Retro Jigsaw Puzzles (“Company,” “we,” “us,” and “our”)
provides virtual reality (“VR”) gaming experiences on the Oculus, Steam,
and other VR platforms through games. This Privacy Policy is designed to
help you understand how we collect, use, and share your personal
information and to help you understand and exercise your privacy rights.
Company is the controller for the personal information we process, unless
otherwise stated. For information on how to contact us, please refer to
Section 13 below.
1. SCOPE
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR INFORMATION
4. HOW WE DISCLOSE YOUR INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. SECURITY OF YOUR INFORMATION
7. INTERNATIONAL DATA TRANSFERS
8. RETENTION OF PERSONAL INFORMATION
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
11. CHILDREN’S INFORMATION
12. OTHER PROVISIONS
13. CONTACT US
1. SCOPE
This Privacy Policy applies to personal information processed by us,
including on our websites, mobile applications, games, and other online or
offline offerings. To make this Privacy Policy easier to read, our
websites, mobile applications, games, and other offerings are collectively
called “Services”.
2. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you
interact with us, our Services, and the requirements of applicable law. We
collect information that you provide to us on our website and through our
mobile applications and games, information we obtain automatically when
you use our Services, and information from other sources such as
third-party services, organizations and platforms, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
-
Account Creation. We may collect information when you
create an account to play our games via Steam, Oculus, or other
platforms, such as your profile picture, display name, Game Platform
User ID, or other information that you have made available via your
privacy settings on Steam, Oculus, or other platforms. We also store the
calibrated height information associated with your account to allow us
to better track your movement in the virtual environment.
-
Beta User Information. If you sign up to join a Beta on
our Services, we will collect your email address, first name, region,
and Discord username. We will also add your email to our mailing list.
For more information about how to unsubscribe from our email list,
please see Section 5 below.
-
Purchases. We may collect personal information and
details associated with your purchases, including payment information.
Any payments made for our Services are processed through third-party
payment processors or through Oculus, Steam, or other platforms. We do
not collect or store any payment card information for purchases on our
Services.
-
Your Communications with Us. We may collect personal
information, such as email address, phone number, or mailing address
when you request information about our Services, register for our
mailing list, complete the “Contact Us” form on our website, request
customer or technical support, apply for a job, or otherwise communicate
with us.
-
Surveys. We may contact you to participate in surveys.
If you decide to participate, you may be asked to provide certain
information, which may include personal information.
-
Interactive Features. We and others who use our
Services may collect personal information that you submit or make
available through our interactive features (e.g., forums, blogs, and
social media pages). Any information you provide on the public sections
of these features will be considered “public”, unless otherwise required
by applicable law, and is not subject to the privacy protections
referenced herein. Please exercise caution before revealing personal
information to strangers via our Services.
-
Sweepstakes or Contests. We may collect personal
information you provide for any sweepstakes or contests that we offer.
In some jurisdictions, we are required to publicly share information of
sweepstakes and contest winners.
-
Conferences, Trade Shows, and Other Events.
We may collect personal information from individuals when we attend
conferences, trade shows, and other events.
-
Business Development and Strategic Partnerships.
We may collect personal information from individuals and third parties
to assess and pursue potential business opportunities.
-
Job Applications. We may post job openings and
opportunities on our Services. If you reply to one of these postings by
submitting your application, CV and/or cover letter to us, we will
collect and use your information to assess your qualifications.
B. Information Collected Automatically
We may collect personal information automatically when you use our
Services:
-
Automatic Data Collection. We may collect certain
information automatically when you use our Services, such as your
Internet protocol (IP) address, user settings, MAC address, cookie
identifiers, mobile carrier, mobile advertising and other unique
identifiers, browser or device information, general location information
(including approximate location derived from IP address), and hardware
information such as your GPU (type and clock speed), CPU (type and clock
speed), system memory, graphics memory, OS locale, time zone, and
Internet service provider. We may also automatically collect information
regarding your use of our Services, such as pages that you visit before,
during and after using our Services, information about the links you
click, the types of content you interact with, the frequency and
duration of your activities, and other information about how you use our
Services.
-
Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or
other functionality on our Services, may use cookies, pixel tags, local
storage, and other technologies (“Technologies”) to automatically
collect information through your use of our Services.
-
Cookies. Cookies are small text files placed in device
browsers that store preferences and facilitate and enhance your
experience.
