PLAYBUCKS LLC

PRIVACY POLICY

Last Updated: September 11, 2023

PlayBucks LLC (“PlayBucks”, “we,” “our” or “us”) is committed to respecting the privacy and security of your personal information. We collect personal information when you access or use our mobile application or website, or the services offered through the mobile application or website,  or our other products and services (collectively, the “Services”). The following privacy policy (“Privacy Policy”) describes the information we collect and how we use it. By using our Services, you consent to our Privacy Policy.

We may periodically update this Privacy Policy to reflect material changes in how we collect, use, share or store your personal information. We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current Privacy Policy. You consent to any changes we make to this Privacy Policy if you continue to use the Services after receiving a notice of the change or upon our posting of the new Privacy Policy.

This Privacy Policy informs you about:

(1)   the personal information we collect and how we collect it;

(2)   how we use and disclose the personal information;

(3)   how we protect your personal information;

(4)   our practices regarding the personal information of children;

(5)   third party data practices;

(6)   how you can access and change the personal information we store about you; and

(7)   how you can contact us with any questions or concerns.

1.         COLLECTING PERSONAL INFORMATION

Personal Information. As used in this Privacy Policy, the term “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to, directly or indirectly, a particular consumer or household. The personal information we collect about you includes individual identifiers and demographic information, internet and network activity, and location information. Personal information does not include, publicly available information from government records, Deidentified Information or Aggregate Information, or in circumstances when certain laws require separate privacy notices or are exempt from general personal information privacy policy disclosure requirements. “Deidentified Information” means information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular individual, and for which PlayBucks has implemented technical safeguards and business processes that prohibit reidentification of the individual. “Aggregate Information” means information that relates to a group or category of individuals, from which individual identities have been removed, that is not linked or reasonably linkable to any individual or household, including via a device.

The following are the types of personal information we collect and the sources we collect them from:

Personal information You Give Us. We collect information you provide directly or indirectly to us, such as when you create or modify your account, request on-demand services, redeem your rewards, contact customer support, or otherwise communicate with us. This information may include: name, email, mailing address, age, gender, social media profiles, phone number, and PayPal information. During the registration process, we will also collect information such as your IP address and Google Advertising ID (together, the “ID”).

If you sign into our Services using a third-party profile, we will import the first name and last name displayed in such profiles, such as information on Facebook or Google, on our platform.

Automatically Collected Personal Information. We may receive and store certain types of personal information from you each time you use the Services. We may also receive and store information about the device you used to access the Services. Information we collect automatically may include:

•        Hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, and mobile network information, and in some cases, browser type, Internet service provider, referring/exit pages and URLs, or clickstream data;

•        IP address, unique device identifiers, advertising identifiers, device serial numbers, and similar identifiers;

•        App activity data, including which third party apps you have installed and data related to the use of third party apps installed via our Services;

•        Approximate geolocation data, zip/postal code (inferred from your IP address, using publicly available data); and/or

•        Scores and achievements,  points (which may include "PlayBucks" or "BlastBucks" as a virtual currency) accrued, and other information as reasonably required to offer and enhance our Services.

The technologies we use for this automatic data collection may include: 

·         Cookies. Cookies are small data files stored on your hard drive by a website. Among other things, cookies help us improve our Services and improve your experience of our Services by analyzing the way you use our Services. you can set your browser to not accept cookies, but that may prevent us from providing you with the full range of Services we offer. Also, please be aware that if you visit other websites you may be required to accept cookies. The use of cookies placed by third parties on other websites is not covered by this Privacy Policy. We do not have access or control over such cookies.

·         Web Beacons. Web beacons are electronic images that may be used in our Services or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.

·         Other. We may also use clear gifs or other data files or identifiers to collect personal information for statistical purposes and to improve and develop the Services we provide. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are placed on a hard drive, clear gifs are embedded invisibly on web pages.  

We also may use these technologies to collect personal information about your online activities over time and across third-party websites or other online services (behavioral tracking). We do not respond to browser-based “do not track” signals. Some third party sites who push content to our Services may keep track of your browsing activities over time and across different websites when they serve you content, which enables them to tailor what they present to you.

We may use third-party Service providers to monitor and analyze the use of our Service.

When you use our Services, we will also collect information about how you interact with the games advertised on our platform. The type of information we collect relates to: i) achievements that are unlocked, ii) in-game purchases, iii) other apps on your device, iv) the time you spend playing games, v) the units you’ve earned in PlayBucks, and vi) the game experience earned (collectively “User Gaming Profile”). A User Gaming Profile is visible to other users via the chat social networking feature.

