2. Information We Collect and How We Collect It
We will process any personal information that you provide to us, including when you create your account or a player profile.
A. Information About You That You Share With Us Directly
Depending on the Service, the personal information we collect will be relevant to providing that Service and include some or all of the following:
- your first and last name;
- your game username or alias;
- your gender;
- your age, birthday or age range;
- your email address;
- your profile photo and/or avatar;
- your approximate location;
- your contact details including phone number and address;
- a password;
- details about the games and platforms you use;
- links to your profiles on various social networks and social network ID number;
- information related to any purchases you make in our Services (see further details below); and/or
- personal information you provide when you ask for help from our customer support team, including the content of that communication with our team.
A note on sensitive personal information: While we typically do not request sensitive or special categories of personal information, you may choose to provide this information to us. The meaning of sensitive or special categories of personal information changes from region to region but could include information about your health or, in certain places, types of financial or precise location information. For some Services, we may also ask you to voluntarily provide information about any accessibility requirements you may have to better understand the needs of players and to improve the accessibility of our Services.
B. Information Shared About Others
We collect personal information that you choose to provide to us about people you know, but be sure to ask their permission first. Other players may also provide use with personal information about you too.
We may give you the ability to invite people you know to use Op Digital Services, including by importing your address book or manually entering their contact information. You are responsible for ensuring your sharing of this personal information with us is compliant with applicable laws. In some countries, this may require you to get permission from the people you invite before you share their information. We may also get personal information about you from other Op Digital users. We process this personal information to help you and your contacts connect through our Services. If you want to remove personal information stored by us, follow any instructions in the Service or see “Your Rights” below.
C. Information You Generate Using Our Services
We’ll collect personal information about the ways you use and interact with our Services.
When you use our Services, we will collect personal information about the ways in which you use and interact with our Services, such as when and for how long you play our games, which game features and other players you interact with, any purchases you make, what progress or levels you achieve, and other gameplay activities in which you participate. We may also create a Op Digital player ID to identify your game account.
If you choose to use communication features in Op Digital Services to communicate or share information with other players, then we’ll collect information on what is communicated or shared. This includes:
- your participation in player forums and message boards;
- your public posts or comments on other players’ profiles or gameboards;
- your non-public messages or invitations to other players, made either directly on our websites or through in-game mechanisms;
- your chats with other players (whether by instant message, live chat, or video); and/or
- your posted photos, drawings, or other user-generated content.
We may keep these communications, comments, photos, drawings, and other user-generated content on Op Digital’s servers to use them to protect the safety and well-being of our players; to protect Op Digital’s rights and property in connection with our Services; to conduct research; to operate, improve, personalize, and optimize our Services and our players’ experiences, including through the use of analytics; and to manage and deliver advertising. Where required by law, we will seek your consent for this.
D. Payment Information
We’ll collect information related to any purchases you make.
E. Information We Get About You From Connected Third-Party Platforms
We’ll collect personal information from other companies, including social networks, if you access our games through your accounts with those companies or you choose to connect through those accounts to our games.
If you play Op Digital’s games or access any of our other Services on social networks like Facebook or other connected third-party platforms, Op Digital may receive certain information about you from that third-party platform.
Depending on the Op Digital game you’re playing, the third-party application, your privacy settings, and, if applicable, your friends’ privacy settings on that third-party application, Op Digital may collect and store some or all of the following from the third-party platform:
- your first and last name;
- your profile picture or its URL;
- your user identification number (like your Facebook ID number), which may be
linked to publicly-available information like your name and profile photo;
- your friends’ user ID numbers and other public data;
- the email address you provided to that third-party platform;
- your approximate physical location and that of the devices you use to access our Services;
- your gender;
- your birthday, age, and/or age range;
- information about your activities on or through the connected third-party platform;
- other publicly-available information on the third-party platform; and/or
- any other information that you or the third-party platform share with Op Digital.
If you are unclear about what information a third-party platform is sharing with us, please go to that platform to find out more about their privacy practices and any options available to you regarding such sharing.
F. Cookies and Other Automated Information Collection
We, our service providers, and our business partners use these cookies and other similar technologies to process information, including:
- IP address;
- the type of computer or mobile device you are using;
- platform type (like Apple iOS or Android);
- your operating system version;
- your mobile device’s identifiers, like your MAC Address, Apple Identifier For Advertising (IDFA), and/or Android Advertising ID (AAID);
- application performance and de-bugging information;
- your browser type and language;
- referring and exit pages, and URLs;
- the number of clicks on an app feature or web page;
- the amount of time spent on an app feature or web page;
- domain names;
- landing pages;
- pages viewed and the order of those pages; and/or
- what your current progress is in our Services and the date and time of activity.
In some cases, we will connect the information we collect using cookies and similar technologies with your social network ID or Op Digital user ID.
