PRIVACY POLICY. Effective Date: 1 June 2018

Transcription

1 PRIVACY POLICY Effective Date: 1 June 2018 T dwnlad and/r print this Privacy Plicy ( Privacy Plicy ), supprt@parkplacetech.cm r use the brwser t print and/r dwnlad. Privacy Plicy Scpe Welcme! An verview f this Park Place Technlgies Privacy Plicy is prvided belw. T see the full text, click n the links. This Privacy Plicy applies t yur use f any nline services (e.g., website, sftware, r mbile app) that psts a link t this Privacy Plicy ( Service ), regardless f hw yu access r use it. Als, please review ur Terms f Use. In additin, if yu are accessing the Service frm utside f the U.S., EU data subjects shuld review ur EU Privacy Plicy psted n the Service fr a different EU/EEC Privacy Plicy and data subjects in ther cuntries shuld read Sectin 7 t see if different terms, cnditins r practices apply t yur use f the Service. Yur Chices and Yur Privacy Rights Yu have certain chices regarding infrmatin cllectin and cmmunicatins ptins explained in Sectin 10, including: -- Certain internatinal users may have certain additinal privacy rights detailed in Sectin 7; -- Park Place Technlgies may ask yu t prvide Persnal Infrmatin (e.g., name, address, , phne number, etc.), as well as ther infrmatin (e.g., gender, interests, etc.), which may be required t access certain -- Althugh Park Place Technlgies des nt lk fr r respnd t d nt track signals, yu can find infrmatin n tracking technlgies in Sectin 1.B and certain chice ptins regarding Tracking Technlgies in Sectin 10; -- Yur ptins regarding accessing and changing certain f yur Persnal Infrmatin are available in Sectin 9; -- Yur ptins regarding prmtinal cmmunicatins are explained in Sectin 10.D; and -- The Service is restricted t users wh are at least age f majrity in the jurisdictin in which they side, but ntice t parents f privacy rights f children and minrs are explained in Sectin 8. Cllectin f Infrmatin 1

2 Use f Infrmatin The infrmatin Park Place Technlgies cllects is used fr a variety f purpses as detailed in this Privacy Plicy. Fr example, yur infrmatin helps Park Place Technlgies prvide and imprve the Service, cmmunicate with yu, serve advertising and ffers t yu, and perate Park Place Technlgies business. Fr mre infrmatin, read Sectin 2. Sharing f Infrmatin -- Park Place Technlgies may share the infrmatin Park Place Technlgies receives frm r abut yu via the Service (r give thers access t it), including yur Persnal Infrmatin, fr a variety f purpses, as detailed in this Privacy Plicy. Fr mre infrmatin, read Sectin 3. These include, withut limitatin: t deliver and imprve Park Place Technlgies services; fr Park Place Technlgies, Affiliates (defined belw), and third parties marketing and ther purpses; in cnnectin with crprate transactins (e.g., merger r sale); t display yur psts r send yur messages (Fr mre infrmatin, read Sectin 4); and in cnnectin with yur use f third-party services (Fr mre infrmatin, read Sectin 5). -- Park Place Technlgies btains yur cnsent (e.g., pt in), hwever, befre 2

3 cntent, features, and functinality. Fr mre infrmatin, read Sectin 1.A. -- Park Place Technlgies and third parties may cllect infrmatin frm yu autmatically as yu access the Service (e.g., infrmatin abut the devices yu use t access the Service and yur usage activities). Fr mre infrmatin, read Sectin 1.B. --This may include use f ckies and ther technlgies t keep track f yur interactins with the Service, and t serve yu with ads n third-party services, t ffer yu a mre persnalized and relevant experience. Fr mre infrmatin, read Sectin 1.B. --The infrmatin Park Place Technlgies receives via the Service may be cmbined with infrmatin Park Place Technlgies receives frm third parties and surces utside f the Service. Fr mre infrmatin, read Sectin 1.C. -- Park Place Technlgies plicies and practices regarding Persnal Infrmatin cllected frm children are explained in Sectin 8. knwingly sharing Persnal Infrmatin with third parties (ther than Park Place Technlgy Affiliates) fr their wn direct marketing purpses. --Park Place Technlgies may share yur nn- Persnal Infrmatin, aggregate and/r deidentified infrmatin abut yu except as prhibited by applicable law. Questins and Hw t Cntact Park Place Technlgies Fr mre infrmatin abut Park Place Technlgies privacy practices regarding the Service, read the full Privacy Plicy. Yu can als cntact Park Place Technlgies by e- mailing us at supprt@parkplacetech.cm if yu have questins r cncerns. Internatinal If yu are accessing the Service frm utside f the U.S., EU data subjects shuld review ur EU Privacy Plicy fr a different EU/EEC Privacy Plicy and data subjects in ther cuntries shuld review Sectin 7 t see if different terms, cnditins r practices apply t yur use f the Service. FULL PARK PLACE TECHNOLOGIES PRIVACY POLICY Thank yu fr visiting ur Service, which is wned r