 

 

 

 

Biometric Data

By using our Services and accepting our Privacy Policy, you understand that requesting a reward within the PlayBucks mobile application may only be possible upon additional user authentication via face verification. Your consent applies to the processing of such biometric data, and is an express acknowledgement that such data is “special category” personal information pursuant to Article 9 of the General Data Protection Regulation (GDPR).

We will use your face verification exclusively for fraud prevention. Upon redeeming a reward from, you may be prompted to provide a facial image using your mobile device’s camera. This facial image provides us with a face map (a mathematical representation of your face generated through our third party provider). This facial image is encrypted on your mobile device before being sent to our servers for processing, and is linked to your user account to ensure the uniqueness of your user registration within the mobile application. If you do not want to redeem rewards through the Services, you can use all other features of the mobile application without providing a facial image.

Permissions

In providing our Services, we may need you to allow certain “permissions” on your device, which will enable information collection and usage relevant to those functions. These include the permissions described in the list below. Please take note that we may revise and update this list from time to time, for the reasons such as update or revision of our product, technology upgrading, like changes in your phone’s operating system, or legal and policy requirements.

PERMISSION       RELATED FUNCTIONS PURPOSE OF PERMISSIONS

ACCESS_NETWORK_STATE   Allows applications to access information about networks making the application work properly.

ACCESS_NOTIFICATION_POLICY   Marker permission for applications that wish to access notification policy.        Receiving notifications

ACCESS_FINE_LOCATION      Allows an app to access precise location.   Providing local content

PACKAGE_USAGE_STATS      Allows an app to collect component usage statistics          Judge task completion

SYSTEM_ALERT_WINDOW   Allows an app to create windows.     Message prompt.

The specific way to review the status of such permissions and deny them may vary in different devices. Please refer to the notes or instructions provided by relevant device OEMs and OS developers. If you are unable to carry out relevant steps and adjust the settings in your currently-used product or device, please contact us or the OEM of your device.

Please note that when you deny or disable the permissions in whole or in part, it means you have refused to provide related information to us, therefore also making us unable to provide you those functions relevant to such permissions. To the extent allowed by applicable laws, your decision to deny a certain permission on your device does not affect or invalidate our previous handling of your relevant information based on your prior consent to allow such permission.

 

 

2.         USING PERSONAL INFORMATION

Our primary purpose in collecting personal information is to provide you with the Services.  We may also use and disclose your personal information for various purposes, including without limitation:

·         To improve our Services;

·         To confirm that you are an actual person and not a bot;

·         To respond to any questions or concerns that you may have;

·         To track engagement activity;

·         To track targeted users for marketing purposes and event announcements;

·         To improve marketing strategy and goal setting;

·         To ship items that you have ordered through our Services;

·         Enabling you to redeem rewards earned on our platform;

·         To perform internal operations, including, conducting data analysis, testing and research and to troubleshoot software bugs and operational problems;

·         To monitor and analyze usage and activity trends;

·         Personalization of ads to provide you with better recommendations of advertised games in your country and to help you earn rewards;

·         For market research and automation, project planning, troubleshooting problems, detecting and protecting against errors, fraud, or other criminal activity;

·         To better understand your needs and provide you with more personalized Services; and

·         To fulfil other legitimate purposes permitted by applicable law.

3.         DISCLOSING PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may share your personal information in the following circumstances:

·         To third-party contractors that provide services to us and are contractually bound to safeguard your personal information (i.e., website hosting providers, payment processors, log monitoring analysts, forensic data scientists, user data analysts, marketing assistants, and other service providers for legitimate purposes permitted by applicable law);

·         To our wholly-owned companies and affiliates, which may be outside the United States;

·         To third parties in connection with any merger, acquisition, reorganization, change in capital structure or sale of all or part of the business or makes a sale or transfer of assets of PlayBucks;

·         To third parties designated by you with your express consent;

·         When we have a good faith belief that disclosure is necessary to comply with law, protect or defend our rights or the rights of other users of our Services, or act in an emergency to protect someone’s safety; or

·         Otherwise with your express consent.

We may create Deidentified Information or Aggregate Information from the personal information we collect. We may use that Deidentified Information or Aggregate Information for our own purposes or disclose it to third parties in our own discretion.

Internet Advertising.

We may work with third-party advertising partners in the event that we serve third party advertisements within our Services. In such case, we may share information about you (including your approximate location, advertising identifiers, gender and age) with these partners to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads. We or they may also employ cookies or similar technologies, as described above, to ensure appropriate advertising and personalized experiences.

