Last Updated: May 21st, 2019
2. CATEGORIES AND USE OF INFORMATION
2.1 Account information
When you start engaging with our Platform, we collect information such as device model, OS and OS version. Additionally, our Game creates a randomized Unique Device ID (UDID). That UDID is unique to Hidden Secrets and allows us to associate all activities to a single device for sake of saving game progress and validating any prize claims.
2.2 Prize winner information
Prizes are subject to eligibility requirements, as set out in the Terms of Service. Upon winning a prize, Hidden Secrets will require you to submit your name, date of birth, address, zip/postal code, email, phone number, other legal and tax related information, along with any other information Hidden Secrets deems necessary to determine your eligibility and review and process the cash prize.
This information may be used for the purposes of:
1. Determining eligibility for accessing the Platform, playing the Game and/or claiming any cash prize;
2. in respect of the name, photo, voice, likeness information and statements about the game or winnings, for publicity and marketing, information, trade, advertising, public relations, and promotional purposes without any further compensation, notice, review or consent.
2.3 Gameplay Information
When you engage in the Platform, we will process:
1. information on how you use the Platform (such as the web pages that were visited prior to accessing the Platform; the pages or features of the Platform that were browsed and the time spent on those pages or features; search terms and the links on the Platform that were clicked on; and other group statistics); and
2. information that your device sends (like a device identifier, user settings, country, language, browser type, operating system, and location information (when location services are turned on),
and combine that information with the UDID. This information is used to improve gameplay and the Platform, to personalize the Platform for you, and for marketing purposes including direct marketing.
2.4 Email Subscription
If you elect to subscribe to our mailing list, we will collect your email address for the purposes of:
1. periodically sending you free newsletters and emails that directly promote the Platform; and
2. creating “Lookalike Audiences” and to customize content and advertising on social media websites such as Facebook.
You have the option to opt-out of receiving direct marketing communications from us. If you do not wish to continue to receive direct marketing communications from us you should opt-out by clicking on the “unsubscribe” link in any email communications that we might send you. Please note that some features of the Platform may involve us providing suggestions for additional services we offer, through the functionality within the Platform.
2.5 Website Information Collected Using Cookies and other Web Technologies
Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information on our website. Whether this information is personal to you will depend to what extent the technology can individuate you, in the sense that you are singled out and distinguished from all others.
2. “Web Beacons” (also known as web bugs, pixel tags, or clear GIFs) are tiny graphics with a unique identifier that may be included on the Platform for several purposes. For example, we may use Web Beacons to deliver or communicate with Cookies, to track and measure the performance of the Platform, to monitor how many visitors view our Platform, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s hard drive, Web Beacons are typically embedded invisibly on web pages (or in an email). We use these web beacons, such as Facebook Pixel, to customize content and advertising, to provide social media features and to analyze traffic to our website.
3. LAWFUL BASIS FOR PROCESSING
3.1 Performance of a Contract
1. In respect of the processing of information of your information for the purposes of providing the Platform, creating a UDID to associate all activities to a single device for sake of saving game progress and validating any prize claims, and discovering if you have falsified your claim to any such prizes, such processing is necessary for the performance of the contract between you and us.
3.2 Legitimate interests
2. If you are based in the European Union you have the right to object to the way we processes your information where the processing is based on legitimate interests. For more information see “Rights of EU based persons” section below for further details.
4. INFORMATION THAT WE SHARE WITH THIRD PARTIES
We will not share any of your personally identifiable information that we have collected from or regarding you except as described below:
4.1 Information Shared with Professional Advisors and Service Providers
4.2 Information Disclosed in Connection with Business Transactions
If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your information, may be disclosed or transferred to a third party acquirer in connection with the transaction. In the event of such a transaction, we will give you notice of the transaction and the opportunity for a period of 30 days to refuse disclosure or transfer of your information to the third party acquirer in connection with the transaction.
4.3 Information Disclosed for Our Protection and the Protection of Others
We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you that is in our possession or control to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to identify and stop any activity that we consider illegal, unethical, or legally actionable activity.
5. YOUR CHOICES
We offer you choices regarding the collection, use, and sharing of your information and we’ll respect the choices you make. Please note that if you decide not to provide us with the information that we request, you may not be able to access some or all of the features of the Platform.
5.1 Access and Correction of Information
1. You have the right to seek access to information which we hold about you and to correct that information if it is incorrect.
2. If you wish to exercise your rights, please contact us using the contact information below. We may require you to provide verification of your identity.
3. Please note that in certain circumstances we may withhold access to your information where we have the right to do so, for example, where disclosing the information may reveal the identity of a third party.
5.2 Rights for EU-Based Persons
Under the GDPR, if you are based in the European Union you have the right to:
1. access and correct your information.
2. in certain circumstances, have your information erased.
3. restrict the processing of your information.
4. move, copy or transfer your information easily for your own purposes across different services in a safe and secure way.
5. object to processing where we rely on our legitimate interests as the basis for processing.
6. withdraw your consent to our processing of your information where your consent is being relied on by us.
If you wish to exercise your rights please contact us at email@example.com to submit the request.
6. KEEPING YOUR INFORMATION
Following termination or deactivation of your account, Hidden Secrets, its clients, affiliates, or service providers may retain information (including your profile information) and user content for a commercially reasonable time period for backup, archival, and/or audit purposes. If you have any questions about termination or deactivation of your account, please contact us directly at firstname.lastname@example.org.
7. RESPONDING TO DO NOT TRACK SIGNALS
The Platform does not have the capability to respond to “Do Not Track” signals received from various web browsers. To learn more about browser tracking signals and “Do Not Track,” please visit http://allaboutdnt.org.
8. THE SECURITY OF YOUR INFORMATION
We take appropriate GDPR approved administrative, physical, and electronic measures designed to protect the information that we collect from or about you or your authorized child from accidental or unlawful destruction, accidental loss or unauthorized access, use, modification, interference, or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
9. INTERNATIONAL TRANSFER
Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside New Zealand and choose to provide your information to us, we may transfer your information to New Zealand and process it there. For persons based in the European Union, please note that the appropriate safeguard in place for such a transfer is an adequacy decision under Article 45 of the GDPR. Whenever we transfer your information outside of the jurisdiction in which you are located, we ensure that appropriate safeguards are in place in relation to its security. You may request us not to transfer your information to New Zealand, but if you do so, we may not be able to provide some or all of the Platform to you.