perated by Park Place Technlgies, LLC ( Park Place Technlgies ). This Privacy Plicy will prvide yu with infrmatin as t hw Park Place Technlgies cllects, uses, and shares infrmatin abut yu, including the chices Park Place Technlgies ffers with respect t that infrmatin, and applies t yur use f any Service, regardless f hw yu access r use it. It des nt apply t Park Place Technlgies data cllectin activities ffline r therwise utside f the Service (unless therwise stated belw r at the time f cllectin). Fr certain Services, r if yu access the Service frm certain nn-u.s. jurisdictins, there may be additinal ntices abut infrmatin practices and chices. Please read thse additinal privacy disclsures t understand hw they apply t yu. By visiting r therwise using the Service, yu agree t the Service s Terms f Use and cnsent t Park Place Technlgies data cllectin, use, and disclsure practices, and ther activities as described in this Privacy Plicy, and any additinal privacy statements that may be psted n an applicable part f the Service. If yu d nt agree and cnsent, please discntinue use f the Service, and uninstall Service dwnlads and applicatins. INFORMATION WE COLLECT. A. Infrmatin abut Yu that Yu Prvide. Park Place Technlgies, and/r its Service Prviders (defined belw), may cllect infrmatin yu prvide directly t Park Place Technlgies and/r its Service Prviders via the Service. Fr example, Park Place Technlgies cllects infrmatin when yu use r register fr the Service, subscribe t ntificatins, pst n the Service, participate in prmtinal activities, r 3

4 cmmunicate r transact thrugh the Service. In additin, when yu interact with Third-Party Services (defined belw), yu may be able t prvide infrmatin t thse third parties. Fr mre infrmatin n Third-Party Services data cllectin and practices, read Sectin 5. Fr mre infrmatin n Service Prvider data cllectin and practices, review Sectin 3. Infrmatin Park Place Technlgies, its Service Prviders and/r Third-Party Services may cllect may include: (1) persnally identifiable infrmatin, which is infrmatin that identifies yu persnally, such as yur first and last name, address, phne number, address, and full payment accunt number ( Persnal Infrmatin ); and (2) demgraphic infrmatin, such as yur gender, age, zip cde, interests, and recent and upcming purchases ( Demgraphic Infrmatin ). Except t the extent required by applicable law, Demgraphic Infrmatin is nn-persnal Infrmatin (i.e., data that is nt Persnal Infrmatin under this Privacy Plicy). In additin, Persnal Infrmatin, including, withut limitatin, Park Place Technlgies- Cllected PI (defined belw), nce De-identified (i.e., the remval r mdificatin f the persnally identifiable elements, r the extractin nn-persnally identifiable elements including thrugh annymizatin, pseudnymizatin, and hashing) is als nn-persnal Infrmatin and may be used and shared withut bligatin t yu, except as prhibited by applicable law. Hwever, we d nt make assurances that Deidentified data is nt capable f re-identificatin. T the extent any nn-persnal Infrmatin is cmbined by r n behalf f Park Place Technlgies with Persnal Infrmatin Park Place Technlgies itself cllects directly frm yu n the Service ( Park Place Technlgies-Cllected PI ), Park Place Technlgies will treat the cmbined data as Park Place Technlgies-Cllected PI under this Privacy Plicy. B. Infrmatin Cllected Autmatically. Park Place Technlgies, its Service Prviders, and/r Third-Party Services may als autmatically cllect certain infrmatin abut yu when yu access r use the Service ( Usage Infrmatin ). Usage Infrmatin may include IP address, device identifier, brwser type, perating system, infrmatin abut yur use f the Service, and data regarding netwrk cnnected hardware (e.g., cmputer r mbile device). Except t the extent required by applicable law, r t the extent Usage Infrmatin is cmbined by r n behalf f Park Place Technlgies with Park Place Technlgies-Cllected PI, Park Place Technlgies des nt cnsider Usage Infrmatin (including, withut limitatin, unique device identifiers) t be Persnal Infrmatin r Park Place Technlgies-Cllected PI. Fr mre infrmatin n Third- Party Services data cllectin and practices, read Sectin 5. Fr mre infrmatin n Service Prvider data cllectin and practices, review Sectin 3. Fr infrmatin n chices sme f these third parties may ffer yu regarding autmated data cllectin, review Sectin 10. The methds that may be used n the Service t cllect Usage Infrmatin include: Lg Infrmatin: Lg infrmatin is data abut yur use f the Service, such as IP address, brwser type, internet service prvider, referring/exit pages, perating system, date/time stamps, and related data, and may be stred in lg files. Infrmatin Cllected by Ckies and Other Tracking Technlgies: Ckies, web beacns (als knwn as tracking pixels ), embedded scripts, lcatin-identifying technlgies, fingerprinting, device recgnitin technlgies, in-app tracking methds and ther tracking technlgies nw and hereafter develped ( Tracking Technlgies ) may be used t cllect infrmatin abut interactins with the Service r s, including infrmatin abut yur brwsing and purchasing behavir. Ckies A ckie is a small text file that is stred n a user s device, which may be sessin ID ckies r tracking ckies. Sessin ckies make it easier fr yu t navigate the Service and expire when yu clse yur brwser. Tracking ckies remain lnger and help in understanding hw yu use the Service, and enhance yur user experience. Ckies may remain n yur hard drive fr an extended perid f time. If yu use yur brwser s methd f blcking r remving 4

