Redefining the Service Experience
Effective Date: 1 June 2018
Your Choices and Your Privacy Rights
You have certain choices regarding information collection and communications options explained in Section 10, including:
- Certain international users may have certain additional privacy rights detailed in Section 7;
- Although Park Place Technologies does not look for or respond to “do not track” signals, you can find information on tracking technologies in Section 1.B and certain choice options regarding Tracking Technologies in Section 10;
- Your options regarding accessing and changing certain of your Personal Information are available in Section9;
- Your options regarding promotional communications are explained in Section 10.D; and
- The Service is restricted to users who are at least age of majority in the jurisdiction in which they side, but notice to parents of privacy rights of children and minors are explained in Section 8.
Collection of Information
- Park Place Technologies may ask you to provide Personal Information (e.g., name, address, e-mail, phone number, etc.), as well as other information (e.g., gender, interests, etc.), which may be required to access certain content, features, and functionality. For more information, read Section 1.A.
- Park Place Technologies and third parties may collect information from you automatically as you access the Service (e.g., information about the devices you use to access the Service and your usage activities). For more information, read Section 1.B.
- The information Park Place Technologies receives via the Service may be combined with information Park Place Technologies receives from third parties and sources outside of the Service. For more information, read Section 1.C.
- Park Place Technologies’ policies and practices regarding Personal Information collected from children are explained in Section 8.
Use of Information
Sharing of Information
- to deliver and improve Park Place Technologies’ services;
- for Park Place Technologies’, Affiliates’ (defined below), and third parties’ marketing and other purposes;
- in connection with corporate transactions (e.g., merger or sale);
- to display your posts or send your messages (For more information, read Section 4); and
- in connection with your use of third-party services (For more information, read Section 5).
- Park Place Technologies obtains your consent (e.g., opt in), however, before knowingly sharing Personal Information with third parties (other than Park Place Technology Affiliates) for their own direct marketing purposes.
- Park Place Technologies may share your non-Personal Information, aggregate and/or de-identified information about you except as prohibited by applicable law.
Questions and How to Contact Park Place Technologies
Information We Collect
Information about You that You Provide
Park Place Technologies, and/or its Service Providers (defined below), may collect information you provide directly to Park Place Technologies and/or its Service Providers via the Service. For example, Park Place Technologies collects information when you use or register for the Service, subscribe to notifications, post on the Service, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices, read Section 5. For more information on Service Provider data collection and practices, review Section 3.
Information Collected Automatically
Park Place Technologies, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Park Place Technologies with Park Place Technologies-Collected PI, Park Place Technologies does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or Park Place Technologies-Collected PI. For more information on Third-Party Services’ data collection and practices, read Section 5. For more information on Service Provider data collection and practices, review Section 3. For information on choices some of these third parties may offer you regarding automated data collection, review Section10.
The methods that may be used on the Service to collect Usage Information include:
- Log Information: Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in logfiles.
- Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
- Cookies: A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service, and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-into or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings manager.html. The Service may associate some or all of these types of cookies with your devices.
- Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
- Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Park Place Technologies’ web server, or from a third party with which Park Place Technologies works, and is active only while you are connected to the Service, and deleted or deactivated thereafter.
- Location-identifying Technologies: GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked.
- Fingerprinting: Collection and analysis of information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes of identification and/or tracking.
- Device Recognition Technologies: Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
- In-App Tracking Methods: There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and/or devices.
Some information about your use of the Service and certain third-party services may be collected using Tracking Technologies across time and services, and used by Park Place Technologies and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain third-party services. See Section 10 regarding certain choices regarding these activities.
Park Place Technologies is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 10 so that your consent to encountering them is meaningfully informed.
Information Park Place Technologies Collects From Other Sources
How We Use the Information We Obtain
- Allow you to participate in the features we offer on the Service;
- Facilitate, manage, personalize, and improve your online experience;
- Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
- Park Place Technologies and Affiliates’ marketing and other purposes which you consent thereto by providing your Personal Information;
- Improve the Service and for any other internal business purposes;
- Tailor our content, advertisements, and offers;
- Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so;
- Determine your location and manage digital content rights (e.g., territory restrictions); and
- Prevent and address fraud, breach of policies or terms, and threats or harm.
Information We Share With Third Parties
Subject to applicable law, Park Place Technologies may share non-Personal Information, and Personal Information that is not deemed Park Place Technologies-Collected PI hereunder (provided that Park Place Technologies is aware of no restrictions of Park Place Technologies’ use, if any), with third parties or Park Place Technologies and their affiliates (“Affiliates”) for any purpose. Subject to applicable law, Park Place Technologies’ sharing of Park Place Technologies-Collected PI is, however, subject to the following:
- Marketing: Subject to your communications choices explained in Section 10.D, we may use your Personal Information to send you marketing communications. We will not share your Personal Information with third parties, other than Affiliates, for third parties’ marketing purposes unless you opt-in to such sharing and will discontinue sharing if you opt-out (see Section 10.D), except in connection with Corporate Transactions (defined below), or if you consent to such sharing via a third party interaction described in the next bullet point.
- Your Disclosure or Consent: As more fully described in Section 4 (Information You Disclose Publicly or to Others) and Section 5 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Service may, by their nature, result in the sharing of your Park Place Technologies-Collected Personal Information (as well as your other Personal Information and your non-Personal Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third party data receipt and collection is subject to the privacy and business practices of that third party, not Park Place Technologies.
