Effective Date: May 24th 2018
Last Modified: May 24th, 2018
We are committed to the protection of your privacy while you use the TSG Network and access the Services.
Who are we and how can you contact us?
We are, as stated above, Truly Social Games, LLC. We collect and process your Personal Data, as well as manage our third-party service providers that additionally process your Personal Data.
The best way to contact us is through our dedicated customer service email, firstname.lastname@example.org or through the form on our mobile application in the Settings section.
You can also reach us as follows:
Truly Social Games, LLC
6915 SW Macadam Ave.
Portland, OR 97219
Data Protection Officer: Patrick Tougas
What Personal Data do we collect from you and why?
Through your visitation to, use of, and interaction with the TSG Network, you may be asked for certain types of Personal Data. You don’t have to register to use our Services, but if you choose to do so, you will be subject to voluntary data collection. This section will only cover the Personal Data that we receive specifically from you.
Personal Data collected when/if you register with us: If you register to use the TSG Network, you can do so through Facebook. TSG will receive general profile information from Facebook, such as your first name, last name, email address, and any public information you’ve made available, such as your gender, age, birthday, friends list, and public photos. TSG may not utilize this Personal Data, and only receives it through Facebook for the purposes of your registration to provide the Services to you. By registering with us, we’ll be able to better serve you, and provide a more personalized user experience for you each time that you visit us.
Personal Data collected for challenge winners: As noted in the TSG Terms & Conditions (https://trulysocialgames.com/terms-conditions/), TSG permits challenges whereby prizes are received by winners. If you are a winner of a TSG challenge, we will send you an email to the email address you provide to request some information in order to validate your win and send your physical prize, if applicable. We will ask you for your First Name, Last Name, Address, and Phone Number. None of this information is ever collected automatically, however, and is instead asked for and received by TSG on a one-to-one basis.
Personal Data collected for billing: As a user of the TSG Network, you may wish to make purchases on or through Planet Gold Rush. Through in-app purchases, you will receive access to virtual goods and virtual currency for our game play. Billing is done exclusively through the online application store through which you downloaded the application, either the Apple App Store (through iTunes) or the Google Play Store. Information such as credit or debit card number, billing address, and verification may be requested by the respective third-party. Thus, the user agreement provided by the Apple App Store and the Google Play Store are applicable to your in-app purchases. TSG does not collect or store any billing information, and in-app purchase options are provided exclusively for the purposes of improving our Planet Gold Rush game play for all users.
Personal Data collected when we’re communicating: As a user of the TSG Network, we may communicate with you about your account with us. These communications specifically won’t be marketing communications, but will rather be informational items, such as updates to our policies or other privacy-related matters (in other words, you won’t be able to opt-out of these important messages). You may also be asked questions about how to improve TSG, or you may, at some point, communicate with our representatives because of questions that you have. In that case, we’ll receive your first name, last name, and email address. We consider this information Personal Data. We collect this information so that we can help with anything you need and to continue improving our Services in the future.
What Personal Data do we collect about you that we get from other sources and why?
Geolocation data: We may collect information about your location depending on the permissions you have set on your device. We solely and exclusively use this information to provide you with our Services, including to update your time zone and validate any challenge wins. You can enable or disable location Services when you use our Services at any time, through your device settings, but please be advised that you may not be permitted to have a validated challenge win unless we can confirm your location through our geolocation data. Disabling our access to your geolocation data may result in a disqualification to the Challenge.
Usage Data: We may also collect information about the use of our Services, such as general data about your interactions with Planet Gold Rush and with other users. We collect this data to help us troubleshoot any problems that may arise for you and other users, as well as to help us understand usage trends.
Log data: When you use the TSG Services we collect certain information (often called “log data” or “log information” – the same information that most websites and applications log when they are accessed). This information usually includes the browser type you used, your Internet Protocol (“IP) address, your operating system, the date and time of day, the language you use, and any referring websites. We log this information for internal business purposes. For example, this log information helps us determine how well our Services are working so that we can continually improve the quality of the TSG Network. The log information is also important for security, audit, quality improvement, and other internal business purposes.
Personal data that we combine or aggregate: We may combine or aggregate some of your Personal Data with non-personal data collected from you. While the non-personal data may already be completely anonymous, we may take the extra step of ensuring the data undergoes anonymization or pseudonymization. Either way, this non-personal data may be stored in the same location or used in conjunction with your Personal Data. In case the aggregation of your Personal Data and non-personal data allows us to identify you, we will handle such aggregated information as Personal Data.
We combine or aggregate data in order to better serve you and to better enhance and update the TSG Network for your and other consumers’ use.
What is our legal basis for processing your Personal Data?
We respect data minimization principles, which means we only collect the minimal amount of Personal Data required for legitimate business purposes, including providing the TSG Services to you.
In other words, we need the Personal Data that we do to effectively run our business and we don’t collect more than is necessary. The Personal Data you provide to us voluntarily (such as through registration, use, and communication with us) is up to you. That said, we may still process automatic Personal Data, such as that received through cookies, regardless of how you interact with TSG.
Will your Personal Data ever be shared and if so, how and with whom?