5 ckies, sme but nt all types f ckies may be deleted and/r blcked and as a result sme features and functinalities f the Service may nt wrk. A Flash ckie (r lcally shared bject) is a data file which may be placed n a device via the Adbe Flash plug-in that may be built-in t r dwnladed by yu t yur device. HTML5 ckies can be prgrammed thrugh HTML5 lcal strage. Flash ckies and HTML5 ckies are lcally stred n yur device ther than in the brwser and brwser settings wn t cntrl them. T identify certain types f lcal shared bjects n yur device and adjust yur settings, please visit: The Service may assciate sme r all f these types f ckies with yur devices. Web Beacns ( Tracking Pixels ) Web beacns are small graphic images, als knwn as internet tags r clear gifs, embedded in web pages and messages. Web beacns may be used, withut limitatin, t cunt the number f visitrs t the Service, t mnitr hw users navigate the Service, and t cunt cntent views. Embedded Scripts An embedded script is prgramming cde designed t cllect infrmatin abut yur interactins with the Service. It is temprarily dwnladed nt yur cmputer frm Park Place Technlgies web server, r frm a third party with which Park Place Technlgies wrks, and is active nly while yu are cnnected t the Service, and deleted r deactivated thereafter. Lcatin-identifying Technlgies GPS (glbal psitining systems) sftware, ge-filtering and ther lcatin-aware technlgies lcate (smetimes precisely) yu, r make assumptins abut yur lcatin, fr purpses such as verifying yur lcatin and delivering r restricting cntent based n yur lcatin. If yu have enabled GPS r use ther lcatin-based features n the Service, yur device lcatin may be tracked. Fingerprinting Cllectin and analysis f infrmatin frm yur device, such as, withut limitatin, yur perating system, plug-ins, system fnts, and ther data, fr purpses f identificatin and/r tracking. Device Recgnitin Technlgies Technlgies, including applicatin f statistical prbability t data sets, as well as linking a cmmn unique identifier t different device use (e.g., Facebk ID), which attempt t recgnize r make assumptins abut users and devices (e.g., that a user f multiple devices is the same user r husehld) ( Crss-device Data ). In-App Tracking Methds There are a variety f Tracking Technlgies that may be included in mbile applicatins, and these are nt brwser-based like ckies and cannt be cntrlled by brwser settings. Sme use device identifier, r ther identifiers such as Ad IDs t assciate app user activity t a particular app and t track user activity acrss apps and/r devices. 5

6 Sme infrmatin abut yur use f the Service and certain third-party services may be cllected using Tracking Technlgies acrss time and services, and used by Park Place Technlgies and third parties fr purpses such as t assciate different devices yu use, and deliver relevant ads and/r ther cntent t yu n the Service and certain third-party services. See Sectin 10 regarding certain chices regarding these activities. Park Place Technlgies is giving yu ntice f the Tracking Technlgies and yur chices regarding them explained in Sectin 10 s that yur cnsent t encuntering them is meaningfully infrmed. C. Infrmatin Park Place Technlgies Cllects Frm Other Surces. Park Place Technlgies may als btain infrmatin abut yu frm ther surces, including Service Prviders and Third- Party Services, and cmbine that with Park Place Technlgies-Cllected PI. Ntwithstanding anything t the cntrary, except t the extent such data cmbined by r n behalf f Park Place Technlgies with Park Place Technlgies-Cllected PI, this Privacy Plicy is nt intended t limit Park Place Technlgies activities regarding such third-party-surced, r nn-service-surced, infrmatin (including Persnal Infrmatin), and such data will nly be treated as Park Place Technlgies-Cllected PI t the extend it is cmbined with Park Place Technlgies-Cllected PI. Park Place Technlgies is nt respnsible r liable fr the accuracy f the infrmatin prvided by third parties r fr third party plicies r practices. HOW WE USE THE INFORMATION WE OBTAIN. Park Place Technlgies may use infrmatin abut yu, including Park Place Technlgies-Cllected PI and ther Persnal Infrmatin, fr