Last Modified: 23rd May, 2018

PRIVACY POLICY

Introduction

Blastworks Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of personal information we may collect from or about you or that you may provide to us when you visit the website  http://www.blastworksinc.com (our “Website“) and/or access any of our games, including Slingo Arcade, Slingo Adventure, Slingo Blast, Slingo Shuffle, Slingo Showcase, Slingo Casino, Classic Slingo (Slingo.com), GHSlots, Hidden Artifacts (our “Games”),  and/or our mobile or desktop apps, including Bluefin (our “Apps”), and our practices for collecting, using, maintaining, protecting and disclosing that information.  Together, where applicable, we refer to our Website, Games and Apps collectively as our “Platform”.

This policy applies to information we collect:

  • Through our Platform.
  • In e-mail, text and other electronic messages between you and our Website, or otherwise in connection with our Platform.
  • Through mobile and desktop applications, including any Games, you download from our Website, or Games and/or Apps, which you access either through or Website or separately, including from third parties, and which provide dedicated non-browser-based interaction.

It does not apply to information collected by:

  • us offline or through any other means, including on any other website operated by Company or any third party; or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from our Platform.

This policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE INFORMATION WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL INFORMATION COLLECTED
  4. HOW WE USE YOUR PERSONAL INFORMATION
  5. DISCLOSURES OF YOUR PERSONAL INFORMATION
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

Please read this policy together with any other notice we may provide on specific occasions carefully to understand our policies and practices regarding your information and how we will treat it. This policy supplements the other notices and is not intended to override them. If you do not agree with our policies and practices, your choice is not to use our Website or play our Games and use our Apps, i.e. not use our Platform. By accessing or using any part of our Platform, you agree to this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE

Controller

Blastworks Inc. is the controller and responsible for your personal information.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Blastworks Inc.

Name or title of data privacy manager:  Sr Director, Technology

Email address: privacy@blastworksinc.com

Postal address: 113 Cherry St. #22893, Seattle, WA 98104

Telephone number: 250.900.7320

If you are based in the European Union you also have the right to make a complaint at any time to the national supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.

We may change this policy from time to time as described in Changes to our Privacy Policy. Your continued use of this Website or accessing our Games or Apps, after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Persons Under the Age of 16

Our Platform or parts of it, including our Website, Games or Apps, is not be intended for children under 16 years of age . No one under age 16 may provide any information to or on our Platform. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on our Website, on or through any of its features or through our Games or Apps in violation of the applicable terms of use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@blastworksinc.com.

2. THE INFORMATION WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal information about you which we have grouped together follows:

Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.

Contact Data includes email address.

Transaction Data includes platform information on purchases (Facebook, Google Play, iTunes, Amazon Appstore).

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website, our Games, and Apps.

Profile Data includes your username, purchases or orders made by you, preferences, feedback and survey responses. 

Usage Data includes information about how you use our Website, or access our Games and Apps, such as the buttons or controls you click on, pages of our Website that you visit, the time spent on those pages, the dates and times of your visits, but also about the webpage you were visiting before you came to our Website and the webpage you go to next.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL INFORMATION COLLECTED

We use different methods to collect information from and about you including through:

Direct interactions. You may give us your Identity and Contact by filling in forms, in connection with playing our Games or using our Apps, or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you:

register to use any part of our Platform;

create an account on our Website;

subscribe to our services;

request marketing to be sent to you;

enter a competition, promotion or survey;

report a problem with our Platform; or

give us some feedback.

Automated technologies or interactions. As you interact with our Website, play one of our Games, or use any of our Apps, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below:

Technical Data from the following parties:

analytics providers such as Google, Swrve, Adjust based outside the EU;

notification providers such as Google, Swrve, Apple, Amazon based outside the EU;

advertising networks such as ironSource, AppLovin, Chartboost, Vungle, SpotX, Lifestreet, Yellowhammer, Optimatic, Brightroll, based outside the EU; and

Contact, and Transaction Data from providers of technical, payment and delivery services such as Facebook, Google Play, iTunes, Amazon Appstore.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including any advertisements, on our Platform are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

4. HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at support@blastworksinc.com.

Purposes for which we will use your personal information

We have set out below, in a table format, a description of all the ways we plan to use your personal information, and, if you are based in the European Union, which of the legal bases under the new European General Data Protection Regulation (GDPR) we rely on to do so. Where we rely on legitimate interests as a legal basis, we have also identified what our legitimate interests are where appropriate.

Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at support@blastworksinc.com if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new user

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Transaction

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business, our  Website, Games and Apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website, Games and Apps updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)


Marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. We have established the following personal information control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal information with any company outside our company for marketing purposes, including service providers who perform marketing services on our behalf, such as conducting surveys, sending communications to you on our behalf, or serving advertisements to you.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at support@blastworksinc.com.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of a service purchase, service experience or other transactions.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@blastworksinc.com.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide with the third parties set out below for the purposes set out in the table in paragraph 4 above:

To our subsidiaries and affiliates set out in the Glossary.

To contractors, service providers and other third parties we use to support our business, as set out in the Glossary.

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Platform users is among the assets transferred. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

We may also disclose your personal information:

To comply with any court order, law or legal process, including to respond to any government or regulatory request.

To enforce or apply the applicable terms of use.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.

California Residents: Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Platform that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@blastworksinc.com.

6. INTERNATIONAL TRANSFERS

We share your personal information within our company. This will involve, if you are based in the European Union, transferring your data outside the European Economic Area (EEA).

Many of our external third parties are also based outside the European Economic Area (EEA) so their processing of your personal information will involve a transfer of data outside the EEA.

If you are based in the European Union, whenever we transfer your personal information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information by the European Commission. For further details, see EUROPEAN COMMISSION: ADEQUACY OF THE PROTECTION OF PERSONAL DATA IN NON-EU COUNTRIES.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal information the same protection it has in Europe. For further details, see EUROPEAN COMMISSION: MODEL CONTRACTS FOR THE TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US. For further details, see EUROPEAN COMMISSION: EU-US PRIVACY SHIELD.

Please contact us at support@blastworksinc.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have implemented appropriate measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Platform.

For more information about the security measures we have implemented to protect your personal information, please contact us at support@blastworksinc.com.

8. DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, and Transaction Data) for five years after they cease being customers for tax purposes.

In some circumstances, if you are based in the European Union, you can ask us to delete your information: see below for further information.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

If you are a European Union resident, under certain circumstances, you have rights under data protection laws in relation to your personal information. Please click on the links below to find out more about these rights:

Request access to your personal information.

Request correction of your personal information.

Request erasure of your personal information.

Object to processing of your personal information.

Request restriction of processing your personal information.

Request transfer of your personal information.

Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at  privacy@blastworksinc.com.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@blastworksinc.com.

Performance of Contract means processing your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal information where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Service providers acting as processors based in the United States who provide SaaS based services for email and push notifications.

Social networking sites acting as processors based in the United States to which you have linked your account.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.

Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information’s accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Changes to Our Privacy Policy

This version of our Privacy Policy was last updated on May 25th, 2018 and historic versions can be obtained by contacting us at privacy@blastworksinc.com.

It is our policy to post any changes we make to our privacy policy on this. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on our Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes as you continue to use our Platform.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, please contact us at:

privacy@blastworksinc.com