How does this Policy apply to my company?
This statement describes the manner in which VLG either controls or processes data provided by or collected by VLG through a myriad of marketing activities. The majority of our data is provided by and controlled by our customers or their partners. We do not share that controlled data to any third-party without written consent or at the direction of our customers or their partners.
How does this Policy apply to me as a user?
VLG is contracted to provide marketing services on behalf of its customers and their partners. As such, controlled data is shared with us in accordance with our and our customers privacy policies. Through the performance of our Services, we also collect and process data. As the controller of this data, we are obligated by contract to share that information with our customer on a “contract-to-hire” basis.
However, should a user wish to exclude their information, we will honor that wish and collected data for that specific user will not be shared with our customer. Similarly, if the user data is controlled by our customer but the user wishes to opt-out, we will record that request and share it with our customer. It would then be up to our customer, the data controller, to carry out the user’s requests.
What is a data controller and a data processor?
For the purposes of this Policy and in accordance with certain domestic and foreign regulations, we act as a “Data Controller” when collecting opt-in data from users. Opt-in data would include information gained with explicit permission from the user, including online behavior tracking and opt-in data submissions (i.e. submitted a form on a website that includes checking an opt-in box).
We take into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons. We have implemented appropriate technical and organizational measures to ensure and to be able to demonstrate that processing is performed in accordance with the European General Data Protection Regulation (GDPR). Measures taken will be reviewed and updated where necessary.
For the purposes of this Policy and in accordance with certain domestic and foreign regulations, we act as a “Data Processor” when retained by the Data Controller, either a VLG customer or third-party vendor. We take all steps necessary to protect the rights of the data subject when protecting PII, or processing data.
Please note that the scope of this Policy is limited to information controlled or processed by VLG through your use of the Service. VLG is not responsible for the actions of third-party people or companies, the content of their sites, the use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those people or companies.
Where required by law, we obtain consent from individuals to collect, use, retain or disclose their personal data. Individuals located within the European Economic Area are asked to opt-in. If applicable, we inform individuals of the consequences for failing to consent or provide their personal data and the process to alter their consent decisions. VLG verifies that the use of personal data is consistent with the consent obtained. If personal data will be used for a purpose other than that originally disclosed to the individual, we acquire additional consent.
We collect information as described below. Our primary goal is to process data and pass those results through to our customers. In all other instances, we collect data to provide services to you, improve our Service, contact you, conduct research, and create reports for internal and external use on behalf of our customers. We store information on servers located in the United States via Amazon Web Services or within our secure, dedicated server environment, and may store information on servers and equipment in other countries. We collect personal data in a fair, transparent, and lawful manner. As such, we adhere to the following guidelines:
- Collect the minimum personal data required to support the Service or as mandated by law;
- Collect personal data in a fair and non-deceptive manner;
- Collect personal data directly from an individual, when possible;
Where required by local law, obtain explicit consent from individuals, prior to the collection of sensitive personal information (e.g. race, ethnic origin, health details, sexual orientation etc.); and
Verify that personal data collected from third parties, including our customers, is reliable and legally obtained.
Furthermore, we monitor the involvement of third parties during collection and conduct due diligence to ensure adherence to our Policy, when possible.
We use personal information collected through our Services for purposes described in this Policy or disclosed to you in our Services or in connection with our Services. For example, we, and by extension our customers, may use your information to:
- operate and improve our internal operations, systems, and Services, or those of our customer;
- obtain your preferences to improve your experience and enjoyment using our Services;
- respond to your comments, questions, and support queries, and provide customer service;
- provide the Services you request, whether you request them directly from us or from one of our channel partners;
- communicate with you about new products and services, upcoming events, promotions, rewards, and other news about products and services offered with the appropriate permission rights;
- process and deliver incentives and rewards;
- append information about you with consent to compile personal information we get from third parties, to help understand your needs and provide you with better and more personalized service; and
- protect, investigate, or deter against fraudulent, unauthorized, or illegal activity.
On Your Device
While you are browsing VLGs websites, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring Web site addresses may be logged automatically. We may use this information to monitor, develop, and analyze your use of the Service. In addition, we may ask you to submit and we may process data that is personal to you, including but not limited to your name, profile photo, gender, age, birthday, links to your profiles on social networking websites and other third party sites, user names, e-mail and mail addresses. We may use this information to create a user profile and provide you services. With permission, we may use your email address to contact you about your experience with VLG sites and notify you about company news and promotions. Your gender and birthday may be used to analyze user trends and target certain promotions. Your mail address may be used if we have merchandise or other physical promotional materials that we want to send to you. If you no longer wish to receive these types of promotional materials, you may opt-out from receiving them at any time by emailing us at email@example.com.
iOS and Android Platforms
When you use any of the VLG games or applications on a mobile platform, we may collect and record certain information such as your unique device ID (persistent/non-persistent), hardware type, media access control (MAC) address, international mobile equipment identity (IMEI), the version of your operating system (OS), your device name, and your location (based on your Internet Protocol (IP) address). This information is useful to us for troubleshooting and helps us understand usage trends.
Apple Game Center, Amazon Game Circle, and GREE
Our apps can be connected to Apple’s Game Center, Amazon’s Game Circle, and Android-compatible GREE gaming services. These services authenticate your identity and provide you the option to share certain personal information with us and others.
We collect your name, address, phone number, and email address when you make a purchase on WeFightBoredom.com or contact us for customer help. You may contact us from time to time. In order to reply, we will likely use your email address or phone number to contact you. If you no longer wish to receive certain email communications from VLG, please opt-out using links provided at the bottom of each email we send. You can also email us at firstname.lastname@example.org and you won’t be notified of upcoming sales, promotions or other product information.
We may occasionally send our customers’ employees permission-based push notifications through our software, third-party software, or mobile applications. These employees may opt-out of receiving these notifications by turning them off using your device’s built-in notification settings.
Game Data Collection
We collect anonymous data about all of your interactions with the game via server log files and through the use of Google Analytics. This information is aggregated and used to improve our products and features, as well as identify potential bugs in our code.
We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
Third Party Services
How We Use Information
We may use information to provide you genuine customer service, as well as enhanced features and functionality within each app and on our website. In addition, we may collect information for dissemination to VLG customers through the normal course of business.
Disclosure of Your information
We do not sell your personal information. Our customers are far too important to us and we would not want to betray that trust. That said, VLG collects data and it may be used in the following manner:
We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.
We may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or notice on our site of any change in ownership or users of your personal information.
With your permission only, we may share information about you with advertisers, publishers, business partners, sponsors, and other third parties.
Changes to the Policy
VLG takes extraordinary measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
Access to Personal Information
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services, contact us at email@example.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Our Policy Regarding Children
We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use our Service. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us at firstname.lastname@example.org.
Opting Out of Marketing
Individuals located in the European Economic Area will be forced to opt-in if prior approval has not already been obtained by the controller. You may opt-out of receiving promotional emails from us by following the instructions in those emails or by emailing us at email@example.com. If you opt-out of marketing communications, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also opt-out of receiving SMS notifications from us, either via SMS or by emailing us at firstname.lastname@example.org.
VLG Marketing LLC
167500 Westgrove Drive
Addison, TX 75001