any purpses nt incnsistent with Park Place Technlgies statements under this Privacy Plicy, r therwise made by us in writing at the pint f cllectin, and nt prhibited by applicable law, including, withut limitatin, the fllwing: Allw yu t participate in the features we ffer n the Service; Facilitate, manage, persnalize, and imprve yur nline experience; Prcess yur registratin, manage yur accunt and/r uplad yur User Generated Cntent ( UGC ). (Fr mre infrmatin n hw UGC is treated under the Service s Terms f Use, read Sectin 2 f the Terms f Use. Fr mre n the public nature f UGC, see Sectin 4); Transact with yu, prvide services r infrmatin yu request, respnd t yur cmments, questins and requests, serve yu cntent and/r advertising, and send yu ntices; Park Place Technlgies and Affiliates marketing and ther purpses which yu cnsent theret by prviding yur Persnal Infrmatin; Imprve the Service and fr any ther internal business purpses; Tailr ur cntent, advertisements, and ffers; Fulfill ther purpses disclsed at the time yu prvide Persnal Infrmatin r therwise where we are legally permitted r are required t d s; Determine yur lcatin and manage digital cntent rights (e.g., territry restrictins); and Prevent and address fraud, breach f plicies r terms, and threats r harm. 6

7 INFORMATION WE SHARE WITH THIRD PARTIES. Subject t applicable law, Park Place Technlgies may share nn-persnal Infrmatin, and Persnal Infrmatin that is nt deemed Park Place Technlgies-Cllected PI hereunder (prvided that Park Place Technlgies is aware f n restrictins f Park Place Technlgies use, if any), with third parties r Park Place Technlgies and their affiliates ( Affiliates ) fr any purpse. Subject t applicable law, Park Place Technlgies sharing f Park Place Technlgies-Cllected PI is, hwever, subject t the fllwing: Marketing: Subject t yur cmmunicatins chices explained in Sectin 10.D, we may use yur Persnal Infrmatin t send yu marketing cmmunicatins. We will nt share yur Persnal Infrmatin with third parties, ther than Affiliates, fr third parties marketing purpses unless yu pt-in t such sharing and will discntinue sharing if yu pt-ut (see Sectin 10.D), except in cnnectin with Crprate Transactins (defined belw), r if yu cnsent t such sharing via a third party interactin described in the next bullet pint. Yur Disclsure r Cnsent: As mre fully described in Sectin 4 (Infrmatin Yu Disclse Publicly r t Others) and Sectin 5 (Third-Party Cntent, Third-Party Services, Scial Features, Advertising and Analytics), yur activities n the Service may, by their nature, result in the sharing f yur Park Place Technlgies-Cllected Persnal Infrmatin (as well as yur ther Persnal Infrmatin and yur nn-persnal Infrmatin) with third parties and by engaging in these activities yu cnsent t that and further sharing and disclsure t third parties. Such third party data receipt and cllectin is subject t the privacy and business practices f that third party, nt Park Place Technlgies. Park Place Technlgies may als share any infrmatin abut yu (including, withut limitatin, Park Place Technlgies-Cllected PI) fr any purpses nt incnsistent with this Privacy Plicy, r ur written statements at the pint f cllectin, and therwise nt prhibited by applicable law, including, withut limitatin: Park Place Technlgies agents, vendrs, cnsultants, and ther service prviders (cllectively Service Prviders ) may receive, r be given access t yur infrmatin, including, withut limitatin, Persnal Infrmatin, Demgraphic Infrmatin, and Usage Infrmatin, in cnnectin with their wrk n Park Place Technlgies behalf, prvided hwever, Park Place Technlgies des nt authrize its Service Prviders t use Park Place Technlgies-Cllected PI prvided by Park Place Technlgies t the Service Prviders t send yu direct marketing messages ther than related t Park Place Technlgies and Affiliates absent yur cnsent. Fr mre infrmatin n chices Service Prviders may ffer yu, read Sectin 10. T cmply with the law, law enfrcement r ther legal prcess, and in respnse t a gvernment request; and If Park Place Technlgies believes yur actins are incnsistent with Park Place Technlgies terms f use, user agreements, applicable terms r plicies, r t prtect the rights, prperty, life, health, security and safety f Park Place Technlgies, the Service r its users, r any third party. In additin, Park Place Technlgies may share yur Park Place Technlgies-Cllected Persnal Infrmatin (as well as yur ther Persnal Infrmatin and yur nn-persnal Infrmatin), in cnnectin with r during negtiatins f any prpsed r actual financing f ur business, r merger, purchase, sale, jint venture, r any ther type f acquisitin r business cmbinatin f all r any prtin f Park Place Technlgies assets, r transfer f all r a prtin f Park Place Technlgies business t anther cmpany, whether as a ging cncern r as part f bankruptcy, liquidatin, r similar prceeding ( Crprate Transactins ). 7