- Park Place Technologies’ agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including, without limitation, Personal Information, Demographic Information, and Usage Information, in connection with their work on Park Place Technologies’ behalf, provided however, Park Place Technologies does not authorize its Service Providers to use Park Place Technologies-Collected PI provided by Park Place Technologies to the Service Providers to send you direct marketing messages other than related to Park Place Technologies and Affiliates absent your consent. For more information on choices Service Providers may offer you, read Section 10.
- To comply with the law, law enforcement or other legal process, and in response to a government request; and
In addition, Park Place Technologies may share your Park Place Technologies-Collected Personal Information (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Park Place Technologies assets, or transfer of all or a portion of Park Place Technologies’ business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information, to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
Information You Disclose Publicly or to Others
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Park Place Technologies relies on you to only send to people that have given you permission to do so. The recipient’s Personal Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Park Place Technologies for any other marketing purpose unless Park Place Technologies obtains consent from that person. Your contact information and message may be included in the communication.
Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics
The Service may include hyperlinks to, or include on or in connection with, the Service (e.g., apps and plug-ins), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Park Place Technologies’ content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 4) or by the Third-Party Service that you use. Similarly, if you post information on a third-party service that references the Service (e.g., by using a hashtag associated with Park Place Technologies or other Park Place Technologies Affiliates in a tweet or status update),your post may be used on or in connection with the Service or otherwise by Park Place Technologies and Park Place Technologies Affiliates. Also, both Park Place Technologies and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
Park Place Technologies may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the internet, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a third party service after you have left the Service (i.e., “retargeting”).
Data Security and Monitoring
Park Place Technologies takes reasonable measures to protect Park Place Technologies-Collected PI (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet and online digital storage are not completely secure and Park Place Technologies does not guarantee the security of your information collected through the Service.
The Service is intended for a general audience and not directed to children less than 13 years of age. Park Place Technologies does not intend to collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.
Accessing and Changing Information
Park Place Technologies may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Park Place Technologies-Collected PI, and potentially certain other information about you (e.g., profile and account information). In addition, you can contact us at firstname.lastname@example.org discuss your options regarding accessing, changing and deleting your Personal Information. To the extentpermitted by applicable law, there may be a change for doing so unless you make changes yourself by means of your account tools. Park Place Technologies will make good faith efforts to make requested changes in Park Place Technologies’ then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Park Place Technologies’ databases) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law. Certain international users may also have certain additional privacy rights detailed in Section 7.
Choices: Tracking and Communications Options
Tracking Technologies Generally
Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, andin some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website https://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Some app-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Park Place Technologies currently does not alter Park Place Technologies’ practices when Park Place Technologies receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit https://www.allaboutdnt.com, but Park Place Technologies is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Park Place Technologies is not responsible for the completeness or accuracy of this tool or third party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section.
Analytics and Advertising Tracking Technologies
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit https://www.aboutads.info/choices/,and https://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see https://www.networkadvertising.org/choices/ Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI/ DAA browser-based opt-out may not, or may no longer, be effective. Park Place Technologies supports the ad industry’s 2009 Self-regulatory Principles for Online Behavioral Advertising (https://www.iab.com/wp-content/uploads/2015/05/ven-principles-07-01-09.pdf) and expects that ad networks Park Place Technologies directly engages to serve you Interest-based Advertising will do so as well, though Park Place Technologies cannot guaranty their compliance. Park Place Technologies is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our databases (“Matched List Ads”). This is done by matching common factors between our databases and the databases of the third-party services. For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad and find out how to opt-out with us from such list. If you opt-out from our Facebook Matched List Ads, we will remove the matching Personal Information from that list, however, this will not take effect immediately and if you have multiple e-mails or other accounts you may have to opt-out separately for each one. If we use Twitter Matched Use Ads, you should be able to opt-out through your account settings on Twitter. If you opt-out from our Twitter Matched Use Ads, you will be removed from that list, however, this will not take effect immediately and if you have multiple e-mails or other accounts you may have to opt-out separately for each one. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions or to provide us notice of your opt-out elections, and they may change their options without notice to us or you.
With respect to Park Place Technologies’ mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist. See also the prior section regarding the DAA’s mobile Interest-based Advertising choices.
Marketing & Communications
You can opt out of receiving certain promotional communications (emails or text messaging) from Park Place Technologies and our Affiliates at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; (ii) for text messages, following the instructions provided in text messages from Park Place Technologies to text the word, “STOP”; and (iii) for app push notifications turn off push notifications on the settings of your device and/or the app, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain types of communications, other communications may continue. You can opt-out of the processing of your Personal Information by us for any marketing purposes by contacting us via email at email@example.com via mail here: 5910 Landerbrook Drive, Mayfield Heights, OH 44124. (Attention: Legal/Web Compliance). Even if you opt out of receiving promotional communications, Park Place Technologies may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Park Place Technologies’ ongoing business relations.
If you have opted-in to Park Place Technologies sharing your Personal Information with third parties for marketing purposes, you may opt-out of such sharing by contacting us via email at firstname.lastname@example.org or via mail here: 5910 Landerbrook Drive, Mayfield Heights, OH 44124. (Attention: Legal/Web Compliance). For your choices regarding Interest-based Advertising see Section 10.B above.
Certain international users may also have certain additional privacy choices detailed in Section 7.
Contact Park Place Technologies