(Last updated on February 26, 2015)
Vegas Games Inc. develops and publishes casino games and other Apps that can be accessed or used in connection with certain mobile and non-mobile devices and/or that can be accessed via the Internet at various websites, including websites that are owned or controlled by Vegas Games, as well as third-party websites that are licensees or otherwise in a business relationship with Vegas Games or one or more of its affiliates.
2. Managing Your Information Preferences
We do not share your Personal Information with third parties for their direct marketing purposes without your consent. If you desire to opt out of having your Personal Information disclosed to third parties for their direct marketing purposes, please contact us and let us know by sending an email to firstname.lastname@example.org or by writing to us at Vegas Games Inc., Attn: Customer Service – Privacy, 850 Stanton Road, Suite D, Burlingame, CA 94010. If such a need should arise, we ask that you please include your full name, email address, mailing address, and a declaration stating that you do not want your Personal Information shared with third parties for their direct marketing purposes.
3. Information We Collect
Personally Identifiable Information
Non-Personally Identifiable Information
We also collect information that by itself cannot be used to identify or contact you, which includes demographic information (e.g., your age, gender, profession, etc.) (collectively, "Non-Personally Identifiable Information"). Non-Personally Identifiable Information also includes information regarding browser types, domain names, and other statistical data, that is automatically collected through the actions you take in connection with the Service and in connection with any particular App (collectively, "Usage Data"). For example, in addition to your devices’ IP addresses as previously mentioned, each time you use the Service we automatically collect the type of information regarding your web browser, operating system, internet service provider, webpages you view, and the time and duration of your visit to and use of the Service. This usage information is coupled with your username and profile, but we do not disclose the associated information to third parties. Non-Personally Identifiable Information is used to help us garner insights into our Users, their interests, and their preferences, so that we are better able to create effective content for advertising and promotional purposes and so that we can design and develop more compelling versions of our casino games and other Apps.
Information You Provide to Us
We collect information that you choose to provide to us directly. For example, we collect information when you register with us and create an account, manage your user profile, participate in any interactive features of the Service, participate in a promotion or survey, request customer support, or choose to communicate with us for any other reason. Additionally, individuals who win prizes as a result of participating in any contests or sweepstakes may be required to provide certain PII (e.g., the winner’s Social Security Number, street address, telephone number, etc.) for prize fulfillment and for tax purposes.
You are required to register with Vegas Games in order to access and use our Apps or to participate in certain activities and/or audiovisual content materials that are part of the Service. In completing the registration process, you must provide true, accurate, current, and complete information about yourself. The required information will vary depending on the activity and, for example, may include your age (or birth date), name, e-mail address, passwords, etc.
Vegas Games and its affiliates will only permit access to information that is considered "public" or that you have designated as "public" in your settings. Your name (including both your first and last names) and profile picture are considered "public" on Vegas Games’ websites that offer direct access to the Service and our Apps, and, as is true of any publicly available information, third-party search engines may index such information.
You may choose to import your address book contacts and/or manually enter e-mail addresses into your user profile or account information in order to (i) identify and locate your contacts that are using any of our Apps or other aspects of the Service; and/or (ii) invite your contacts to join you when you play a particular App. Your designated contact information will be stored for the purpose of aiding you and your contacts to connect online so that you can play our Apps together and/or jointly participate in other aspects of the Service. If you do not want us to store your contacts, you must either refrain from sending requests to any of your contacts, or, if such a request has been sent, then you must terminate your account and create a new account where you refrain from sending any requests to any of your contacts.
We take your security seriously and will use diligent efforts to respect your privacy throughout our relationship. Please be advised that any password(s) that you choose to provide to Vegas Games so that we are able to access your address book contacts will not be stored or shared with any unaffiliated third parties.
Information collected from users through a mobile device (e.g., smartphone, tablet, or other mobile communications or computing device, etc.) includes the mobile device identifier(s) (e.g., IP address, MAC address, etc.), name associated with the device, type of device, mobile device model, mobile phone number, the mobile carrier used with the device, country, geo-location, and email address. We will, at our discretion, create and assign an account number or other such identifier(s) to your device(s). If permission is granted, we will also access your contacts so that you may invite your friends to join you in playing one of our Apps or in connection with another aspect of the Service.
