Supplemental California Consumer Privacy Act Policy
Effective Date: 25/09/2020
Where noted in this Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information“) from some its requirements.
- Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
In particular, we will look to collect the following information:
- Information you provide directly to us.
- Information automatically collected. When you access or use the App, we automatically collect information about you, including:
- Device Information: We collect device-specific information when you access our App, or any incidental services from a mobile device, including your hardware model, operating system and version, unique device identifiers, mobile network information and country, language, screen size and resolution, and battery life remaining.
- Use Information:We collect information about your use of the App or any incidental services, including the type of browser you use, access times, pages viewed, game play activity, interactions with other players, your IP address and, with respect to our website, the page you visited before navigating to our App.
- Information Collected by cookies and other tracking technologies:We use various technologies to collect information, and this includes sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our services and your experience, see which areas and features are popular and count visits. We also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that are used in our websites or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.
- Other Information Collected with Permission: Applications distributed through various “app” stores also request permission to automatically collect other information from your mobile device, including your email address. We only collect this information with your authorization in accordance with your device operating system’s permission process.
- Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information.
- To provide, support, personalize, and develop our products, applications, services and games.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To help maintain the safety, security, and integrity of our websites, applications, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our applications, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our consumers is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
- Sharing Personal Information
We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Outright has not disclosed nor sold Consumer personal information for a business purpose.
- Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
- 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 or selling that personal information.
- The categories of third parties with whom we share that personal information.
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by email to [email protected]
We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
Only you (or a parent/guardian of a child), or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You can designate an authorized agent to make a request under the CCPA on your behalf if the authorized agent is a natural person or a business entity registered with the Secretary of State of California; and you sign a written declaration that you authorize the authorized agent to act on your behalf.
If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in the preceding section above:
- Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to our contact details included in section 8 and
- Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.
- If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
Please note, we cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact [email protected]
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
You may not be discriminated against because you exercise any of your rights under the CCPA in violation of Cal. Civ. Code § 1798.125.
- Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. For further information, please contact us at our contact address.
- Contact Information
Email: [email protected]
Postal Address: FAO Legal Department
Outright Games LLC
Margarita Parkway Site 110
Rancho Santa Margarita,
If you need to access this Policy in an alternative format due to having a disability, please contact [email protected]