If you play Op Digital games on a mobile device, in addition to the information we collect using cookies and similar technologies, we may also collect:
- the name you have associated with your device;
- your country;
- your telephone number (if you provide it);
- your specific geolocation (with your permission);
- your mobile contacts (with your permission, as described further in Information Shared about Others above); and/or
- information about the Op Digital games and about other third-party applications with embedded Services you have on your device.
If you want to adjust your privacy preferences on your device, please see “Your Rights” below.
G. Other Sources
We may collect information from other third-party sources.
We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.
3. Why We Process Your Information and our Legal Grounds
We process your personal information for a number of reasons, including to provide and improve our Services; protect you and others; for marketing and advertising our, and our third party partners’, products and services; for business continuity reasons; and to comply with legal rights and obligations.
The main reason we process your personal information is to provide you with Services and to improve your gaming experience, but there are other reasons as well. We process your information for the purposes below:
- Provide our Services and create accounts in those Services;
- Improve, optimize and personalize our Services and our players’ experiences;
- Help you to connect with other people you know and other third-party platforms you use, including communicating with other players;
- Communicate with you about the Services you are using or we think you will like, including in-game updates, new Services, pre-registrations and promotional marketing offers;
- Customer service and managing player communications, including technical support;
- Marketing, research, analytics and delivering contextual and behavioral advertising;
- Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- Protect the safety and well-being of our players and others;
- Where you provide sensitive or special category personal information to us;
- Maintain our business operations, including any business transition, like a merger, acquisition by another company, or sale of all or part of our assets;
- Cooperate with public authorities and law enforcement where lawfully permitted or required; and/or
- Protect Op Digital’s rights, including compliance with applicable legal obligations, resolving any disputes we may have, and to administer our agreements with third parties.
Our legal grounds for collecting and using the information described above depends on what the information is, the context in which we collect it and applicable privacy laws. Those grounds are as follows:
- For our or our partners’ legitimate interests;
- Consent (where applicable);
- Compliance with a legal obligation;
- Protect your vital interests or those of another person (for example, another player); and/or
- While we typically do not collect sensitive or special category personal information, where we do this it will be on the ground of consent or other applicable lawful basis.
If you have questions, need further information about the legal grounds for processing your personal information, or want to withdraw your consent please see the “Contact Us” section below.
4. How We Share Information
We share your information with our parent company, USAopoly, Inc., people you know, other Op Digital players and certain other third parties when you use our Services.
We may share your personal information from our Services with others in the ways described below.
A. People you know and Other Op Digital Players
Op Digital’s games and Services support and often encourage you to interact with other players. In most Op Digital games, if you play through a social network or connect to a social network (for example, Facebook), your social network friends who also play an Op Digital game will see your name, photo, player profile (which may include the information described above in “Information About You That You Share With Us Directly”), and descriptions of your in-game activity (including any Op Digital games you have played).
In addition, in many Op Digital games, other players, regardless of whether they are your social network friends, will be able to see your player profile (as described above); view descriptions of your in-game activity; communicate with you within our Services; and send you game requests or friend requests through our Services or the related social network.
B. Our Group Companies
We’ll share your information with other companies in the Op Digital group.
C. Third-Party Advertising Including Behavioral Advertising and Analytics
We’ll share some of your information with advertisers to help make the advertisements you see more relevant to your interests when you use our Services.
We’ll share some of your information with advertisers to help make the advertisements you see more relevant to your interests when you use our Services. Advertisements that are tailored for your interests may include banner ads on game boards or in Services, such as full-screen ads between moves or games or ads made available through an “offer wall” (in which advertisers offer virtual currency or other in-game items to players in exchange for watching an advertisement, signing up for an account, completing a survey or performing some other activity). Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Op Digital.
To enable advertisers, advertising intermediaries, and offer wall providers to serve you with more relevant ads, they may collect, or we may collect and share with them, the following types of information when you use our Services:
- performance data (like the number of clicks on an advertisement);
- certain device information (like IP address, non-persistent device identifier such as IDFA, and de-identified persistent device identifier such as a hashed Android ID);
- a unique identifier, such as your social network ID or Op Digital player ID; and/or
- other contextual data about your game play (like your level and session length).
In addition to serving you with relevant ads, the information collected may be used to:
- measure how effective advertising campaigns are;
- offer you targeted advertising in third party services for products and services that are more likely to appeal to you;
- undertake web analytics to analyze traffic and other player activity; and/or
- improve our Services.
Please note, after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Op Digital or the social network through which you are playing Op Digital’s games.
If you do not want to receive tailored in-application advertisements, please see “Your Rights” below or view the applicable Cookie Notice.
Please note that the practices of third-party companies delivering advertisements on our Services are subject to those companies’ own privacy policies and privacy practices. If you have any questions about how these third-party services use your information, you should review their policies and contact them directly.