Social Networking Sites
You will need to provide certain PII in order to make a purchase and/or pay for certain activities or aspects of the Service or any of our Apps. For example, such information will be required when acquiring a license for virtual currency, purchasing digital items, and/or obtaining upgrades or customized versions of any of our Apps. Vegas Games will collect your accurate, current, and complete billing information when it is necessary in order to complete a transaction. This may include your mailing address, as well as your e-mail address. If any update(s) to your billing information is required, you must make them promptly. For example, updates would include any changes with respect to your billing address, shipping address, credit card number, or credit card expiration date. Please review our Terms of Service, which describes the relevant terms and conditions regarding our billing practices and related activities, including, but not limited to, our billing practices.
Your information will also be collected when you submit, disclose or share information within the context of any of our Apps, or any related message boards, forums, and/or other aspects or activities of the Service. The Service allows you to create, submit, post, display, transmit, perform, publish, distribute, broadcast or otherwise disseminate audio and/or visual content materials to Vegas Games or any of its affiliates. This includes text, graphics, comments, forum posts, chat posts, messages, profiles, suggestions, recommendations, links, e-mails, music, sounds, sound effects, pictures, photos, drawings, caricatures, videos, technology, software, code modules, tools, utilities, and any other materials and/or information displayed or otherwise made available to and/or by means of the Service (collectively "Content"). Content also includes any feedback, comments, suggestions, recommendations and/or proposals that you may provide regarding the Service, or any of the Apps, and/or any other Content, including, without limitation, any responses that you may elect to provide in connection with any user surveys.
Your interactions with our team will require that we collect and store certain contact information that you provide so that we can efficiently and effectively respond to your questions and requests relating to the Service and/or any of our Apps. Other information that may be collected and stored could include information concerning your game play, and your activities when accessing and using the Service, any of our Apps, and/or participating in any related activities. Any such communications may also be retained for future reference, including any information that is contained within such communications.
SMS Notifications, Push Notifications & Local Notifications
If you choose to sign up to have SMS notifications sent to your smartphone or other mobile device, please be aware that we will store the information that you provide, which may include, but is not limited to, your telephone number. You will have access to certain options in your notifications settings that allow you to choose the form of notifications that you would like to receive and the timing of such messages. This can be done by accessing the "Settings” page after logging into your account.
We also use what are commonly referred to as "push notifications" to provide updates and other messages to interested Users who access and use the Service or any of our Apps. Your settings for such push notifications can be adjusted by accessing the Settings page within any of our Apps. Your device’s Settings page may also provide you with the opportunity to manage such settings and controls.
We also send local notifications to your mobile device to provide you with updated information regarding the Service and our Apps and related activities and service offerings. You can manage your settings for local notifications from the Settings page within the relevant App.
4. How We Collect Information
We will collect information from you and other Users of the Service and/or any of our Apps, such as the number of Users of the Service, feature usage, game play statistics, user rankings, click paths, and other such information and related data. Please be advised that we collect information and data in the following ways:
Information about Users and their Experiences with the Service and our Apps
When you play or otherwise participate in any of our casino games or other Apps, Vegas Games collects and stores particular information that is provided by you directly, or provided by means of the SNS (or other third-party website you may be using) that offers access to any of our Apps. In order to provide better Apps, as well as more engaging and enjoyable social experiences, we also gather information that relates to your specific gameplay, interactions with other Users, and experiences within the Service and in connection with our Apps. This information is collected and stored through the use of log files, which includes IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Service and/or any of our Apps.
Cookies and Other Tracking Technologies
You will be able to communicate or share information with not only Vegas Games and its affiliates, but also with other Users and with third-parties that are licensees, sponsors, advertising networks, or other business partners of Vegas Games. You may disclose information about yourself when contributing Content, playing any of our Apps, participating in chat rooms, writing on message boards, submitting or updating user profiles, or engaging in similar forums or other online activities that are part of the Service or any of the Apps. Any information that you choose to disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality with respect to any and all such information.