If you would prefer to opt out of having information about you usage used for interest-based advertising, you may do so through your device settings (“Limit Ad Tracking” on iOS and “Opt Out of Ads Personalization” on Android). Depending on your location, we may be required to obtain your consent prior to obtaining your personal information, including for interest-based advertising purposes, in which case we will present you with consent options when you access the Services. Please note that if you opt out or fail to provide consent, you may continue to receive generic ads that are not based on your preferences.

4.         PROTECTING YOUR PERSONAL INFORMATION

We take reasonable steps to help protect your personal information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction. We comply with applicable laws and follow reasonable standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure and we do not guarantee its absolute security. Please contact us as described below if you have any questions about security of our Services.

5.     PROCEDURES REGARDING CHILDREN

Our Services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to us using the Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any personal information through the Services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that personal information. If you believe we might have any personal information from or about a child under 13, please contact us at described below.

6.         THIRD PARTIES

The Services may include links, content, and advertisements from third parties. Such links, content, and advertisements are not endorsements, authorizations or representations of our affiliation with that third party. We are not responsible for the privacy practices or the content of third parties, and we encourage you to carefully review the privacy policy of any website you visit. Advertising agencies, advertising networks, and other companies who may place advertisements through our Services may use their own cookies, pixel tags, web beacons, web bugs and other technology to collect personal information about you. We do not control these companies’ use of such technology and we have no responsibility for the use of such technology by these companies to gather personal information about you. 

7.         HOW TO ACCESS, MODIFY OR DELETE YOUR PERSONAL INFORMATION

You can make the following choices regarding your personal information: 

·               Access your personal information. you may request access to your personal information by contacting us as described below.  We will grant you reasonable access to the data that we have about you as required by law. 

·               Modify your personal information. To modify the personal information you have provided during registration, please login and update your personal settings on the Services. Note that we may keep historical personal information in our backup files as permitted by law.  If our Services do not permit you to update or correct certain personal information, please contact us as described below.

·               Deletion of your personal information. If you request your personal information be deleted or if you unsubscribe from communications, we may need to retain certain personal information for recordkeeping purposes, as required under applicable legal obligations, or to complete any transactions that you began prior to requesting such change or access. When updating or deleting your personal information, we may ask you to verify your identity before we can act on your request. We will comply with your request as soon as reasonably practicable and in accordance with applicable.

·               Retention of your personal information. PlayBucks retains your personal information for so long as your account is active or as needed to provide you with Services or to fulfill our contractual obligations, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, or for so long as is necessary for the purposes for which we collected such personal information.

8.         OPTING OUT

We want to communicate with you only if you want to hear from us. you can make the following choices to opt out of certain activities regarding your personal information:

·               Promotional E-Mails. To unsubscribe from a promotional email, please follow the instructions in any email you receive. If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your account, to fulfill orders you have made, to ask you to rate a Service you have used, or event you attended.

·               Behavioral-Based Advertising. We participate in behavioral-based advertising, as such, if you wish to limit third parties’ collection of information about your use of our Services, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe.  PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

9.         RESIDENTS OF CALIFORNIA

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Services do not respond to Do Not Track signals.

However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked.

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below, and include the email address associated with your account.

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.

10.            CCPA/CPRA PRIVACY NOTICE (CALIFORNIA PRIVACY RIGHTS)

This privacy notice section for California residents supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which we may collect from California residents.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information are in fact collected by us,  but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: Yes (facial images for authentication purposes only).

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: yes.

Category L: Sensitive personal information.

Examples: Account login and password information, geolocation data.

Collected: Yes.

Under CCPA/CPRA, personal information does not include:

Publicly available information from government records

Deidentified or aggregated consumer information

Information excluded from the CCPA/CPRA's scope, such as:

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Use of Personal Information

We may use or disclose personal information we collect for "business purposes" or "commercial purposes" (as defined under the CCPA/CPRA), which may include the following examples:

To operate our Services and provide you with our Services.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Services.

To fulfill or meet the reason you provided the information. For example, if you share your contact information to ask a question about our Services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase our Services, we will use that information to process your payment and facilitate delivery.

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/CPRA.

For internal administrative and auditing purposes.

To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Other one-time uses.

Please note that the examples provided above are illustrative and not intended to be exhaustive.

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, we will update this Privacy Policy.

 

Disclosure of Personal Information

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D: Commercial information

Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed,   but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be disclosed.