8 In cnjunctin with laws and regulatins enfrced by the Equal Emplyment Opprtunity Cmmissin ( EEOC ), the Office f Federal Cntract Cmpliance Prgrams ( OFCCP ) and similar state and lcal regulatry agencies, we may ask yu t prvide us with self-identifying infrmatin (such as veteran status, gender and ethnicity). Prviding such self-identifying infrmatin is vluntary, but if yu d prvide us with such infrmatin, we may submit that infrmatin, t the EEOC, the OFCCP and similar state and lcal regulatry agencies r therwise use r disclse it fr business-related purpses, including, withut limitatin, respnding t infrmatin requests, fulfilling regulatry reprting requirements and defending against emplyment related cmplaints. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS. The Service may permit yu t pst r submit UGC including, withut limitatin, written cntent, user prfiles, audi r visual recrdings, cmputer graphics, pictures, data, r ther cntent, including Persnal Infrmatin. If yu chse t submit UGC t any public area f the Service, yur UGC will be cnsidered public and will be accessible by anyne, including Park Place Technlgies. Ntwithstanding anything t the cntrary, unless therwise explicitly agreed by us, Persnal Infrmatin included in UGC is nt subject t Park Place Technlgies usage r sharing limitatins, r ther bligatins, regarding Park Place Technlgies- Cllected PI r ther Persnal Infrmatin under this Privacy Plicy r therwise, and may be used and shared by Park Place Technlgies and third parties t the fullest extent nt prhibited by applicable law. Park Place Technlgies encurages yu t exercise cautin when making decisins abut what yu disclse in such public areas. Fr mre infrmatin n hw UGC is treated under the Service s Terms f Use, read Sectin 2 f the Terms f Use. Additinally, the Service may ffer yu the ptin t send a cmmunicatin t a friend r ther cntact. If s, Park Place Technlgies relies n yu t nly send t peple that have given yu permissin t d s. The recipient s Persnal Infrmatin yu prvide (e.g., name, address) will be used t facilitate the cmmunicatin, but nt used by Park Place Technlgies fr any ther marketing purpse unless Park Place Technlgies btains cnsent frm that persn. Yur cntact infrmatin and message may be included in the cmmunicatin. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS. The Service may include hyperlinks t, r include n r in cnnectin with, the Service (e.g., apps and plug-ins), websites, lcatins, platfrms, applicatins r services perated by third parties ( Third-Party Service(s) ). These Third-Party Services may use their wn ckies, web beacns, and ther Tracking Technlgy t independently cllect infrmatin abut yu and may slicit Persnal Infrmatin frm yu. Certain functinalities n the Service permit interactins that yu initiate between the Service and certain Third-Party Services, such as third party scial netwrks ( Scial Features ). Examples f Scial Features include: enabling yu t send cntent such as cntacts and phts between the Service and a Third- Party Service; liking r sharing Park Place Technlgies cntent; lgging in t the Service using yur Third-Party Service accunt (e.g., using Facebk Cnnect t sign-in t the Service); and t therwise cnnect the Service t a Third-Party Service (e.g., t pull r push infrmatin t r frm the Service). If yu use Scial Features, and ptentially ther Third-Party Services, infrmatin yu pst r prvide access t may be publicly displayed n the Service (see Sectin 4) r by the Third-Party Service that yu use. Similarly, if yu pst infrmatin n a third-party service that references the Service (e.g., by using a hashtag assciated with Park Place Technlgies r ther Park Place Technlgies Affiliates in a tweet r status update), yur pst may be used n r in cnnectin with the Service r therwise by Park Place Technlgies and Park Place Technlgies Affiliates. Als, bth Park Place Technlgies and the third party may have access t certain infrmatin abut yu and yur use f the Service and any Third-Party Service. 8

9 Park Place Technlgies may engage and wrk with Service Prviders and ther third parties t serve advertisements n the Service and/r n third-party services. Sme f these ads may be tailred t yur interest based n yur brwsing f the Service and elsewhere n the internet, smetimes referred t as interest-based advertising and nline behaviral advertising ( Interest-based Advertising ), which may include sending yu an ad n a third party service after yu have left the Service (i.e., retargeting ). Park Place Technlgies may use Ggle Analytics r ther Service Prviders fr analytics services. These analytics services may use ckies and ther Tracking Technlgies t help Park Place Technlgies analyze Service users and hw they use the Service. Infrmatin generated by these services (e.g., yur IP address and ther Usage Infrmatin) may be transmitted