Last Updated: July 22, 2020
INFORMATION TRIVIAMAKER COLLECTS
When you engage in certain activities via the Site, including but not limited to creating an account, sending feedback, or otherwise participating in the Site, or interacting with us offline, we collect certain information about you. We collect the following categories of information:
- Account Data, including your username, password, and information for authentication and account access.
- Billing Data, including your payment instrument number (such as a credit or debit card number), expiration date, and security code as necessary to process your payments.
- Contact Data, including your email address.
- Profile Data, including games you created, your collections, and your favorites.
- Content, including content within any messages you send to us (such as feedback and questions to customer support).
You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.
INFORMATION COLLECTED AUTOMATICALLY
In addition, we automatically collect information when you use the Site. The categories of information we automatically collect include:
- Service Use Data, including data about features you use, pages you visit, emails, and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
- Device Data, including data about your device’s identification number and device type, your device’s operating software, your internet service provider, your device’s regional and language settings, device identifiers such as IP address and Ad Id, your mobile carrier, and your mobile carrier user identification.
- Location Data, including imprecise location data (such as location derived from an IP address or data that indicated a city or postal code level) and, with your consent, location data (such as latitude/longitude data).
COOKIES AND RELATED TRACKING TECHNOLOGIES
Our Site uses tracking technologies to automatically collect information. The types of tracking technologies we use include:
Log files, which are files that record event that occur in connection with your use of the Site.
Cookies, which are small data files stored on your device that act as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Site and can be used to track your session on the Site. They expire when you close your browser. Persistent cookies are used to customize our website content for you as an individual, remember your preferences, and support security features. Additionally, persistent cookies allow us to bring you advertising off the Site. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings.
App Technologies, which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps include SDKs, including the Facebook SDK, which is code that sends information about your use to a server. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
Location-Identifying Technologies, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.
INFORMATION WE COLLECT FROM OTHER SOURCES
We also collect information from other sources. The categories of sources from which we collect information include:
- Social networks with which you interact.
- Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
- Publicly available sources, including data in the public domain.
PURPOSE FOR USING YOUR INFORMATION
- To operate, manage, and improve the Site;
- To perform services requested by you, such as respond to service requests and support customer needs more efficiently;
- To personalize user experience;
- To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- To prevent and address fraud, breach of policies or terms, and threats of harm;
- We use information in the aggregate to understand how our users as a group use the services and resources provided on the Site;
- To conduct research, including focus groups and surveys;
- To improve our Site and other TriviaMaker websites, apps, marketing efforts, products and services;
- To run a promotion, contest, or other Site feature, including verifying your eligibility and delivering prizes in connection with your winning entries;
- To develop and send advertising, direct marketing, and communications about topics we think will be of interest, and about our and other entities’ products, offers, promotions, rewards, events, and services;
- To send periodic emails;
- To fulfill any other purpose at your direction; and
- With notice to you and your consent.
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
ANALYTICS AND ADVERTISING
We use analytics services, such as Google Analytics, to help us understand how users access and use the Site. In addition, we work with agencies, advertisers, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
As part of this process, we may use tracking technologies, such as cookies, pixels, and web beacons, in the Site, including when you use or interact with our Site, marketing communications, advertising content and/or other websites, in order to provide you with relevant advertising based on your browsing activities and interests across time and services (“Interest-based Advertising”).
We also use audience matching services to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own Service, and the other party matching common factors between our data and their data or other datasets. For instance, we incorporate the Facebook pixel on our Service and may share your email address with Facebook as part of our use of Facebook Custom Audiences.
For further information on the types of tracking technologies we use on the Site and your rights and choices regarding analytics, Matched Ads and Interest-based Advertising, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.
SHARING OF INFORMATION
- Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as payment processing, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
- Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section above.
- Affiliates. We share information with our affiliates and related entities, including where they act as our service provider or for their own internal purposes.
- Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
- Promotions. Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern the promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
- Public Forums. We share information you make public through the Site, such as trivia games you submit to the Public Collections forum. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
- Mergers or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
- Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Site or anyone else.
- Facilitating Requests. We share information at your request or direction.
- Consent. We share information with notice to you and your consent.
Notwithstanding the above, we may share information that does not identify you (including information that has be aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
Some examples include:
- Links. The Site includes links that hyperlink to websites, platforms, and other services not operated or controlled by us.
- Liking, Sharing, and Logging-In. We may embed a pixel or SDK (e.g., Facebook SDK) on our Site that allows you to “like” or “share” content on, or log-in to your account through social media. If you choose to engage with such integration, we may receive information from the social network that you have authorized to share with us. Please note that the social network may independently collect information about you through the integration.