Third-Party Service Providers: We use third party service providers (those “data processors” we mentioned earlier) to help us operate the TSG Network. The third party service providers that we use help run the business, so your data will pass through them, but we don’t provide your Personal Data (or any personally identifying information) for intentional access and external usage (like for marketing list purposes, for example) to anyone.
You may find our games advertised on third party websites, mobile applications, and services. If you click on one of those advertisements and become a user of our Services, an anonymized device identifier may be shared with the advertiser to verify the installation and assist with our tracking.
For the third parties that we utilize who also process your Personal Data, we have appropriate security and contractual measures (like encryption and data processing agreements) to ensure that your Personal Data always gets treated in compliance with the policies laid out here, as well as applicable law.
Other Disclosures: In certain cases, we may have to disclose your Personal Data to third parties outside those above. We limit that disclosure to the following circumstances:
- To satisfy any local, state, or Federal laws or regulations;
- To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
- In the case of any business transfer, sale, or transfer of assets of TSG (we’ll notify you if this happens);
- To generally cooperate with any lawful investigation about our users; or
- If we suspect any fraudulent activity on the TSG Network.
We may also share anonymized information with affiliates, subsidiaries, and business partners but we will ensure that Personal Data cannot identify you in any way nor will it be stored with any data that can.
Your Consent: Otherwise, if we get your explicit, unambiguous, and prior consent to share your Personal Data with anyone, we’ll do so.
What about marketing?
We may send you marketing communications, such as newsletters and brochures, but only after we obtain your explicit consent. In other words, we’re never going to automatically add you to a mailing list or other marketing communication list – we’ll specifically ask you to opt-in to the communications you want to receive.
If you do consent to receive marketing communications through your affirmative opt-in, you’ll be receiving things like newsletters, targeted campaigns, and offerings of new products, services, promotions, or recommendations from us and our affiliates and subsidiaries. We also may send you push notifications to your mobile device, if you’ve consented to do so.
Even if you do want to get marketing messages from us, you’ll be able to revoke your consent at any time. You can do so for push notifications by deactivating the notification permissions on your mobile device. You can do so for other marketing communications by
- Clicking on the “unsubscribe” link contained in each marketing email sent to you, exclusive of the initial welcome email requesting “opt-in” for such communications;
- Sending an email to email@example.com
We’ll take you off our marketing list as soon as we can and you won’t hear from us again.
You may also find advertisements for other services (those created and operated by third parties) on the TSG Network. TSG may act as both a data controller (in that your Personal Data is provided for targeted advertisements) and a data processor (in that those companies are collecting their own personal data from customers that visit the TSG network) with regard to the entities posting the advertisements (the “Third Party Advertisers”). We request your affirmative consent prior to using your Personal Data for any targeted advertisements. Additionally, we ensure that the Privacy Policies of the Third Party Advertisers comply with the strict standards under which we process your Personal Data.
How do we store and protect your Personal Data?
Personal Data Protection: We employ organizational and technical security measures to protect your Personal Data, such as limiting access to your Personal Data, secured networks, and encryption.
We also use secure physical and digital systems to store your Personal Data. We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction by utilizing practices that are consistent with standards in the industry to protect your privacy.
Please note, however, that no system involving the transmission of information via the Internet or the electronic storage of data is completely secure, no matter what reasonable security measures are taken. Although we take the protection and storage of your Personal Data very seriously, and we take all reasonable steps to protect your Personal Data, we cannot be responsible for data breaches that occur outside of our reasonable control. We will, however, follow all applicable laws in the event a data breach occurs, including taking reasonable measures to mitigate any harm, as well as notifying you of such breaches as soon as possible, but in no event, later than two weeks time.
What are your rights in relation to your Personal Data?
By using the TSG Network, you can exercise the following rights:
- REFUSING TO PROVIDE YOUR PERSONAL DATA: The voluntary Personal Data you provide to us is an integral part of your use of the TSG Network. You can choose to forego the provision of that data, but you will be restricted from using our Services.
- WITHDRAWING CONSENT: You can withdraw your consent to the processing of your Personal Data at any time by sending an email to firstname.lastname@example.org. However, please be advised, as above, that you may be restricted from using the TSG Services. We may request identity verification to ensure we are interacting with the correct data subject.
California Privacy Rights: California Civil Code Section § 1798.83 permits users of TSG that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com.
What about the international transfer of Personal Data?
We are based in the United States. In other words, your Personal Data may be transferred from the location in which you reside to our physical location in the United States. It may also be transferred to third parties, as described above, located in the United States. The risks of transferring data outside of your jurisdiction to the United States includes the possibility of data breaches and loss, but we maintain industry standards to protect your Personal Data as much as possible.
Do we collect any Personal Data from minors?
We do not allow use of the TSG Network or any of our Services by users under the age of 16 (sixteen). As such, we don’t collect, store, or otherwise use any Personal Data from any minors under 16. If you are a parent or guardian, and you learn that your children have provided us with Personal Data, please contact us immediately. If we become aware that we have collected Personal Data from children without verification of parental consent, we will immediately take steps to remove that information from our servers.