D. Safety, Security and Compliance with Law
We’ll share your information if necessary for safety, security, or compliance with legal obligations.
Your information, and the contents of all of your online communications in our Services and between you and Op Digital may be accessed and monitored as needed to provide our Service and may be disclosed:
- to satisfy any applicable legal obligations;
- when we have a good faith belief that we have to disclose personal information in response to lawful requests by public authorities, including for national security, law enforcement, or legal process purposes (for example, a court order, search warrant, or subpoena);
- when we believe in our sole discretion that our Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
- when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally; and/or
E. Third-Party Service Providers
We’ll share your information with the third-party service providers and business partners that we work with to bring you our Services and that support us with our business.
We will share your information with:
- third-parties who perform services on our behalf, like payment processing, analytics, analysis, hosting services, customer service, marketing and advertising, including, for example, Microsoft and PlayFab; and
- our third-party business partners who assist us in delivering and optimizing our Services, such as our platform partners (including, for example, Apple, Google and Facebook).
F. Sale or Merger
We may share your information with a third party in connection with a business transition, like a merger or acquisition.
Where we consider a business transition, like a merger, acquisition by another company, or sale of all or part of our assets (like selling a game), we may disclose or transfer your information, including personal information, to the purchaser.
5. Your Rights
Depending on what privacy laws apply to you, you and/or your legal representative have certain legal rights in connection with your personal information.
Your privacy rights are explained below. These rights apply to information about you, and their scope and applicability can vary across different regions. For example, they could extend to your household or a legal entity or could be exercised by a legal representative on your behalf. We will comply with applicable privacy laws, including any required response times.
Subject to certain exemptions, you have the right to:
- Request a copy of your personal information (known as ‘accessing your data’).
- Delete your information. When you ask us to delete your personal information please remember that there may be lawful limitations on this right. For example, we will keep certain payment records or customer service records where we need to, including for legal or accounting purposes. We’ll also keep information in order to exercise, protect, defend, or establish our rights or the rights of third parties.
- Correct or update your personal information where it is inaccurate. To review and update personal information associated with your Op Digital player profile in certain games, visit the “settings” page in that game.
- Opt-out of marketing communications we send you by following the instructions in “Opting Out of Promotional Communications from Op Digital” below.
- Where applicable, withdraw your consent at any time directly in the Service or by contacting us. Withdrawing your consent will not affect the processing already undertaken before your withdrawal. Also, it will not affect processing of your personal information under other lawful grounds.
- Object to processing of your personal information, ask us to restrict processing of your personal information or Request portability of your personal information.
- Ask that you are not subject to automated decision-making that has a legal effect or any other significant effect on you.
- Complain to a data protection authority. A list of privacy authorities is available here. In certain regions, you also have the right to request compensation if you suffer damage due to unlawful processing of your Personal Data.
For California residents, please also review our California Notice for additional rights. For Nevada residents, please see section 6 below.
You and/or your legal representative can exercise these rights by submitting a request through the Contact Us channels below.
Managing Personal Information We Receive From Third-Party Applications / Platforms And From Your Mobile Device
To manage the information we receive from third-party applications or platforms and from your mobile device, use the tools and settings provided by those third-party applications and devices.
You can manage the information we receive from third-party applications or platforms and from your mobile device as follows:
- To manage the personal information we receive about you from a third-party application or platform where you play our games, like Apple or Google, you can update your privacy settings through the third-party application or platform’s “settings” menu.
- For your mobile device, visit the “settings” page or web browser to review the access permissions of each of our Services.
Opting Out of Promotional Communications from Op Digital
You can unsubscribe from promotional emails by clicking the “unsubscribe” link or visiting our Email Settings page. You can opt out of mobile push notifications in your device’s settings page. You can opt out of SMS text communications by texting STOP.
To stop receiving promotional emails from Op Digital, click on the “unsubscribe” link at the bottom of any promotional email from Op Digital or Contact Us. Your unsubscribe request or email preferences change will be processed promptly, and in no event longer than ten business days. During that processing period, you may receive promotional emails that were already scheduled.
If you want to stop receiving push notifications, which are messages an app sends you on your mobile device even when the app is not on, you can turn off push notifications by visiting your mobile device’s “settings” menu. Many of our games also offer the ability to turn off push notifications in the in-game “settings” menu.
You can opt out of receiving SMS text messages by texting back STOP to the number we send the text from or by Contacting Us.
When we receive an opt-out message from you for SMS text messages, we may send a text message confirming receipt.
Where you opt out of receiving promotional communications from us, you may occasionally hear from us if we need to provide you with non-marketing information about our Services or if we need to request information from you related to the performance of our Services to you.