The Service allows Users to interact with one another, and, consequently, your friends and contacts on a particular SNS may see, for example, your name, profile photo, App name, game-related activity, game-related profile, game-related stats, and even your SNS ID number. This information allows others to view public information associated with your SNS account or your account with Vegas Games or any of its affiliates. Other Users may send you "friend requests" or game requests by means of a particular SNS.
Please be aware that any PII that you submit while using the Service can be read, collected, and used by other Users, and may be used to send unsolicited messages to you and/or to your account. Vegas Games is not responsible, and shall have no obligation or liability, for any PII that you choose to submit in any such public forums. Please refer to our Terms of Service for further information regarding User-generated Content.
We reserve the right to record and store archives of these communications on servers that are owned or controlled by Vegas Games or any of its affiliates. To protect the safety and well-being of our Users, to preserve and maintain the security and integrity of the Service and our Apps, and to protect and enforce Vegas Games' rights and interests in and relating to the Site, the Service and the Apps, Vegas Games expressly reserves the right to record and store archival copies of any and all communications that are undertaken and/or otherwise occur on any and all servers that are owned or operated for the benefit of Vegas Games or any of its affiliates. You acknowledge and consent to the recording and storage of such communications for any such purposes. If you do not wish for Vegas Games or any of its affiliates to have access to any particular information, please do not submit or otherwise contribute it by means of our Site or the Service or any of our Apps. While we encourage all of our Users to avail themselves of our Service, the Site and our Apps to its/their full potential, we also want our Users to be aware of their privacy rights and to take reasonable steps to safeguard their privacy rights by, for example, managing their activities and disclosures of PII in an appropriate and responsible manner.
Vegas Games and its affiliates also collect or receive information from other sources including (i) other Users who upload information regarding their email contacts or SNS contacts; and (ii) third-party information providers. Such information is used by Vegas Games and its affiliates to supplement your profile (e.g., to help you and your contacts connect with one another to jointly experience the Service or any of our Apps) and will be combined with other information that we collect to help us better understand your activities and experiences with the Service, the Site and our Apps, as well as those of other Users.
5. How We Use Collected Information
In most cases we use the information that we collect in order to better understand our Users, to help us improve the Site and our Apps, along with the marketing and promotional materials regarding our Apps. In this way we can provide a safe, efficient, and customizable experience that will stay abreast of changing consumer demands that arise in connection with this rapidly evolving technological age. We use PII for internal purposes only, for example, providing Users with access to and use of the Service on various mobile and non-mobile devices, responding to specific requests, processing transactions, responding to your inquiries, providing notifications, soliciting feedback and input, improving our Apps, the Site and/or the Service, fulfilling your orders, notifying you of new products and services, and to otherwise communicate with you about the Service, the Site and our Apps.
6. Sharing and Disclosing Information
We may establish a business relationship with other persons or entities whom we believe are trustworthy and who have confirmed that their privacy practices are capable of maintaining the confidentiality, security, and integrity of information that is provided to them and who provide assurances that they will maintain the information in such a manner (collectively, "Third-Party Providers"). For example, we may contract with Third-Party Providers to undertake a particular service on our behalf (e.g., responding to requests, order fulfillment, payment processing, data analysis, e-mail services, hosting services, data storage, customer service, to provide marketing and promotional information, and to enhance your activities and experiences while accessing and using the Service, the Site and/or our Apps. If any Third-Party Provider needs to have access to any PII that you provide to us, we will provide the applicable Third-Party Provider with only the information that is needed to perform the corresponding services. Each Third-Party Provider must comply with our privacy policies and maintain the confidentiality of the information that we share with them by using reasonable security procedures and practices that are suitable according to the nature of the information involved, and that are capable of protecting your PII and maintaining the confidentiality, security and integrity of such information from unauthorized access, use or disclosure. Third-Party Providers are prohibited from using PII for any purpose other than providing their contracted service(s) on our behalf.
In some situations, we provide services in cooperation with another company or other such entity. In such cases it may be necessary to share your PII with such Third-Party Providers in order to facilitate the performance of the affected services. However, before we do so, we will identify the Third-Party Provider and request your permission to share your PII.
