VEGAS FUN LLC, (“VEGAS FUN”,” “we,” “us” or “our”) value your privacy. We offer a variety of games through various means, including our mobile applications (collectively, our “Applications”). On our website www.VegasFunGames.com (the “Site”), we provide information about our products and services, including our Applications, and how you may redeem certain points that you earn through the Applications. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our Site and our Applications, and the services offered on each (collectively, “Services”).
By using any of our Services or visiting our Site or Applications, you agree that your personal information will be handled as described in this Policy. Your use of our Site, Applications or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The VEGAS FUN Terms of Services are incorporated by reference into this Policy:
All capitalized terms used in this Policy and not defined within the Policy are defined in the Terms of Service.
TABLE OF CONTENTS
GDPR AND YOUR RIGHT TO ACCESS YOUR PERSONAL DATA, CORRECT YOUR PERSONAL DATA, AND TO BE FORGOTTEN.
If you are a citizen of any country in the EU, you have certain rights regarding your personal data that are governed by the General Data Protection Regulation (“GDPR”) adopted by the EU Parliament. If the GDPR applies to you, you have the right to access personal data that we process, request corrections to any of that data, as well as request to be forgotten. Even if the GDPR doesn’t apply to you, we are committed to providing you with the same rights you would have if it did.
To receive a copy of the personal data we process, request that corrections be made to your personal data, or to request to be forgotten, please send your request by mail or email to:
VEGAS FUN GAMES LLC
Attn: Privacy Department 1522 W. Warm Springs Road, Henderson, NV 89014
contactus@VegasFunGames.com
WHAT IS “PERSONAL DATA”?
The European Commission defines personal data as any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data.
Examples of personal data include your name and surname, your email address, your mobile phone’s device ID, an IP address, and the advertising ID of your phone. Personal data that has been rendered anonymous in such a way that the individual is not or no longer identifiable is not considered personal data
WHAT HAPPENS IF YOU REQUEST TO BE FORGOTTEN?
If you request to be forgotten, we will delete or anonymize your personal data such that you cannot be identified from the data that we retain, unless we have a basis to maintain it (see below “How long will we store your personal data?”).
Please know, however, that if you request to be forgotten and subsequently download and play any of our Applications, none of your historical performance data will be available, meaning you will lose any virtual currency, game progress, and Reward Points you had at the time your request is processed.
WHAT HAPPENS IF YOU WITHDRAW YOUR CONSENT FOR US TO PROCESS YOUR PERSONAL DATA?
If you withdraw your consent for us to process your personal data, we will treat your request as a request to be forgotten. We must take this action because when you play any of our Applications, whether via a mobile device or Facebook, we obtain and process personal data.
HOW LONG WILL WE STORE YOUR PERSONAL DATA?
We will store your personal data no longer than is necessary for the purposes for which your personal data is processed. If you submit a request to be forgotten, we will either delete or anonymize your personal data unless we have a legal obligation to continue to store the personal data, or for the establishment, exercise or defense of a legal claim. For example, if you have made purchases within any of our Applications, or redeemed a Reward, we may store your personal data for as long the statute of limitations for making a claim relating to that purchase or redemption. If you have indicated in any way that you believe you have a dispute with us, we may store your personal data at least until that dispute is resolved.
We may store anonymized data indefinitely. We maintain this type of data to compare performance of our Site, our Applications and our Services over past periods, to analyze current performance, to measure player activity over time, and for other business uses.
ACCESS TO AND MODIFICATION OF YOUR PERSONAL INFORMATION IN THE APPLICATIONS AND ON FACEBOOK.
In addition to making a request to rectify your personal data, you may modify personal information that you have submitted by logging into your account and updating your profile information. You also may deauthorize the VEGAS FUN Facebook application from your Facebook page. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Applications for a period of time.
If you would like to access or modify your Facebook profile information, or adjust the types of information we receive from Facebook, you must adjust your Facebook account settings directly through Facebook. We have no control over how Facebook shares your information with us or other third parties. The information you provide to Facebook is subject to the Facebook Privacy Policy.
What Information Do We Collect About You and Why?
INFORMATION WE COLLECT DIRECTLY FROM YOU AND AS YOU PLAY OUR GAMES.
Certain areas and features of the Applications require registration, such as to accumulate, purchase and redeem Reward Points, Virtual Items and Rewards, and to post any User Content. To register, you must create an account with VEGAS FUN by accessing our Applications through your Facebook account. You may earn Reward Points as you visit our Applications, and we will keep track of your Reward Points. If you choose to purchase a Reward with your Reward Points, we will collect your name and email address in order to process your Reward.
We also collect data about your play activity on our Applications, including what games you play, your spins, game play outcomes, your use of virtual chips, game progress, leaderboard progress, and participation in special events or offers.
INFORMATION WE COLLECT ABOUT YOU FROM FACEBOOK.
When you log into our mobile application through your Facebook account, you will be asked to enter your Facebook email address and password. Facebook controls the information collected from you during the log-in process; VEGAS FUN does not control the information that Facebook collects from you. When you use any of our Applications through Facebook or on a mobile Application that you have connected to Facebook, we will have access to, and may collect and store, the following information: your Facebook ID, your first and last name, profile picture, gender, networks, user IDs, list of friends, your locale and time zone, third-party ID, date of birth, email address, and IP address. We will also have access to any other information you have set to public on your Facebook account. We may use this information to (i) send you email; (ii) post to your Wall; (iii) access posts in your news feed; and (iv) access your Facebook data at any time even if you are not using Facebook. Please note, if you allow VEGAS FUN to have access to this information, then VEGAS FUN will have access to this information even if you have chosen not to make that information public.
