PLEASE SEE BELOW FOR OUR POLICY REGARDING OUR COLLECTION OF INFORMATION FROM U.S. CHILDREN UNDER AGE 13 AND CHILDREN OUTSIDE THE U.S. UNDER AGE 16
If you are a California resident, please see “Additional Information for California Residents,” below, for more information about our practices and your rights.
Last updated December 2, 2020
WHAT IS POLYBINGO?
Polybingo provides an online tool for creating custom bingo games based on users’ personal photos or photos that are publicly available and license/royalty free. A Polybingo game (referred to as a “Polybingo”) consists of a host that is presenting and controlling the bingo game flow, and players that use their smartphones to follow the bingo game progress.
“Personal Information” is information that identifies an individual or relates to an identifiable person, including:
We need to collect and process Personal Information marked as ‘required’ in order to provide the requested Services to you, or because we are legally required to do so. If you do not provide the information that we request, we may not be able to provide the requested Services.
We do not collect any Personal Information from a person who merely plays Polybingo. Further information regarding Player Identifier is included below. In order to be able to create and host a Polybingo, however, a user (“account holder”) must create an account at https://polybingo.com/register/ or through our App. As described in more detail below, we may collect, use and disclose Personal Information from adult account holders. An “adult account holder” is a U.S. user who is age 13 or older or a user from outside the U.S. who is age 16 or older.
Our information practices are different with respect to younger users. Specifically, when a U.S. user who is under the age of 13 or a user from outside the U.S. who is under the age of 16 creates an account (a “child account holder”), we collect his or her email address only for the purpose of providing password reminders to him or her. We collect no other Personal Information from child account holders, and we immediately and permanently alter the email address such that it can only be used as a password reminder and cannot be reconstructed into its original form or used to contact the child account holder. Polybingo also collects a username and password from child account holders, which are used for login purposes only.
Player Identifier or nickname, is a game option that allows a host to track progress and status of the players’ bingo board.
We and our service providers collect Personal Information from adult account holders in a variety of ways, including:
We and our service providers use Personal Information for our legitimate business purposes, including the following:
We engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Providing you with marketing material that we believe may be of interest to you.
We engage in this activity with your consent or where we have a legitimate interest.
We provide personalized services either with your consent or because we have a legitimate interest.
We engage in these activities to manage our contractual relationship with you.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
The Personal Information of adult account holders may be disclosed:
We also use and disclose Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
We and our third party service providers collect Other Information in a variety of ways, including:
We use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We do not knowingly seek or collect Personal Information from users under the age of 13 (for U.S. users) or 16 (for non-U.S. users). If we determine we have inadvertently gathered Personal Information from users under the age of 13 (for U.S. users) or 16 (for non-U.S. users), we will promptly delete any and all such Personal Information from our records.
We and our service providers collect information that is reasonably necessary to support the internal operations of the Polybingo! Service, as described below.
When a user who is under the age of 13 (for U.S. users) or 16 (for non-U.S. users) creates an account (a “child account holder”), we collect an email address only for the purpose of providing password reminders. We immediately and permanently alter the email address such that it can only be used as a password reminder and cannot be reconstructed into its original form or used to contact the child account holder.
To permit the child account holder to use the Services, we also collect a username and password, which are used for login purposes only.
We and our service providers collect the information described above, under “Other Information,” from child account holders; however, we restrict the use of persistent identifiers for children account holders. Specifically, we utilize pseudonymous identifiers to understand, among other things, the volume of unique users using our Services, and we limit the geolocation information that we collect to no more precise than a city-wide area. Our collection persistent identifiers from child account holders does not allow us to identify, contact or create a profile of such users.
The Children’s Online Privacy Protection Act of 1998 (U.S.), the Family Educational Rights and Privacy Act (U.S.), the General Data Protection Regulation (E.U.) and other data privacy laws have been established to protect the privacy of minors. We take our compliance obligations under such laws, and the privacy of our users generally, very seriously.