Friends and Other Vegas Games Users
The Service is designed, supports and encourages interaction among our Users and other individuals who access and use the Service, the Site and/or any of our Apps. For that reason, your SNS friends may be allowed to see your name, profile photo and your game-related activities. Within our Apps, your SNS friends and other Users are able to see your game profile, which may include your name or a "game name" (e.g., a made-up, anonymous account name) and your profile photo and related information, which in some cases may reveal your device ID, SNS User ID number or Vegas Games ID. For example, in Vegas Games’ Texas Hold ‘Em Poker App, any User may encounter your game profile if you are playing at the same table. Access to a Vegas Games ID or your SNS User ID allows other Users to view the public information associated with your related SNS account or the account that you choose to establish with Vegas Games. Other Users may also be able to send you requests asking you to join in playing a particular App at a given time or may contact you with friend requests through the applicable SNS’s communication channels.
Our Apps or their respective webpage(s) within the Site or the Service may display one or more special offers that are hosted by a third-party sponsor. Such special offers typically allow third-party sponsors (which may include Third-Party Advertisers) to provide virtual currency to our Users in exchange for such individuals completing a particular marketing offer.
Please be aware that any such special offers are not made or otherwise provided by Vegas Games. These offers will be displayed to you as the result of certain information being collected regarding you or your mobile or non-mobile device (e.g., anonymous demographic information, etc.). If a User chooses to click on one of these special offer advertisements, he or she will, in all likelihood, be directed to a site that is not owned or operated by Vegas Games or a partnering SNS. In order to properly credit the relevant User’s account and to prevent fraud, a unique identifier (e.g., an email address, account ID number, etc.) will be shared with the sponsor or other originator of a special offer advertisement.
Safety, Security and Compliance with Law
Vegas Games cooperates with government and law enforcement officials and private parties to enforce and comply with all applicable laws and regulations. You understand and agree that we may disclose to relevant governmental agencies and authorities PII that we have collected from and about you, and that your PII may be accessed and monitored in connection with the provision of the Service, the Site and/or the Apps. Such information will be disclosed to law enforcement or appropriate civil authorities if and as required by law, and to comply with legal processes. We will also disclose information if, in our sole discretion, we believe that such disclosure is necessary or appropriate in order to respond to legal requests, to avoid liability, to prevent potential or actual injury, loss or damage, to protect the rights and interests of Vegas Games or the safety of any third party, to prevent or stop any illegal, unethical or legally actionable activity, or to comply with any applicable laws or regulations. You acknowledge and agree that Vegas Games is not required to contest the validity or provide notice of any search warrant, subpoena or other governmental request of a similar nature.
Transfer of Information
7. Our Policies Regarding Children
Neither the Site, the Service nor any of Vegas Games’ Apps, are intended for children under the age of 13. We do not knowingly collect any PII from such children. Children under the age of 13 should not access or use the Site or our Service or any of our casino games or other Apps at any time. If we learn that we have unintentionally collected any PII from a child under the age of 13, we will take reasonable measures to rectify such situation, including the deletion of such information from our records.
8. Accessing and Updating Your Information
Information We Receive From an SNS
Please be aware that you can manage the information that Vegas Games receives about you from an SNS that you use to access the Service and participate in any of our casino games or other Apps. Please follow the directions at the SNS’s website regarding the management of your privacy settings and the updating or deletion of your information. To facilitate you becoming more familiar with the relevant privacy settings, the privacy management tools for Facebook can be found here, while the privacy management tools for Google+ can be found here. You may also manage certain aspects of the information collection and use practices by means of the settings that are offered by your particular mobile or non-mobile device service provider and adjusting the permissions specified for each application.
9. Options Regarding Sharing and Messaging
Please be aware that whenever you provide any information or other User-generated Content on a publicly available page or other public forum that is part of the Site, the Service, or any SNS or other Internet website(s), or by means of any of our Apps, such information and other content materials may be accessed, copied, collected, retained, shared, and otherwise exploited by other persons or entities. In addition, please remember that when you share information in your communications with any third parties, that information may be passed along or made public by such third parties and by others with whom such information or content materials are shared or otherwise distributed. This means that anyone with access to any such information or content materials, including any such information or content materials that you choose to submit, post, disclose, share, or otherwise provide in connection with the Site, the Service and/or any of our Apps, can potentially use it for any purpose, including, but not limited to, sending unsolicited communications.
