Effective Date: [07.24.2019]
This Policy applies to our “Services” which include:
- Our website at playpinquest.com, and other websites where we link to/post this Policy, including any subdomains or mobile versions (the “Sites(s)”).
- The Pinquest web app at app.pinquest.com (the “App”).
This Policy applies to all “Users” of our Services including:
- Operators: bars, arcades or other third parties that operate pinball quests through Pinquest (“Quest”).
- Players: Users participating in Quests.
- All other Users of our Services that provide Personal Data to Pinquest.
Your use of our Services indicates your acknowledgement of the practices described in this Policy.
COLLECTION AND USE OF PERSONAL DATA
Personal Data We Collect
In order to provide our Services, we may collect and process data that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements are examples and may change):
|Identity Data:||Personal Data about you and your identity, such as your name, username, and other Personal Data you provide on registration forms or as part of an account profile.|
|Contact Data:||Personal Data used to contact an individual such as phone number, email address, physical address, and social media or communications platform usernames/handles.|
|Payment Data:||Personal Data relating to certain financial information such as your bank account or credit card information, CVC2/CVV2 code, or other information necessary to facilitate the processing of payments.|
|Location Data:||Personal Data relating to your precise location, such as information collected from your device’s GPS, Wi-Fi network, cell towers, or other precise localization service.|
|Quest Data:||We collect data about your participation in, and completion of our Quests, missions, and specific challenges that may comprise these Quests/missions, such as progress, score, etc.|
|User Content:||Personal Data included in content provided by Users of the Platform in any free-form or unstructured format, such as in an image upload, a “contact us” box, free text field, in a file or document, messages to us, messages to other Users, etc.|
|Device/Network Data:||Personal Data relating to your device, browser, or application. This can include IP addresses, operating system, MAC addresses, application ID/AdID/IDFA identifiers from cookies, session history and similar browsing metadata, and other data generated through applications and browsers, including via cookies and similar technologies.|
|Inference Data:||Personal Data inferred about your personal characteristics and preferences, such as a profile reflecting demographics, interests, behavioral patterns, purchase habits, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.|
How We Collect Personal Data
We collect Personal Data from various sources based on the context in which the Personal Data will be processed:
|Data we collect from you:||We collect Personal Data (such as Identity Data, User Content, or Contact Data) from you directly, for example, when you input Personal Data into an online form, or contact us directly.|
|Data we create or infer:||Personal Data (such as Inference Data) b created or inferred based on observations or analysis of other Personal Data processed in connection with our Services; this data may be correlated with other data processed about you.|
|Data we receive from others:||We receive Personal Data (such as Contact Data or Transaction Data) from third parties with whom we have a relationship in connection with the services they provide, for example, an online payment processor that is operated by a third party on our behalf.|
|Data collected automatically:||Personal Data (such as Device/Network Data) collected automatically in connection with your use of our Services. For example, Device/Network Data is automatically collected via cookies and similar technologies when you browse our Site and when you open our marketing communications.|
Ways we Process Personal Data
Registration & Profile Creation
|Data:||Users may register and create an account on our Services. If you choose to register, we will process __Identity Data__ and __Contact Data__. You may also choose to provide us with certain __User Content__, for example, if you add Personal Data or a picture or image to your User profile. If you are an Operator, we may also collect __Payment Data__ in order to process your subscription fee payment.|
|Uses:||We use Identity Data, Contact Data, and User Content as necessary to create and maintain your account, to provide our Service and complete your requests, provide you with important information about your account and our Service. We use Payment Data in order to process the payment transactions you request. Subject to Your Rights & Choices , and consistent with our business interests, we may process Identity Data and Contact Data in connection with Marketing Communications, Aggregate Analytics, Internal Processes and Service Improvement, and for the other lawful purposes described below.|
|Data:||We process __Identity Data__, __Contact Data__, __Quest Data__, and __Location Data__ when you sign up for a Quest, provide information as part of your completion of various missions, or otherwise participate in the Quest and related activities.|
|Uses:||We process all data collected as part of a Quest as necessary to record your entry into the Quest, manage and document the completion of missions and Quest objectives, and for other purposes necessary in connection with the operation of the Quests. Subject to Your Rights & Choices, we also use Location Data in connection with your participation in specific missions or Quest activities, or at your request. The use of Location Data may be required so that we can validate entry into a contest. For example, when you participate in a Quest that involves the completion of missions at specific locations, we may require you to share Location Data with us, or a third party Operator, so we or that Operator can validate that the mission was completed at the correct location. You may also consent to the use of location services for other purposes, for example, if you search for games, Quests, or missions in your area. You may revoke your consent to process Location Data at any time through your browser or app settings menu. Revocation of consent will not affect Location Data you have already provided. Subject to Your Rights & Choices, and consistent with our business interests, we may also process data collected as part of your participation in a Quest in connection with Marketing Communications, Aggregate Analytics, Internal Processes and Service Improvement, and for the other lawful purposes described below.|