-
Pixel Tags/Web Beacons. A pixel tag (also known as a
web beacon) is a piece of code embedded in our Services that collects
information about engagement on our Services. The use of a pixel tag
allows us to record, for example, that a user has visited a particular
web page or clicked on a particular advertisement. We may also include
web beacons in e-mails to understand whether messages have been opened,
acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
-
Operationally Necessary. This includes Technologies
that allow you access to our Services, applications, and tools that are
required to identify irregular website behavior, prevent fraudulent
activity and improve security or that allow you to make use of our
functionality;
-
Performance-Related. We may use Technologies to assess
the performance of our Services, including as part of our analytic
practices to help us understand how individuals use our Services (see Analytics below);
-
Functionality-Related. We may use Technologies that
allow us to offer you enhanced functionality when accessing or using our
Services. This may include identifying you when you sign into our
Services or keeping track of your specified preferences, interests, or
past items viewed;
Advertising- or Targeting-Related. We may use first party
or third-party Technologies to deliver content, including ads relevant to
your interests, on our Services or on third-party websites.
See Section 5 below to understand your choices regarding these
Technologies.
-
Analytics. We may use Technologies and other
third-party tools to process analytics information on our Services, such
as Google Analytics. For more information, please visit
Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your
information, please click
here.
-
Social Media Platforms. Our Services may contain social media buttons such as Twitter (that might include
widgets such as the “share this” button or other interactive mini
programs). These features may collect your IP address, which page you
are visiting on our Services, and may set a cookie to enable the feature
to function properly. Your interactions with these platforms are
governed by the privacy policy of the company providing it.
C. Information Collected from Other Sources
We may obtain information about you from other sources, including through
third-party services and organizations. For example, if you access our
Services through a third-party application, such as an app store, a
third-party login service, or a social networking site, we may collect
information about you from that third-party application that you have made
available via your privacy settings.
3. HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to
provide our Services, for administrative purposes, and to market our
products and Services, as described below
A. Provide Our Services
We use your information to fulfil our contract with you and provide you
with our Services, such as:
- Managing your information and accounts;
-
Providing access to certain areas, functionalities, and features of our
Services, including game play;
- Answering requests for customer or technical support;
-
Communicating with you about your account, activities on our Services,
and policy changes; and
-
Processing applications if you apply for a job we post on our Services.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
-
Pursuing our legitimate interests such as direct marketing, research and
development (including marketing research), network and information
security, and fraud prevention;
-
Detecting security incidents, protecting against malicious, deceptive,
fraudulent or illegal activity, and prosecuting those responsible for
that activity;
- Measuring interest and engagement in our Services;
-
Short-term, transient use, such as contextual customization of ads;
- Improving, upgrading or enhancing our Services;
- Developing new products and Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Debugging to identify and repair errors with our Services;
-
Auditing relating to interactions, transactions and other compliance
activities;
- Enforcing our agreements and policies; and
- Complying with our legal obligations.
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and
advertisements. We may provide you with these materials as permitted by
applicable law.
Some of the ways we market to you include email campaigns.
If you have any questions about our marketing practices or if you would
like to opt out of the use of your personal information for marketing
purposes, you may contact us at any time as set forth in Section 13 below.
D. Other Purposes
We also use your information for other purposes as requested by you or as
permitted by applicable law.
-
Consent. We may use personal information for other
purposes that are clearly disclosed to you at the time you provide
personal information or with your consent.
-
De-identified and Aggregated Information. We may use
personal information and other information about you to create
de-identified and/or aggregated information, such as de-identified
demographic information, de-identified location information, information
about the device from which you access our Services, or other analyses
we create.
-
Share Content with Friends. Our Services may offer
various tools and functionalities. For example, we may allow you to
provide information about your friends through our referral services.
Our referral services may allow you to forward or share certain content
with a friend, such as an email inviting your friend to use our
Services.
4. HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third parties for a variety of business
purposes, including to provide our Services, to protect us or others, or
in the event of a major business transaction such as a merger, sale, or
asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information
are described below.
-
Service Providers. We may share your personal
information with our third-party service providers who use that
information to help us provide our Services. This includes service
providers that provide us with IT support, hosting, payment processing,
customer service, and related services.
-
Business Partners. We may share your personal
information with business partners to provide you with a product or
service you have requested. We may also share your personal information
to business partners with whom we jointly offer products or services.