t and stred by these Service Prviders n servers in the U.S. (r elsewhere) and these Service Prviders may use this infrmatin fr purpses such as evaluating yur use f the Service, cmpiling statistic reprts n the Service s activity, and prviding ther services relating t Service activity and ther internet usage. Except t the extent we cmbine infrmatin we receive frm Service Prviders, Third-Party Services, r ther third parties with Park Place Technlgies-Cllected PI, in which case Park Place Technlgies will treat the cmbined infrmatin as Park Place Technlgies-Cllected PI under this Privacy Plicy (see Sectin 1.C), data btained by Park Place Technlgies frm a third party, even in assciatin with the Service, is nt subject t Park Place Technlgies limitatins regarding Park Place Technlgies-Cllected PI under this Privacy Plicy, hwever such data remains subject t any restrictins impsed n Park Place Technlgies by the third party, if any. Otherwise, the infrmatin cllected, stred, and shared by third parties remains subject t their privacy plicies and practices, including whether they cntinue t share infrmatin with Park Place Technlgies, the types f infrmatin shared, and yur chices n what is visible t thers n Third-Party Services. Park Place Technlgies is nt respnsible fr, and makes n representatins regarding, the plicies r business practices f any third parties, including, withut limitatin, analytics Service Prviders and Third-Party Services assciated with the Service, and encurages yu t familiarize yurself with and cnsult their privacy plicies and terms f use. See Sectin 10 fr mre n certain chices ffered by sme third parties regarding their data cllectin and use, including regarding Interest-based Advertising and analytics. DATA SECURITY AND MONITORING. Park Place Technlgies takes reasnable measures t prtect Park Place Technlgies-Cllected PI (excluding public UGC) frm lss, theft, misuse and unauthrized access, disclsure, alteratin, and destructin. Nevertheless, transmissin via the internet and nline digital strage are nt cmpletely secure and Park Place Technlgies des nt guarantee the security f yur infrmatin cllected thrugh the Service. T help prtect yu and thers, Park Place Technlgies and its Service Prviders may (but make n cmmitment t) mnitr use f the Service, and may cllect and use related infrmatin including Park Place Technlgies-Cllected PI and ther Persnal Infrmatin fr all purpses nt prhibited by applicable law r incnsistent with this Privacy Plicy, including, withut limitatin, t identify fraudulent activities and transactins; prevent abuse f and investigate and/r seek prsecutin fr any ptential threats t r misuse f the Service; ensure cmpliance with the Terms f Use and this Privacy Plicy; investigate vilatins f r enfrce these agreements; and therwise t prtect the rights and prperty f Park Place Technlgies, Affiliates, third parties, and ther users. Mnitring may result in the cllectin, recrding, and analysis f nline activity r cmmunicatins thrugh ur Service. If yu d nt cnsent t these cnditins, yu must discntinue yur use f the Service. 9

10 INTERNATIONAL TRANSFER. Park Place Technlgies is based in the U.S. and the infrmatin Park Place Technlgies and its Service Prviders cllect is gverned by U.S. law, except as therwise required by applicable law. If yu are accessing the Service frm utside f the U.S., please be aware that infrmatin cllected thrugh the Service may be transferred t, prcessed, stred, and used in the U.S. data prtectin laws in the U.S. may be different frm thse f yur cuntry f residence. Yur use f the Service r prvisin f any infrmatin therefre cnstitutes yur cnsent t the transfer t and frm, prcessing, usage, sharing, and strage f yur infrmatin, including Persnal Infrmatin, in the U.S. as set frth in this Privacy Plicy; prvided, hwever that if yu are accessing the Service frm certain jurisdictins different terms, cnditins r practices apply t yur use f the Service. Please cntact us at supprt@parkplacetech.cm t see if this applies t yu. CHILDREN S PRIVACY. The Service is intended fr a general audience and nt directed t children less than 13 years f age. Park Place Technlgies des nt intend t cllect persnal infrmatin as defined by the U.S. Children s Privacy Prtectin Act ( COPPA ) ( Children s Persnal Infrmatin ) in a manner that is nt permitted by COPPA. If we btain knwledge that we have cllected Children s Persnal Infrmatin in a manner nt permitted by COPPA, we will remve such data t the extent required by COPPA. ACCESSING AND CHANGING INFORMATION. Park Place Technlgies may prvide web pages r ther mechanisms allwing yu t delete, crrect, r update sme f the Park Place Technlgies-Cllected PI, and ptentially certain ther infrmatin abut yu (e.g., prfile and accunt infrmatin). In additin, yu can cntact us at supprt@parkplacetech.cm t discuss yur ptins regarding accessing, changing