Last Updated: May 25, 2018
- Information we collect from you and how we collect it
Information We Collect. We collect information about your use of our Service, including but not limited to: your online behavior, your Internet connections, mobile, or other device computer equipment, as well as the site(s), application(s), destination(s), and/or service(s) visited before using or accessing the Services, and after leaving the Services, along with your time of visits, content viewed, ads viewed, and other similar information about traffic and usage, as you navigate to, through, and away from our website(s), including other clickstream data. This is “Non-Personal Data,” which does not directly, personally identify you.
Information You Provide, Directly and Indirectly. You may register to use our Services, set up an account, enter a sweepstakes or contest, complete a survey, make a payment, subscribe to our Services, or respond to communications (e.g., surveys, polls, requests for feedback). We will collect the information you provide to us. This may include your IP address, first and last name(s), demographic information, mailing address, e-mail address, phone number, credit card number, and any other information you provide to us. Such information may also include the geographic location of you and/or your computer, mobile or other device, as well as date/time stamp, IP address, your computer (e.g., the make, model, settings, and specifications, including but not limited to your CPU speed, connection speed, browser type, operating system, device identifier). While using our Services, you may also transmit your communication preferences, your physical location, your demographic information (e.g., your age, marital status, ethnicity/race, and gender), and other information. All of this is “Personal Data,” which can be used to personally identify you.
Additionally, if you choose to access, visit, and/or use any third party social networking service(s) that may be integrated with our Service, we may receive your Personal Data and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts on those services. For example, some social networking services allow you to push content from our Service to your contacts or to pull information about your contacts so you can connect with them on or through our Service. Some social networking services also will facilitate your registration for our Service or enhance or personalize your experience on our Service. Your decision to use a social networking service in connection with our Service is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available to our Service by visiting those services’ privacy policies and/or modifying your privacy settings directly with those services.
- How we use information about you
For Legitimate Interests. Spy Games uses information collected by clickstream data collection, web pixels, and cookies to store your preferences, improve website navigation, make personalized features and other services available to you, compile and analyze aggregate statistics and trends, and otherwise help administer and improve the Services. We may identify you from your Personal Data and merge or co-mingle Personal Data and Non-Personal Data, for any lawful business purpose. Where you provide registration information, cookies can also be used to identify you when you log onto the Services or portions of the Services. Except as otherwise stated, we may use information we collect from you for the legitimate business purpose of providing our Services to you, including, but not limited to:
- to administer the Services
- to help diagnose problems with our servers
- to customize our Services to your preferences
- to communicate information to you (e.g., new features, products, or services)
- to check on your account status
- to improve our Services
- to show you content and sponsored messaging based on geographic location information from you and/or your computer, mobile, or other device
- to prevent or investigate fraud (or for risk management purposes), or to comply with a legal obligations, court order, or in order to exercise our legal claims or to defend against legal claims
- to conduct aggregate analysis and develop business intelligence that helps us to enhance, operate, protect, make informed decisions and report on the performances of our Services
- for other purposes identified to you and as requested by you (please note that you have the right to withdraw your consent to such use at any time by contacting us via the information below)
With the Consent of a Data Subject within the European Union. If we have obtained your consent, we may also use your information:
- to send e-mail and postal mail to provide you with updates and news
- to process any request you make
- to process any commercial transaction, including but not limited to fulfilling an order or subscription request
- to process your Personal Data as described throughout this Policy
- to process your Non-Personal Data as outlined as described throughout this Policy
- to establish your account to use the Services
- to validate your username, e-mail, password, and/or other login credentials
- to respond to your requests
- to provide you with merchandise you have requested
- to fulfill your subscription purchase(s)
- to notify you of your contest or sweepstakes results
- to send you e-mail and postal mail supplying you with the most recent service information or to send you information about your order (e.g., order confirmations, shipment notifications, etc.)
- to notify you of any changes to relevant agreements or policies
In each case, we may use third‐party e‐mail providers to deliver these communications to you.
- Sharing Personal Data with third parties
We may sell or share information about you and your computer, mobile, or other device, including without limitation, your Personal Data, with our parent, subsidiaries, and affiliates and with carefully selected companies who we think may offer services and/or products that may be of interest to you. Additionally, we may use, transfer, assign, sell, share, and provide access to your Personal Data and other information about you and your computer, mobile, or other device that we receive through third-party social networking services. We may use, transfer, sell, and share your and Non-Personal Data, aggregated with other users’ Non-Personal Data, for any lawful business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.
In addition, as our business changes, we may buy or sell various assets. In the event all or a portion of the assets owned or controlled by us, our parent or any subsidiary or affiliated entity are sold, assigned, transferred or acquired by another company, the information from and/or about our Service users may be among the transferred assets.
Do not track signals. We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.
Third party behavioral tracking. It’s also important to note that we do not allow third party behavioral tracking.
Sharing. At times, we partner with other parties to provide specific services. When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.
Links. This website may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
Surveys & Contests. From time-to-time our site requests information via surveys or contests. Participation in these surveys or contests is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code, age and gender). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.
- Third-Party Service Providers
We use third-party service providers to help us operate our Services, who may collect, store, and/or process the information detailed herein. We allow access to our database by third parties that provide us with services, such as technical maintenance, market research, community and forums management, auction services, and shopping, personal/job search, and other classified ads functionality, but only for the purpose of and to the extent necessary to provide those services.