YOUR RIGHTS AND CHOICES
- How to Opt Out Of Email Communications
You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Complaints and Contact Information” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
- Push Notifications
If you use our mobile apps, we may ask if you want to receive push notifications so that we can send you updates, communications, and other messages about the Site. To opt out of getting these push notifications or other messages, you must turn off the push notification function in your device settings.
Please note that your opt-out is limited to the email address and device used and will not affect subsequent subscriptions.
- Tracking Technology Choices
Cookies and Pixels. Most browsers accept cookies by default. You can set up your browser to either let you know when you receive a cookie, to decline cookies, or to deny cookie access to your computer. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor “Do Not Track” signals or alter our information collection and usage practices when we detect such a signal from your browser. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
App and Location Technologies. You can stop all collection of information via our app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.
Please be aware that if you disable or remove tracking technologies some parts of the Site may not function correctly.
- Analytics and Interest-Based Advertising
Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.
The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).
You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt Out of Interest-Based Ads” (for Android devices).
Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt-out options or programs.
The Site is intended for general audiences and is not directed at children under 18 years old. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, or if we learn we have collected or received personal information from a child under 18, we will remove that personal information in accordance with COPPA. If you believe we have any personal information from or about your child under 18, please contact us at email@example.com. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.
If you are a California resident under 18 years old and registered to use the Site, you can ask us to remove any content or information you have posted on the Site. To make a request, email us at the email address set out in the “Complaints and Contact Information” section with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with out legal obligations, resolve disputes, and enforce our agreements.
We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.
If you subscribe to electronic newsletters or other communications from us or our website, you will have an option to unsubscribe immediately.
We fully endorse and comply with the requirements of Canada’s anti-spam legislation (CASL) and CAN-SPAM Act of 2003 (Controlling the Assault of Non-Solicited Pornography and Marketing Act), and all other applicable unsolicited commercial e-mail laws.
For more information on your rights and choices regarding promotional emails please see the “Your Rights and Choices” section above.
COMPLAINTS & CONTACT INFORMATION
Redwood Pro Media LLC
P.O. Box 912
Crescent City, CA 95531
OUR NOTICE TO NEVADA RESIDENTS
Under Nevada law, Nevada residents may opt out of the sale of certain “covered information” collected by operators of websites or online services or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please email us at firstname.lastname@example.org and provide your name and whether you would like to opt out.
OUR NOTICE TO CALIFORNIS RESIDENTS
These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.
- Notice of Collection.
In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:
- Identifiers, including name, postal address, email address, and online identifiers (such as IP address).
- Customer records, including credit or debit card information.
- Commercial or transactions information, including records of products or services purchased, obtained, or considered.
- Internet activity, including browsing history, search history, and interactions with a website, email, application, or advertisement.
- Geolocation data.
- Inferences drawn from the above information about your predicted characteristics and preferences.
For further details on information we collect, including the sources from which we receive information, review the “Information TriviaMaker Collects” section above. We collect and use these categories of personal information for the business purposes described in the “Purpose for Using Your Information” section above, including to manage our Site.
Under the CCPA, “sell” is defined broadly, and some of our data sharing practices may be considered a “sale.”
We do not generally sell information as the term “sell” is traditionally understood.
- Right to Know and Delete.
You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information was collected;
- The categories of personal information about you we disclosed for a business purpose or sold;
- The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
- The business or commercial purpose for collecting or selling the personal information; and
- The specific pieces of personal information we have collected about you.
In addition, you have the right to delete the personal information we have collected from you.
To exercise any of these rights, please submit a request through our Online Form or email us at email@example.com. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
- Right to Opt-Out.
To the extent TriviaMaker sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by emailing us at firstname.lastname@example.org.
- Authorized Agent.
You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.
- Right to Non-Discrimination.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights.
- Shine the Light.
If you are a California resident, you may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Complaints and Contact Information” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.
OUR NOTICE TO DATA SUBJECTS IN EUROPE
Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). TriviaMaker acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.
- Lawful Basis for Processing
Data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include where: (a) you have given consent to the processing for one or more specific purposes, either to us or to our service providers or partners; (b) processing is necessary for the performance of a contract with you; (c) processing is necessary for compliance with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests. Where applicable, we will transfer your personal data to third countries subject to appropriate or suitable safeguards, such as standard contractual clauses.
- Your Data Subject Rights
Your principal rights under data protection laws in Europe are:
(a) The right to access;
(b) The right to rectification;
(c) The right to erasure;
(d) The right to restrict processing;
(e) The right to object to processing;
(f) The right to data portability;
(g) The right to complain to a supervisory authority; and
(h) The right to withdraw consent at any time for any data processing we do based on consent you have provided to us.
To exercise any of these rights, please contact us as set out in the “Complaints and Contact Information” section above and specify which right you are seeking to exercise. We will respond to your request within 30 days. We may require specific information from you to help us confirm your identity and process your request.
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have any issues with our compliance, you may contact us at email@example.com. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.