When we disclose personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sharing of Personal Information

We may share your personal information identified in the above categories with the following categories of third parties:

Service providers

Payment processors

Our affiliates

Our business partners

Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services We provide to you

Sale of Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow service providers to use your personal information for the business purposes described in this Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

We may sell the following categories of personal information:

•        Category A: Identifiers

•        Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

•        Category D: Commercial information

•        Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold,  but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us.

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.

 

 

Your Rights under the CCPA/CPRA

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

The right to notice. you have the right to be notified which categories of personal information are being collected and the purposes for which the personal information is being used.

The right to know/access. Under CCPA/CPRA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, 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 purposes for collecting or selling 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;

If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:

The categories of personal information categories sold;

The categories of personal information categories disclosed;

The right to say no to the sale or sharing of personal information (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request, please contact us.

The right to correct personal information. You have the right to correct or rectify any inaccurate personal information about you that we collected. Once we receive and confirm your request, we will use commercially reasonable efforts to correct (and direct our service providers to correct) your personal information, unless an exception applies.

The right to limit use and disclosure of sensitive personal information. You have the right to request to limit the use or disclosure of certain sensitive personal information We collected about you, unless an exception applies. To submit, please or contact us.

The right to delete personal information. You have the right to request the deletion of your personal information under certain circumstances, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers 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, 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 et. 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.

The right not to be discriminated against. you have the right not to be discriminated against for exercising any of your consumer's rights, including by:

Denying goods or services to you;

Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties;

Providing a different level or quality of goods or services to you; or

Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising your CCPA/CPRA Data Protection Rights

Please see the "Do Not Sell My Personal Information" section and "Limit the use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected.

Additionally, in order to exercise any of your rights under the CCPA/CPRA, and if you are a California resident, you can contact us:

By email: support@playbucks.co

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.

Your request to us must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with the required information if we cannot:

Verify your identity or authority to make the request; and

And confirm that the personal information relates to you.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

We do not sell personal information as the term sell is commonly understood. We do allow service providers to use your personal information for the business purposes described in our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA.

You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us.

The service providers we partner with (for example, our analytics or advertising partners) may use technology on the Services that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser you use. you may need to opt out on every browser that you use.

 

10.              EUROPEAN ECONOMIC AREA VISITORS

GDPR Privacy

Legal Basis for Processing Personal  Information under GDPR

We may process personal information under the following conditions:

Consent: you have given your consent for processing personal information for one or more specific purposes.

Performance of a contract: Provision of personal information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.

Legal obligations: Processing personal information is necessary for compliance with a legal obligation to which PlayBucks is subject.

Vital interests: Processing personal information is necessary in order to protect your vital interests or of another natural person.

Public interests: Processing personal information is related to a task that is carried out in the public interest or in the exercise of official authority vested in PlayBucks.

Legitimate interests: Processing personal information is necessary for the purposes of the legitimate interests pursued by PlayBucks.

In any case, PlayBucks will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

PlayBucks undertakes to respect the confidentiality of your personal information and to guarantee you can exercise your rights.

You have the right under this Privacy Policy, and by law if you are within the EEA, to:

Request access to your personal information. The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the personal information we hold about you.

Request correction of the personal information that we hold about you. you have the right to have any incomplete or inaccurate information We hold about you corrected.

Object to processing of your personal information. This right exists where we are relying on a legitimate interest as the legal basis for your processing and there is something about your particular situation, which makes you want to object to our processing of your personal information on this ground. you also have the right to object where We are processing your personal information for direct marketing purposes.

Request erasure of your personal information. you have the right to ask us to delete or remove personal information when there is no good reason for us to continue processing it.

Request the transfer of your personal information. We will provide to you, or to a third-party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where We used the information to perform a contract with you.

Withdraw your consent. You have the right to withdraw your consent on using your personal information. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Service.

Exercising of your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

 

11.              INTERNATIONAL OPERATIONS

PlayBucks is based, and our Services are hosted, in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein.

 

12.              CONTACTING US

We welcome your questions, comments, and concerns about privacy, including any data privacy complaints. Please contact us by email at: support@playbucks.co. Or mailing us at:

PlayBucks LLC
Attn: PlayBucks Privacy Agent
3031 Tisch Way
110 Plaza West, PMB#129
San Jose, CA 95128

If PlayBucks needs, or is required, to contact you concerning any event that involves personal information about you, we may do so by email, telephone, or mail. 

We are committed to working with you to obtain a fair resolution of any privacy concern.