For information about how Facebook may disclose your information, including any information you make public, please consult the Facebook Privacy Policy. We have no control over how Facebook uses or discloses the personal information you provide to it. We store the information that we receive from Facebook along with other information that we collect from you or receive about you.
INFORMATION WE COLLECT AUTOMATICALLY; COOKIES AND OTHER TRACKING TECHNOLOGIES.
We use cookies, including Flash cookies, and other tracking technologies (including technologies designed for mobile devices) to track information about your use of our Services. We automatically collect the following information about you from your use of our Services through these technologies: your browser type and operating system; web pages you view; links you click; your IP address; and the length of time you visit our Site, Applications, and/or use our Services.
For users of our mobile application, in addition to the information listed above, we collect the following: language information, unique device identifier (as permitted), device advertising id, device name and model, device operating system, and system memory size.
We may use this information in the aggregate or we may combine it with personal information about you.
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Applications, while other cookies are used to enable a faster log-in process or to allow us to track your activities at our Site and Applications. There are two types of cookies: session-based and persistent-based cookies.
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Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
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Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, which may be combined with other user information.
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Third Party Cookies. We may also engage third parties to track and analyze non-personally and personally identifiable Site data. We use the data collected by such third parties to help us administer and improve the quality of the Site and to analyze Site usage. Such third parties may combine the information that we provide about you with other information that they have collected. This Policy does not cover such third parties’ use of the data.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.
Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. You cannot control, delete, or disable the acceptance of Flash LSOs through your browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash cookies, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel“ and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
INFORMATION WE COLLECTION FOR ANALYTICS PURPOSES.
We use automated devices and applications, such as Google Analytics or Facebook Insights, to evaluate usage of our Site and, to the extent permitted, in our Applications. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services and user experiences.
HOW WE USE YOUR INFORMATION.
We use the information that we gather about you for the following purposes:
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To provide our Services to you, to communicate with you about your use of our Services.
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To respond to your inquiries.
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To fulfill your orders, facilitate redemption of Rewards, and for other customer service purposes.
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To track your play activity and progress in our games.
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To provide personal hosted services to you.
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To track Application crash events.
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To tailor the content and information that we may send or display to you, to offer location customization, and to otherwise personalize your experiences while using the Site, Applications, or our Services.
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Where permitted by law, and in accordance with Facebook’s applicable terms and conditions, for marketing and promotional purposes. For example, we may use your information, such as your email address, to email you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you.
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To assist in determining where to advertise our Services on third party websites.
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To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services, analyze player traffic and activity, respond to user desires and preferences, and for other research and analytical purposes.
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If you installed one of our Applications because you viewed a mobile ad, we will use information to identify the third-party ad network that displayed the mobile ad for us.
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We also may post to your Facebook Wall, access posts in your news feeds, and access your Facebook data when you are not logged into Facebook. We will use and access this information for the purposes described in this section and as discussed below
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As required or permitted by law.
HOW WE SHARE YOUR INFORMATION.
We may share the information that we receive from you, including personally identifiable information, as follows:
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VEGAS FUN Users. Your username and any information that you post to VEGAS FUN, including, without limitation, reviews, comments, scores, participation in the game, and text will be available to, and searchable by, all other VEGAS FUN users.
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Our Partners. We may share certain information regarding your Rewards with our partners. The partners will use this information solely for the purpose of determining your eligibility for the Reward. Any information that you submit to a third party will be governed by that third party’s website privacy policy and not this Policy. We do not share your personal information with our partners or other third parties for their direct marketing purposes.
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Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
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Business Transfers: If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
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In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena, or to meet national security or law enforcement requirements.
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To Protect VEGAS FUN and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation in which VEGAS FUN is involved.
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Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
THIRD-PARTY LINKS.
Our Site and Applications contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
USER GENERATED CONTENT.
We may permit users to submit their own content to our Site and Applications including, without limitation, pictures, reviews, comments and other text. We are not responsible for the privacy of any information that you choose to submit through our Site, Applications and Services, or through any public forum, such as a blog, or for the accuracy of any information contained in those postings. Any information that you disclose becomes public information. We cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
SECURITY OF MY PERSONAL INFORMATION.
We have implemented commercially reasonable precautions designed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. To change your Facebook password, you must go to the Facebook site and follow its procedures for changing your password.
WHAT CHOICES DO I HAVE REGARDING OPTING-OUT OF PROMOTIONAL OR INFORMATION EMAILS?
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
As noted above, to adjust the types of information about you that we receive from Facebook, you must change your Facebook account settings directly through Facebook.
THIRD-PARTY AD NETWORKS.
We may use third parties to assist us in advertising our Site, Applications and Services, and we participate in third-party ad networks that may display advertisements on other websites or mobile applications based on your visits to our Site as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your usage of our Site and our Services, as well as aggregate or nonpersonal information about visitors to our Site and users of our Service.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).
Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt- out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.
CHILDREN UNDER 13.
Our Services are not designed for persons under 18. We do not knowingly collect information from persons under 18, including children under 13 in particular. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
SPECIAL NOTICE TO CALIFORNIA CONSUMERS.
California residents may request a list of certain third parties to which we have disclosed certain personal information about you for the third party’s own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for our response to you. We will respond to you within thirty (30) days. You may request this information in writing by contacting us at:
Attn: Privacy Department
VEGAS FUN GAMES LLC 1522 W. Warm Springs Road, Henderson, NV 89014
contactus@VegasFunGames.com
CONTACT US.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at contactus@VegasFunGames.com or at:
Attn: Privacy Department
VEGAS FUN GAMES LLC 1522 W. Warm Springs Road, Henderson, NV 89014
contactus@VegasFunGames.com
CHANGES TO THIS POLICY
This Policy is current as of the effective date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site.