If you would like to review the information we have collected from your child (i.e., his or her username and password), or if you would like to ask us to make no further use of, or delete, the information we have collected from your child, contact us as described in the “Contacting Us” section, below. In your request, please include your name and your child’s Polybingo! username and specify the action you would like us to take. For your child’s protection, we may need to verify your identity before implementing your request.
This section provides information for California residents in connection with the California Consumer Privacy Act (“CCPA”). Under the CCPA, “Personal Information” generally means information that identifies, relates to, or describes a particular California resident or household and includes the categories listed below. This section does not expand upon our practices with respect to our collection of Personal Information from children, as described above in section entitled “Our Collection of Personal Information from Children.” This section may, however, give children who are residents of California (and their parents or guardians) additional rights.
The following sections provide details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months:
Categories of Personal Information Collected. We collected the following categories of Personal Information:
A. Identifiers, such as name, IP address, email address and online identifiers;
B. Personal information, as defined in the California customer records law, such as contact and financial information;
C. Your date of birth;
D. Commercial information, such as transaction information and purchase history;
E. Internet or network activity information, such as browser and device information, app usage data, information collected through cookies, pixel tags and other technologies, demographic information and other information provided by you and aggregated information;
F. Geolocation data, such as device location, limited only to a city-wide area; and
G. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
Sources of Personal Information. We collect this Personal Information directly from California residents themselves, as well as from third-party sources, such as Google or Microsoft (if you choose to register using your Google or Microsoft account), public databases, and joint marketing partners.
Purposes. We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to otherwise accomplish our business purposes and objectives. Our business purposes and objectives include, for example, providing our products and services; developing, improving, and maintaining our products and services; personalizing, advertising, and marketing our products and services; conducting research and data analysis; undertaking quality assurance measures; conducting risk and security control and monitoring; detecting and preventing fraud; performing identity verification; performing accounting, audit, and other internal functions, such as internal investigations; complying with law, legal process, and internal policies; maintaining records; and exercising and defending legal claims.
Disclosures of Personal Information. The Personal Information of adult account holders may be disclosed:
We also use and disclose Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
Sales of Personal Information. We have not sold Personal Information. For purposes of this CCPA Notice, “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
If you are a California consumer, you have the following rights:
(A) Right to Know. You have the right to request that we disclose to you the following information covering the 12 months preceding your request:
The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
The specific pieces of Personal Information we collected about you;
The business or commercial purpose for collecting Personal Information about you; and
The categories of Personal Information about you that we disclosed and the categories of third parties to whom we disclosed such Personal Information.
(B) Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please email firstname.lastname@example.org, fill out the submission form here. or contact us as described in the “Contacting Us” section, below. In some instances, we may decline to honor your request where, for example, we are unable to verify your request or where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident.
(C)Right to be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Twitter, WhatsApp, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to these or other organizations.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
Your choices regarding our use and disclosure of your Personal Information
We give adult account holders choices regarding our use and disclosure of their Personal Information for marketing purposes. You may opt-out from receiving marketing-related emails from us on a going-forward basis by clicking the unsubscribe link in any such email. In addition, in your user settings, you may opt-out of receiving emails letting you know that a Polybingo has been shared.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or suppress your Personal Information
If you are an adult account holder and you would like to request to review, correct, update, suppress or delete Personal Information, restrict the processing of your Personal Information, object to the processing of your Personal Information, or if you would like to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.
In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. You may also delete your account by selecting “Delete My Account” when logged into the Services. You may also delete, when logged into the Services, any content or information that you have posted to the Services in the form of Polybingo’s that you have created. Please note that your actions cannot ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted or repurposed by another account holder.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.
We keep your Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship with you and provide our Services to you; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country.
If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information. You may obtain a copy of these measures by contacting us (see below under Contacting Us).
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
30 Kibbutz Galuyot Street
4051530 Even Yehuda
Because email communications are not always secure, please do not include sensitive information in your emails to us.
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA
If you are located in the EEA, you may lodge a complaint with a supervisory authority competent for your country or region.