If you choose to purchase merchandise, products, and/or services on or through features on the Service, we may forward your information to third parties for services such as credit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. There are also times when you provide information about yourself to us in areas of the Service that may be managed or participated in by third parties. In such cases, the information may be used by us and by such third party(ies), each pursuant to its own policies. We may also provide your information to our advertisers, so that they can serve ads to you that meet your needs or match your interests.
Google Analytics. We have enabled Google Analytics to collect data about our traffic through the use of Google advertisements and other anonymous identifiers. We use Google Analytics cookies and other cookies to compile data to better understand users and provide users with a more tailored experience. You can opt out of Google Analytics by visiting Google’s Opt-Out Browser Add-on website here, https://tools.google.com/dlpage/gaoptout/.
- How Personal Data is protected
Spy Games takes reasonable steps online and offline to safeguard the Personal Data that you provide to us, including Secure Sockets Layer (SSL) encrypted connections (HTTPS) to the web site(s) on our Service(s), secure multi-tiered firewalls, and portions of your data may also be encrypted on our storage server for additional security.
Nonetheless, it is common knowledge that transmission of information via the internet is not wholly secure, and we cannot guarantee the security of your Personal Data, or any other information, transmitted to or through any of our Service(s). Any transmission of Personal Data, or other information, is at your own risk. By using our Service(s), you acknowledge and accept these risks. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us or that are otherwise provided to us and we cannot be responsible for the theft, destruction, or inadvertent disclosure of information. It is your responsibility to safeguard any passwords, ID numbers, or other special access features associated with your use of the Service(s). Any transmission of information is at your own risk. By using our Service(s), you acknowledge and accept these risks.
Please notify us immediately at firstname.lastname@example.org if you become aware of any unauthorized use of your password or account or any other breach of Service security or of this Policy. If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.
- Your choices, access, and rights to your Personal Data
You may change, edit, update, or delete the information you provided, when you set up your account through our Service(s), through your account settings. You may also request the deletion of this information by sending an e-mail to email@example.com.
In certain jurisdictions, you may also have the following rights and options with regard to accessing, reviewing, correcting, and updating your Personal Data, as well as how we use and disclose your Personal Data:
Right to Access. We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your Personal Data.
- How to Access Your Personally Identifiable Information. You may choose to access or update Personal Data, by logging into the account you have created with our Service(s), if applicable.
- Access to Personal Data. You may choose to access your Personal Data by contacting us and requesting access, a process which shall include our identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
Updating Communications Preferences (Opt-Out) and Unsubscribing. You may choose to receive promotional offers, newsletters, and similar communications from us regarding products and services of Spy Games and our affiliated organizations. You may opt out of receiving such communications from us by communicating your preferences to us at firstname.lastname@example.org, or in the case of e-mails, by following the unsubscribe instructions contained in the applicable e-mail.
Right to Rectify — Correction and Deletion. In some jurisdictions, you have the right to correct or amend your Personal Data if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Data; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by contacting us at email@example.com.
Right to Erasure / Be Forgotten. You may request that we delete your Personal Data in certain circumstances, such as if holding the Personal Data is no longer necessary or if part of your Right to Object (below). Please note that if you request erasure of your account, Spy Games, in complying with your request, shall also delete any and all research data that has been submitted to us through our Services. It is your responsibility at all times to ensure that you are in compliance with all applicable rules, policies, and regulations at the institutional, administrative, and federal levels regarding retention of research data, including, but not limited to, United States regulations governing retention and disposal of research records.
Fair Information Practices. The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via in site notification within 7 business days
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act. The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions.
- Process orders and to send information and updates pertaining to orders or information requested.
- We may also send you additional information related to your current or past product and/or service.
- Market to our mailing list (from us or our Trusted Suppliers) or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM we agree to the following:
- NOT use false, or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
Right to Object. You have the right to object to the user of Personal Data for direct marketing uses, scientific uses, or historical research. If you do not wish to have your Personal Data shared with third parties, contact our Data Protection Officer as described at the end of this document. If you do not wish to receive future commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. (But note that you may continue to receive certain communications from us, such as transactional or relationship messages, and/or messages about your account/profile).
Right to Restrict Processing. You have the right to request that we stop processing your Personal Data.
Right to Data Portability. You have the right to request that we provide your Personal Data for the purpose of sharing it with another service provider (through a secure process).
Filing a Complaint. If you are not satisfied with how we manage your Personal Data, you have the right to make a complaint to a data protection regulator. A list of National Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
- Access from Outside the United States
If you are visiting the Services from outside the United States, please be aware that Personal and Non-Personal Data is transferred to, stored in, and processed in the United States.
- Data Protection Officer
Please see below for information regarding our appointed Data Protection Officer.
If you have an inquiry regarding your Personal Data, pursuant to the rights listed in the preceding section (above), please send your message to the following:
Spy Games LLC
Attention: Data Protection Officer for SpyEscape.com
755 S. Main Street
Suite 4 #275
Cedar City, Utah 84720
- Links to third party sites
- Applicability of the Children’s Online Privacy Protection Act
We do not sell products or services for purchase by anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Data from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Data without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).
- Your California privacy rights
California Civil Code Section 1798.83 permits users of the Service(s) who are California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to firstname.lastname@example.org.
- Contact information
Spy Games LLC
Attention: Data Protection Officer for SpyEscape.com
755 S. Main Street
Suite 4 #275
Cedar City, Utah 84720