Special Programs and Offers
|Data:||We may process additional __Identity Data__ and certain __Contact Data__ if you choose to participate in a special program or offer as part of our Service or a Quest, e.g. a contest or promotional challenge. For example, we may collect additional Identity Data such as your birthdate and address to verify your eligibility to receive, or to send you, contest prizes. Additional information may necessary for you to participate in the special program or offer. Please see the program/offer for details.|
|Uses:||We use this Identity Data and Contact Data as necessary to carry out the special programs and related transactions, and to complete any required registration or entry. We may share this Personal Data with third party sponsors or Operators that run the special program/offer. If you participate in a Quest as part of a special program, we will collect the Personal Data as part of the Quest as described above, and we may share also that Personal Data with the sponsor or Operator. Subject to Your Rights & Choices, and consistent with our business interests, we may process Identity Data and Contact Data in connection with Marketing Communications, Aggregate Analytics, Internal Processes and Service Improvement, and for the other lawful purposes described below.|
|Data:||We may process __Identity Data__, __Device/Network Data__, __Inference Data__ and __Contact Data__ in connection with marketing communications (such as emails), which you might receive if you register for an account, choose to receive marketing communications, or engage in a transaction allowing us to send you those marketing communications. We may also collect __Device/Network Data__ when you open or interact with those marketing communications.|
|Uses:||Subject to Your Rights & Choices, we use __Identity Data__ and __Contact Data__ as necessary to customize, deliver, and otherwise process marketing communications, and in order to tailor certain communications to individuals’ preferences and requests including to determine incentives for a particular User. Additionally, we may process __Device/Network Data__ and __Usage Information__ from devices receiving those marketing communications as part of our business interest in understanding whether our emails are opened or other aspects of engagement with such marketing communications.|
|Data:||When you contact us though the Services (including through our chat), we process certain Personal Data such as __Identity Data__, __Device/Network Data__, __Transaction Data__, and any Personal Data contained within any __User Content__.|
|Uses:||To the extent that you provide it, or processing is necessary in connection with your request, we may use __Identity Data__, __Contact Data__, __Transaction Data__, __User Content__. Subject to Your Rights & Choices, we may also use __Identity Data__ and __Contact Data__ in connection with Marketing Communications, if relevant to your request (such as when you request more information about our Services), and for Internal Processes and Service Improvement, and for other lawful purposes described below.|
Cookies and Similar Tracking Technologies
|Data:||We, and certain third parties, may process __Identity Data__, __Contact Data__, __Usage Information__, __Location Data__, and __Device/Network Data__ when you interact with cookies and similar technologies on our Services. We may receive this data (or Aggregated Data derived from it) from third parties to the extent allowed by the applicable partner. Please note that the privacy policies of third parties may also apply to these technologies and the Personal Data collected through them.|
Subject to Your Rights & Choices, we may use this data as follows:
|Note:||Some of these technologies can be used to identify you across platforms, devices, sites, and services.|
How we Process Data for Specific Purposes
Subject to Your Rights & Choices, we will collect and aggregate your Personal Data and information about your use of the Services in order to identify certain trends in how our Services are used and perform, the individuals who use our Services, and the products and services most relevant to Users (“Aggregated Data”). Aggregated Data does not include data about individual Users. We may use this data in order to create analytics that help us better identify patterns and trends among markets, User engagement, and interest in advertised events.
Internal Processes and Service Improvement
Subject to Your Rights & Choices, we may use any Personal Data we process through our Services as necessary in connection with our business interests in improving the design of our Services, to create a personalized user experience (such as greeting you by name and suggesting Parking Spaces based on your preferences), and for ensuring the security and stability of the Service. For example, we may use Personal Data to understand what parts of our Services are most relevant to Users, how Users interact with various aspects of our Services, how our Services perform or fail to perform, etc., or we may analyze use of the Services to determine if there are specific activities that might indicate an information security risk to the Services or our Users.
If we process Personal Data in connection with our Services in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to Your Rights & Choices) unless otherwise stated when you provide it. Note that we may, without your consent, also process your Personal Data on certain public interest grounds. For example, we may process Personal Data as necessary to fulfill our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest. Please see the Data Sharing section for more information about how we disclose Personal Data in extraordinary circumstances.
Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that data was provided. We generally transfer data to the categories of recipients or in connection with specific business purposes, each described below.
Operators & Sponsors
When you participate in Quests, or in special promotions/offers that are run by an Operator, or other third party, we share certain Personal Data collected in connection with Quests, and Special Programs/Offers with those parties. For example, if you complete an Operator’s Quest, the Operator may receive data so that they can validate your reward. Similarly, a sponsor of a contest will receive the contest entry data we collect on their behalf.
In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other lawful business interests, we may share your Personal Data with service providers or subprocessors who provide certain services or process data on our behalf. For example, we may use cloud-based hosting providers to host our Services or disclose data as part of our own internal operations, such as security operations, internal research, etc.) When we disclose data for business purposes we may disclose Identity Data, Contact Data, Device/Network Data, and User Content, Quest Data, Location Data, Payment Data, and Inference Data.
Your Personal Data may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
In order to streamline certain business operations, share promotions and content we believe would be of interest to you, and develop products and services that better meet the interests and needs of our customers, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.
In order to deliver certain advertisements, and develop better products and services, we may share with trusted third parties for marketing, advertising, or similar commercial purposes the Personal Data described in the Cookies and Similar Technology section, and any data that we may use for Marketing Communications.
Other Disclosures with Your Consent
We may ask if you would like us to share your data with other unaffiliated third parties who are not described elsewhere in this policy.
Other Users and the Public
Some Personal Data that you provide may be available to other Users. For example, we may operate a leader board that shows other Users’ username and score, as well as a photo or other User Content you upload to show your completion of a Quest, mission or other challenge. We may also allow for communication between Users or comments or community message features, in which case the messages you send to other Users may be available to them, or to others who view the comments, including any Personal Data or User Content you include in them.
For purposes of the California Consumer Privacy Act, we do not sell your Personal Data.
YOUR RIGHTS & CHOICES
To the extent required under applicable law, and subject to our rights or obligation to limit or deny access or disclosure, you may have the following rights in Personal Data:
|List of Data:||You may receive a list of the specific Personal Data about you that we process.|
|Rectification:||You may correct any errors in Personal Data that we hold about you.|
|Erasure:||You may request that we delete your Personal Data from our systems. If required by law we will grant a request to delete your Personal Data, but you should note that in many cases we must keep your Personal Data to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.|
|Data Export:||You may request that we send you a copy of your Personal Data in a common, portable format of our choice.|
|Regulator Contact:||You have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. Your appropriate local data protection or consumer protection authority varies based on your location and jurisdiction.|
|California Rights:||Residents of California (and others to the extent required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. You may also request that we provide you a copy of your Personal Data, direct us to stop selling or disclosing Personal Data for certain purposes (if we have done so), and receive information regarding: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties with whom we have disclosed your Personal Data, or sold, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.|
You may exercise these rights by Contact Us at the address below and submitting a request. We respond to only verifiable requests, and we may require that you provide additional Personal Data to exercise these rights, e.g. Personal Data necessary to verify your identity.
Note: We are able to fulfill rights requests regarding Personal Data that we control or process. We may not have access to or control over Personal Data controlled by third parties, including Operators. Please contact the third party directly to exercise your rights in third party-controlled information.
You may have the following choices regarding the Personal Data we process, to the extent required under applicable law:
|Consent:||If you consent to processing, you may withdraw your consent at any time. You may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of our Services. If you withdraw your consent to the processing of __Location Data__ then we will no longer be able to participate in certain aspects of our Services, including Quests.|
|Direct Marketing:||You have the choice to opt-out of or withdraw your consent to marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications or by contacting us re: direct marketing.|
|Other Processing:||You may have the right under applicable law to object to our processing of your Personal Data for certain purposes, including without limitation, situations where we process in accordance with our business interests. You may do so by contacting us re: data rights requests. Note that we may not be required to cease processing based solely on your objection.|
We follow and implement reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and we do not have control over third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.
We retain Personal Data for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.
Our Services are neither directed at nor intended for use by minors under the age of majority in the relevant jurisdiction. Further, we do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it.
We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Data may be transferred to the U.S.
CHANGES TO OUR POLICY
We may change this Policy from time to time. Please visit this page regularly so that you are aware of our latest updates. Your use of the Services following notice of any changes indicates acceptance of any changes.
Feel free to contact us with questions or concerns using the appropriate address below.