-
APIs/SDKs. We may use third-party Application Program
Interfaces (“APIs”) and software development kits (“SDKs”) as part of
the functionality of our Services. For more information about our use of
APIs and SDKs, please contact us as set forth in Section 13 below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated
with you to external parties if we, in good faith, believe doing so is
required or appropriate to: comply with law enforcement or national
security requests and legal process, such as a court order or subpoena;
protect your, our, or others’ rights, property, or safety; enforce our
policies or contracts; collect amounts owed to us; or assist with an
investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset
Transfers
If we are involved in a merger, acquisition, financing due diligence,
reorganization, bankruptcy, receivership, purchase or sale of assets, or
transition of service to another provider, your information may be sold or
transferred as part of such a transaction, as permitted by law and/or
contract.
5. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have
about your personal information are determined by applicable law and are
described below.
-
Email and Telephone Communications. If you receive an
unwanted email from us, you can use the unsubscribe link found at the
bottom of the email to opt out of receiving future emails. Note that you
will continue to receive transaction-related emails regarding products
or Services you have requested. We may also send you certain
non-promotional communications regarding us and our Services, and you
will not be able to opt out of those communications (e.g.,
communications regarding our Services or updates to our Terms or this
Privacy Policy).
We process requests to be placed on do-not-mail, do-not-phone, and
do-not-contact lists as required by applicable law.
-
Mobile Devices. We may send you push notifications
through our mobile application. You may opt out from receiving these
push notifications by changing the settings on your mobile device. With
your consent, we may also collect precise location-based information if
you use our mobile application. You may opt out of this collection by
changing the settings on your mobile device.
-
“Do Not Track.” Do Not Track (“DNT”)
is a privacy preference that users can set in certain web browsers.
Please note that we do not respond to or honor DNT signals or similar
mechanisms transmitted by web browsers.
-
Cookies and Interest-Based Advertising. You may stop or
restrict the placement of Technologies on your device or remove them by
adjusting your preferences as your browser or device permits. However,
if you adjust your preferences, our Services may not work properly.
Please note that cookie-based opt-outs are not effective on mobile
applications. However, you may opt-out of personalized advertisements on
some mobile applications by following the instructions for
Android, iOS and
others.
The online advertising industry also provides websites from which you may
opt out of receiving targeted ads from data partners and other advertising
partners that participate in self-regulatory programs. You can access
these and learn more about targeted advertising and consumer choice and
privacy by visiting the
Network Advertising Initiative,
the Digital Advertising Alliance,
the European Digital Advertising Alliance, and
the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each
device.
Your Privacy Rights. In accordance with applicable law,
you may have the right to:
-
Access Personal Information about you, including: (i)
confirming whether we are processing your personal information; (ii)
obtaining access to or a copy of your personal information;
-
Request Correction of your personal information where
it is inaccurate, incomplete or outdated. In some cases, we may provide
self-service tools that enable you to update your personal information;
-
Request Deletion, Anonymization or Blocking of your
personal information when processing is based on your consent or when
processing is unnecessary, excessive or noncompliant;
-
Request Restriction of or Object to our processing of your personal information when processing is
noncompliant;
-
Withdraw your Consent to our processing of your
personal information. If you refrain from providing personal information
or withdraw your consent to processing, some features of our Service may
not be available;
-
Request data portability and
receive an electronic copy of personal information that you have
provided to us; and
-
Be informed about third parties with which your
personal information has been shared.
If you would like to exercise any of these rights, please contact us as
set forth in Section 13 below. We will process such requests in accordance
with applicable laws
6. SECURITY OF YOUR INFORMATION
We take steps to ensure that your information is treated securely and in
accordance with this Privacy Policy. Unfortunately, no system is
100% secure, and we cannot ensure or warrant the security of any
information you provide to us. We have taken appropriate safeguards to
require that your personal information will remain protected and require
our third-party service providers and partners to have appropriate
safeguards as well. To the fullest extent permitted by applicable law, we
do not accept liability for unauthorized disclosure.
By using our Services or providing personal information to us, you agree
that we may communicate with you electronically regarding security,
privacy, and administrative issues relating to your use of our Services.
If we learn of a security system’s breach, we may attempt to notify you
electronically by posting a notice on our Services, by mail or by sending
an email to you.
7. INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored
anywhere in the world, including, but not limited to, the United States or
other countries, which may have data protection laws that are different
from the laws where you live. We endeavor to safeguard your information
consistent with the requirements of applicable laws.
8. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy
Policy for as long as you use our Services or as necessary to fulfill the
purpose(s) for which it was collected, provide our Services, resolve
disputes, establish legal defenses, conduct audits, pursue legitimate
business purposes, enforce our agreements, and comply with applicable
laws.
