or apps, so that we can analyse traffic and understand users' interactions. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. The information is used to improve our site or app.
They allow our sites or apps to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
They are used when you share information using a social media sharing button or “like” button on our sites or apps, or when you link your account or engage with our content on or through a social media site such as Facebook, Twitter, Instagram. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
Some of our sites or apps may use a third party advertising network, or FlipFlop, affiliates, to deliver targeted advertising. They may also have the capability to track your browsing across sites, apps and Social Media Sites.
We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created. See the Your Choices section to learn how to control data collection for certain purposes.
We have a detailed internal retention policy that sets out varying retention periods for different categories of personal information depending on our legal obligations and whether there is a commercial need. After a retention period has elapsed, the personal information is securely deleted.
Under conditions, you have the right to ask us for a copy of your Information, to correct it, erase it or restrict its processing, and to obtain the Information you provide in a structured, machine readable format. You also have the right to ask us to transfer some of this Information to other organisations.
You have the right to object to the processing of personal information on the basis of our legitimate interests. Where we have asked for your consent to process Information, you have the right to withdraw this consent at any time.
If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
We reserve the right not to allow access to your Information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your Information even if you withdraw your consent. To exercise these rights, or to contact us, please submit a request through our e-mail.
Additionally, California law grants California residents the right to, among other things, access, delete, and opt out of the sale of certain personal information. For a description of these rights, please see the section on California and CCPA Privacy Rights and Disclosures.
We operate internationally, and many of our systems are currently based in the United States, this means Information we collect will be processed by us in the U.S. where data protection and privacy regulations will not offer the same level of protection as in other parts of the world, such as the European Union.
When we transfer your Information to our United States group members outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission. We also use these clauses when we transfer your Information to third parties outside the EEA or we may adopt other means to ensure that adequate safeguards are applied to your Information (e.g. Privacy Shield, BCR, etc). To find out more about how we protect your Information when it is transferred outside the EEA, please submit a request through our individual rights request portal here.
Two FlipFlop entities jointly control your Information, namely:
This California and CCPA Privacy Rights and Disclosure Section was last updated July 1, 2020 and addresses legal obligations and rights laid out in the California Consumer Privacy Act (“CCPA”) and other laws that apply only to California residents. These obligations and rights apply to businesses doing business in California and to California residents and information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households (“California Information”). It does not apply to information that has been de-identified or aggregated as provided by CCPA.
This section provides the information California residents need to exercise their rights over their California Information. Here is information about the California Information we have collected from and shared about consumers in the year before this section was last updated.
In the year before this section was last updated, we may have collected the following categories of California Information:
We may have collected or sold these categories of California Information for the following business or commercial purposes:
We may have obtained California Information from a variety of sources, including:
In the year before this section was last updated, we may have disclosed the following categories of California Information to third parties:
We may have disclosed each of these categories of California Information to the following categories of third parties:
The CCPA defines ‘sale’ very broadly. It includes the sharing of California Information in exchange for anything of value. According to this broad definition, in the year before this section was last updated, we may have sold the following categories of California Information to third parties:
We may have sold each of these categories of California Information to the following categories of third parties:
If you are a California resident, California Civil Code Section 1798.83 permits you to request information about our practices related to the disclosure of your personal information by certain members of the FlipFlop Family of companies to certain third parties for their direct marketing purposes. You may be able to opt out of our sharing of your personal information with unaffiliated third parties for the third parties’ direct marketing purposes in certain circumstances. Please send your request (along with your full name, email address, postal address, and the subject line labeled “Your California Privacy Rights”) by email at email@example.com.
In addition, if you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to California Information. In particular, you can request the following:
You can submit a request to us for the following additional information:
Upon your request, we will delete the California Information we have collected about you, except for situations when that information is necessary for us to: provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us, or that are reasonably aligned with your expectations based on your relationship with us.
You can always tell us not to sell your California Information by visiting here.
You may exercise your rights to request access to your California Information, deletion of your California, or to request we not sell your California Information by visiting our Privacy Center here. You can also contact us by email at firstname.lastname@example.org and an agent will assist you with submitting a request. These requests are generally free. When you submit a request, we will usually ask you to provide an email address which we will contact to confirm the request was not fraudulently submitted.
In addition, for access and deletion requests, we will use a third-party verification service to confirm that you are who you say you are. Our verification service does this by matching information you provide against information held about you in its records, or, if necessary, by allowing you to submit documents proving your identity.
If you are the parent of a child under 13 years of age, you may also submit a request on behalf of your child. In that event, we will ask you to provide your child’s email address, to verify your identity, and to submit a signed form authorizing us to proceed with the request regarding your child’s California Information.
You may also designate an authorized agent to submit a request on your behalf. To do so, we will require either (1) a valid power of attorney, or (2) signed written permission from you. In the event your authorized agent is relying on signed written permission, we may also need to verify your identity and/or contact you directly to confirm permission to proceed with the request.
Your authorized agent can make a request by contacting us by email at email@example.com.
If you would like further information on how we handle California Information from consumers under the age of 16 years of age, or if you have questions about these information practices, you may contact us at firstname.lastname@example.org.
California consumers who are registered users of the Sites and under 18 years of age may request removal of content or information they posted on the Sites. We will remove such content or information when we are required to do so by law. To request removal of content or information you posted on the Sites, you may contact us at email@example.com.
However, even if we remove the content or information that you posted, we cannot completely prevent further use or disclosure of that content or information by others once you have shared it in a publicly available forum.