Opting Out of Third-Party Behavioral Advertising
You can opt out of third-party behavioral advertising in your device and by using other third-party opt-out tools.
Our Cookie Notice explains how you can control cookies and similar technologies used for advertising purposes. In addition, if you are interested in more information about behavioral advertising and your choices to prevent behavioral web and mobile web advertising from third parties, you may visit the following websites:
- Network Advertising Initiative Consumer Opt-Out Pageor the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising; and
- Your Online Choiceswebsite for European-based advertising.
These third-party opt-outs are browser and device-specific and will not apply to your use of Op Digital’s Services through other browsers or devices.
If you do not want to receive personalized in-application advertisements from third parties on your mobile device, you may exercise that choice by visiting your mobile device’s “settings” menu and adjusting the device’s ad tracking settings (such as turning off the feature to “Allow Apps to Request to Track”). Certain apps, such as the Digital Advertising Alliance’s “AppChoices” app can help you exercise your behavioral advertising choices and are available from some platform providers (such as Apple or Google).
All of the opt-out tools described in this section are provided by third parties, not by Op Digital. Op Digital does not control or operate these tools or the choices that advertisers and others provide through these tools.
You will still see third-party advertisements in Op Digital’s Services after using these opt-out tools, but the advertising will not be tailored to your interests.
6. U.S. Privacy Laws
If you are a California resident, please see our California Notice. If you are a Nevada resident, please see this section for information on your rights.
If you are a California resident, you may be able to exercise additional rights granted by California law in relation to your personal information that we process (subject to certain limitations). For more information, please review our California Notice.
If you are a Nevada resident you may be able to exercise additional rights to opt out of future sales of certain covered information that a website operator has collected or will collect about you. If you are a Nevada resident, you may exercise this right by submitting a request through the Contact Us channels below. Please include sufficient information for us to identify you, such as information about previous games you’ve played, or, if applicable, your account information including Op Digital ID (if any). Please note we may take reasonable steps to verify your identity and the authenticity of the request.
7. Our Policies Concerning Children
We seek to ensure that we do not collect information from children.
Our Services are not marketed to, or intended for, children. For these purposes, we use the term “children” to refer to someone who is: (a) under 13 years old or, if older, (b) between 13 and 18 years old but under the age at which they can give valid consent to processing of their personal information under applicable data privacy laws. Op Digital strives to follow the different minimum age guidelines set by the laws of individual regions when determining the age that children can access certain features of our Services.
Children are not permitted to use these Services, and we do not knowingly collect any personal information from children. Though our Services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. For users who identify themselves as children in an age-gate on such Services, if we allow children to use the Services, we will either provide a version of that Service that does not collect, use, or disclose “personal information” (as defined in the Children’s Online Privacy Protection Act (“COPPA”)), except as permitted by COPPA or other privacy laws (where applicable), or obtain legally valid parental consent.
If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under COPPA or another applicable privacy law, we will take measures to promptly remove that information from our records.
8. International Operations and Transfers
When you use our Services, your personal information may be processed in the United States and other countries.
As part of our international operations, we may transfer personal information to our Group Companies, business partners and service providers located internationally for our legitimate business purpose, including for the purposes listed in the Why We Process Your Information and Our Legal Grounds section above. We store personal information about you on servers located in the United States or where our business partners and service providers have their operations. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is processed may be different from the privacy laws applicable to the place where you are resident. When we transfer your personal information internationally we treat your personal information securely, lawfully, and in accordance with privacy obligations. For example, in European Countries, this may include transferring personal information to countries deemed safe by the European Commission, implementing the European Commission’s Standard Contractual Clauses or using another approved mechanism for transfers of personal information between our related companies, business partners and service providers (where applicable).
9. How Long We Keep Your Information
We’ll keep your information for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights.
How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for to provide you with the Services or for our legal requirements.
We will retain personal information that is connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take measures to delete this personal information if you delete your account. However, you acknowledge that we may retain some information after you have closed, or we have deleted, your account with us where necessary to enable us to meet our legal obligations or to exercise, defend, or establish our rights.
10. Security of Your Information
We work hard to protect your information but you also have a role to play.
If you have an account registered directly with Op Digital, your profile information is protected by the password you use to access your Op Digital account. It is important that you protect and maintain your Op Digital account’s security and that you immediately tell us of any unauthorized use of your account. If you forget the password to your Op Digital account, the Services allow you to request that instructions be sent to you that explain how to reset your password. Where you access our Services through another account (for example, a social network) please keep that account information secure as well. We urge you to log out of your Op Digital account and any social network account you have used to access our Services when you are finished using them.
While we take precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure. We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur, and we cannot guarantee the security of your information while it is being transmitted to our Service. Any transmission is at your own risk.
12. Contact Us
You can contact us with your questions, comments, or concerns.