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental Notice for California Residents only applies to our
processing of personal information that is subject to the California
Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California
residents with the right to know what categories of personal information
Company has collected about them and whether Greensky Games disclosed that
personal information for a business purpose (e.g., to a service provider)
in the preceding 12 months. California residents can find this information
below:
Category of Personal Information Collected by Greensky Games
Category of Third Parties Information is Disclosed to for a Business
Purpose
Identifiers.
An alias, online identifier, Internet Protocol address, or other similar
identifiers.
- Service providers
- Game platforms
- Dependent services used to operate the games
Personal information categories listed in the California Customer
Records statute (Cal. Civ. Code § 1798.80(e))
A name or other similar identifiers as listed above.
- Service providers
- Game platforms
- Dependent services used to operate the games
Internet or other electronic network activity
Information on a consumer’s interaction with an internet website or
application.
Biometric information
Biological characteristics such as a player’s calibrated height.
- Service providers
- Game platforms
Sensory data
Audio, electronic, visual, thermal, or similar information.
- Service providers
- Game platforms
- Dependent services used to operate the games
Professional or employment-related information (job applicants
only)
Current or past job history or performance evaluations.
The categories of sources from which we collect personal information and
our business and commercial purposes for using personal information are
set forth above in “Personal Information We Collect” and “How We Use Your
Information” above.
“Sales” of Personal Information under the CCPA
For purposes of the CCPA, we do not “sell” personal information, nor do we
have actual knowledge of any “sale” of personal information of minors
under 16 years of age.
Additional Privacy Rights for California Residents
-
Non-Discrimination. California residents have the right
not to receive discriminatory treatment by us for the exercise of their
rights conferred by the CCPA.
-
Authorized Agent. Only you, or someone legally
authorized to act on your behalf, may make a verifiable consumer request
related to your personal information. You may also make a verifiable
consumer request on behalf of your minor child. To designate an
authorized agent, please contact us as set forth in Section 13 below.
-
Verification. To protect your privacy, we will take the
following steps to verify your identity before fulfilling your request.
When you make a request, we will ask you to provide sufficient
information that allows us to reasonably verify you are the person about
whom we collected personal information or an authorized representative,
which may include your name, email address, or Game Platform User ID.
If you are a California resident and would like to exercise any of your
rights under the CCPA, please contact us as set forth in Section 13 below.
We will process such requests in accordance with applicable laws.
Accessibility. This Privacy Policy uses industry-standard
technologies and was developed in line with the World Wide Web
Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or
by saving the page as a PDF.
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale
of certain Personal Information to third parties who intend to license or
sell that Personal Information. Please note that we do not currently sell
your Personal Information as sales are defined in Nevada Revised Statutes
Chapter 603A. If you have any questions, please contact us as set forth in
Section 13 below.
11. CHILDREN’S INFORMATION
The Services are not directed to children under 13 (or other age as
required by local law), and we do not knowingly collect personal
information from children.
If you are a parent or guardian and wish to review information collected
from your child, or have that information modified or deleted, you may
contact us as described in Section 13 below. If we become aware that a
child has provided us with personal information in violation of applicable
law, we will delete any personal information we have collected, unless we
have a legal obligation to keep it, and terminate the child’s account
and/or revert them to the underage experience, as applicable.
12. OTHER PROVISIONS
Third-Party Websites/Applications. The Services may
contain links to other websites/applications and other
websites/applications may reference or link to our Services. These
third-party services are not controlled by us. We encourage our users to
read the privacy policies of each website and application with which they
interact. We do not endorse, screen or approve, and are not responsible
for, the privacy practices or content of such other websites or
applications. Providing personal information to third-party websites or
applications is at your own risk.
Supervisory Authority. If you are
located in the European Economic Area, Switzerland, the United Kingdom or
Brazil, you have the right to lodge a complaint with a supervisory
authority if you believe our processing of your personal information
violates applicable law.
Changes to our Privacy Policy. We may revise this Privacy
Policy from time to time in our sole discretion. If there are any material
changes to this Privacy Policy, we will notify you as required by
applicable law. You understand and agree that you will be deemed to have
accepted the updated Privacy Policy if you continue to use our Services
after the new Privacy Policy takes effect.
13. CONTACT US
If you have any questions about our privacy practices or this Privacy
Policy, or to exercise your rights as detailed in this Privacy Policy,
please contact us at:
contact@brightmotive.site