and deleting yur Persnal Infrmatin. T the extent permitted by applicable law, there may be a change fr ding s unless yu make changes yurself by means f yur accunt tls. Park Place Technlgies will make gd faith effrts t make requested changes in Park Place Technlgies then-active databases as sn as practicable, but it is nt always pssible t cmpletely change, remve r delete all f yur infrmatin r public pstings frm Park Place Technlgies databases) and residual and/r cached data may remain archived thereafter. Further, we reserve the right t retain data (a) as required by applicable law; and (b) fr s lng as reasnably necessary t fulfill the purpses fr which the data is retained except t the extent prhibited by applicable law. Certain internatinal users may als have certain additinal privacy rights detailed in Sectin 7. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS. A. Tracking Technlgies Generally. Regular ckies may generally be disabled r remved by tls available as part f mst cmmercial brwsers, and in sme instances blcked in the future by selecting certain settings. Brwsers ffer different functinalities and ptins s yu may need t set them separately. Als, tls frm cmmercial brwsers may nt be effective with regard t Flash ckies (als knwn as lcally shared bjects), HTML5 ckies, r ther Tracking Technlgies. Fr infrmatin n disabling Flash ckies, g t Adbe s website Please be aware that if yu disable r remve these technlgies, sme parts f the Service may nt wrk and that when yu revisit the Service yur ability t limit brwser-based Tracking Technlgies is subject t yur brwser settings and limitatins. Sme app-related Tracking Technlgies in cnnectin with nn-brwser usage (e.g., mst functinality f a mbile app) can nly be disabled by uninstalling the app. T uninstall an app, fllw the instructins frm yur perating system r handset manufacturer. 1 0

11 Yur brwser settings may allw yu t autmatically transmit a D Nt Track signal t nline services yu visit. Nte, hwever, there is n cnsensus amng industry participants as t what D Nt Track means in this cntext. Like many nline services, Park Place Technlgies currently des nt alter Park Place Technlgies practices when Park Place Technlgies receives a D Nt Track signal frm a visitr s brwser. T find ut mre abut D Nt Track, yu can visit but Park Place Technlgies is nt respnsible fr the cmpleteness r accuracy f this third party infrmatin. Sme third parties, hwever, may ffer yu chices regarding their Tracking Technlgies. One way t ptentially identify ckies n ur web site is t add the free Ghstery plug-in t yur brwser ( which accrding t Ghstery will display fr yu traditinal, brwser-based ckies assciated with the web sites (but nt mbile apps) yu visit and privacy and pt-ut plicies and ptins f the parties perating thse ckies. Park Place Technlgies is nt respnsible fr the cmpleteness r accuracy f this tl r third party chice ntices r mechanisms. Fr specific infrmatin n sme f the chice ptins ffered by third party analytics and advertising prviders, see the next sectin. B. Analytics and Advertising Tracking Technlgies. Yu may exercise chices regarding the use f ckies frm Ggle Analytics by ging t r dwnlading the Ggle Analytics Opt-ut Brwser Add-n. Yu may chse whether t receive sme Interest-based Advertising by submitting pt-uts. Sme f the advertisers and Service Prviders that perfrm advertising-related services fr us and third parties may participate in the Digital Advertising Alliance s ( DAA ) Self-Regulatry Prgram fr Online Behaviral Advertising. T learn mre abut hw yu can exercise certain chices regarding Interest-based Advertising, visit and fr infrmatin n the DAA s pt-ut prgram fr mbile apps. Sme f these cmpanies may als be members f the Netwrk Advertising Initiative ( NAI ). T learn mre abut the NAI and yur pt-ut ptins fr their members, see Please be aware that, even if yu are able t pt ut f certain kinds f Interest-based Advertising, yu may cntinue t receive ther types f ads. Opting ut nly means that thse selected members shuld n lnger deliver certain Interest-based Advertising t yu, but des nt mean yu will n lnger receive any targeted cntent and/r ads (e.g., frm ther ad netwrks). Als, if yur brwsers are cnfigured t reject ckies when yu visit these pt-ut webpages, r yu subsequently erase yur ckies, use a different device r web brwser r use a nn-brwser-based methd f access (e.g., mbile app), yur NAI / DAA brwser-based pt-ut may nt, r may n lnger, be effective. Park Place Technlgies supprts the ad industry s 2009 Self-regulatry Principles fr Online Behaviral Advertising ( and expects that ad netwrks Park Place Technlgies directly engages t serve yu Interest-based Advertising will d s as well, thugh Park Place Technlgies cannt guaranty their cmpliance. Park Place Technlgies is nt respnsible fr effectiveness f, r cmpliance with, any third-parties pt-ut ptins r prgrams r the accuracy f their statements regarding their prgrams. In additin, we may serve ads n third-party services that are targeted t reach peple n thse services that are als identified n ne f mre f ur databases ( Matched List Ads ). This is dne by matching cmmn factrs between ur databases and the databases f the third-party services. Fr instance, we may use such ad services ffered by Facebk r Twitter and ther Third-Party Services. We are nt respnsible fr these Third-Party Services, including withut limitatin their security f the data. If we use Facebk t serve Matched List Ads n Facebk services, yu shuld be able t hver ver the bx in the right crner f such a Facebk ad and find ut hw t pt-ut with us frm such list. If yu pt-ut frm ur Facebk Matched List Ads, we will remve the matching Persnal Infrmatin frm that list, hwever, this will nt take effect immediately and if yu have multiple s r ther accunts yu may have t pt-ut separately fr each ne. If we use Twitter Matched Use Ads, yu shuld be able t pt-ut thrugh yur accunt settings n Twitter. If yu pt-ut frm ur Twitter Matched Use Ads, yu will be remved frm that list, hwever, this will nt take effect immediately and if yu have multiple s r ther accunts yu may have t pt-ut separately fr each ne. We are nt respnsible fr such third parties failure t cmply with yur r ur pt-ut instructins r t prvide us ntice f yur pt-ut electins, and they may change their ptins withut ntice t us r yu. 10

12 C. Mbile Apps. With respect t Park Place Technlgies mbile apps ( apps ), yu can stp all cllectin f data generated by use f the app by uninstalling the app. Als, yu may be able t exercise specific privacy chices, such as enabling r disabling certain features (e.g., lcatin-based services, push ntificatins, accessing calendar/cntacts/phts, etc.), by adjusting the permissins in yur mbile device and/r the app s settings. Beware that if GPS precise lcatin services are disabled, ther means f establishing r estimating lcatin (e.g., cnnecting t r prximity t wi-fi, Bluetth, beacns, r ur netwrks) may persist. See als the prir sectin regarding the DAA s mbile Interest-based Advertising chices. D. Marketing & Cmmunicatins. Yu can pt ut f receiving certain prmtinal cmmunicatins ( s r text messaging) frm Park Place Technlgies and ur Affiliates at any time by (i) fr prmtinal s, fllwing the instructins prvided in s t click n the unsubscribe link, r if available by changing yur cmmunicatin preferences by lgging nt yur accunt; (ii) fr text messages, fllwing the instructins prvided in text messages frm Park Place Technlgies t text the wrd, STOP ; and (iii) fr app push ntificatins turn ff push ntificatins n the settings f yur device and/r the app, as applicable. Please nte that yur pt-ut is limited t the address r phne number used and will nt affect subsequent subscriptins. If yu pt-ut f nly certain types f cmmunicatins, ther cmmunicatins may cntinue. Yu can pt-ut f the prcessing f yur Persnal Infrmatin by us fr any marketing purpses by cntacting us via at supprt@parkplacetech.cm r via mail here: 5910 Landerbrk Drive, Mayfield Heights, OH (Attentin: Legal/Web Cmpliance). Even if yu pt ut f receiving prmtinal cmmunicatins, Park Place Technlgies may, subject t applicable law, cntinue t send yu nn-prmtinal cmmunicatins, such as thse abut yur accunt, transactins, servicing, r Park Place Technlgies nging business relatins. If yu have pted-in t Park Place Technlgies sharing yur Persnal Infrmatin with third parties fr marketing purpses, yu may pt-ut f such sharing by cntacting us via at supprt@parkplacetech.cm r via mail here: 5910 Landerbrk Drive, Mayfield Heights, OH (Attentin: Legal/Web Cmpliance). Fr yur chices regarding Interest-based Advertising see Sectin 10.B abve. E. Internatinal Users. Certain internatinal users may als have certain additinal privacy chices detailed in Sectin CHANGES TO THIS PRIVACY POLICY. We reserve the right t change this Privacy Plicy prspectively effective upn the psting f the revised Privacy Plicy and yur use f ur Service indicates yur cnsent t the privacy plicy psted at the time f use. Hwever, we will nt treat yur previusly cllected Park Place Technlgies-Cllected PI, t the extent it is nt cllected under the new privacy plicy, in a manner materially different than represented at the time it was cllected withut yur cnsent. T the extent any prvisin f this Privacy Plicy is fund by a cmpetent tribunal t be invalid r unenfrceable, such prvisin shall be severed t the extent necessary fr the remainder t be valid and enfrceable. 12. CONTACT PARK PLACE TECHNOLOGIES. If yu have any questins abut this Privacy Plicy, please cntact Park Place Technlgies at supprt@parkplacetech.cm r at 5910 Landerbrk Drive, Mayfield Heights, OH (Attentin: Legal/Web Cmpliance). //End Privacy Plicy// Park Place Technlgies, LLC All Rights Reserved. 11