Information We Receive from Third-Party SNS
If you access the Service and/or play any of our Apps through a third-party SNS, Vegas Games will be granted access and allowed to store information concerning you that is part of your account and/or profile with the relevant SNS. The form of information that will be shared with us depends, in part, on the scope of authorization that you grant us, as well as on the privacy settings that you choose to establish with the SNS that is used by you to access the Service and/or any of our Apps. Please be advised that we do not offer an "opt out" option with respect to the types of information shared with us by the SNS that you choose to use in order to access and use the Site, the Service and/or any of our Apps.
How to Opt Out of Promotional Communications
You can choose to opt-out of receiving any further promotional emails from Vegas Games by clicking on the "unsubscribe" link that appears at the bottom of any promotional email that you may receive from us or on our behalf. Please understand that, in light of the number of requests that we may receive from interested Users during any given timeframe, it may take up to ten (10) business days (after the date on which we receive any such request in writing) for your opt-out request to become effective.
How to Opt-Out of Other Vegas Games Communications
You can choose to opt-out of receiving SMS messages by replying to the number that was used to send you any SMS and texting “STOP”. For certain Apps, you may also be offered a preference management page, which may also be found under the "Help" menu of the App, and that offers Users the opportunity to use such SMS features and functionality. Please be advised that when we receive an opt-out message from you indicating that you no longer desire to receive SMS messages in connection with a particular App, we may send a message to you to confirm that we have received your opt-out request.
When you choose to install one of our Apps on your mobile or non-mobile device, you will be presented with an option as to whether you want (or do not want) to receive "push" notifications. By visiting the "options" or "settings" page, you will be able to turn off push notifications. You may also choose whether (or not) you would like to receive local notifications, and you can turn off local notifications by visiting the "options" or "settings" page within the affected App.
Please note that if you opt-out of our promotional messages or other communications, we may nevertheless email or otherwise communicate with you from time to time if you elect to establish an account that allows you to access and use the Site, the Service and/or any of our Apps. For example, if we need to provide you with any particular information, or in the event that we need to request any information from you regarding your activities or experiences when accessing and using the Site, the Service and/or any of our Apps), or regarding any transactions in which you choose to become involved, and/or for any other reason or purpose unrelated to direct marketing or commercial advertising.
10. International Safe Harbors
Personal information collected on our website(s) will be stored and processed in the United States. By using our website(s) you consent to any such transfer of information outside of your country. Vegas Games complies with the U.S.-E.U. Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Vegas Games has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. To learn more about the Safe Harbor program, and to view Vegas Games’ certification, please visit http://www.export.gov/safeHarbor/.
11. Third-Party Privacy Policies
12. Information Security
14. California Privacy Rights
Under California law, residents of the State of California who have an established business relationship with Vegas Games may choose to opt-out of the disclosure of his or her PII to third parties for direct marketing purposes. However, as noted above, our policy is not to share a User’s PII that is collected online or disclose such information to any third parties for direct marketing purposes without the User’s consent. This can be done by "opting in" to receive such marketing or advertising information from a third party at the time that the User chooses to participate in a particular marketing event or promotional activity through Vegas Games in connection with the Site, the Service, and/or any of our Apps (e.g., a sweepstakes or contest, etc.). Furthermore, should a User ask us to share his or her information in connection with the direct marketing purposes of any third party (or third parties), we will endeavor to make sure that we only share such information in connection with the direct marketing purposes and related promotional activities approved by the relevant User, as we do not have a policy of sharing information with any third party (other than our service providers) on an ongoing and recurring basis. Please do not opt-in if you want to avoid the disclosure of your PII to a third party for its direct marketing efforts. As importantly, if you would like to opt-out of the disclosure of your PII to any third party for its direct marketing efforts at any time after initially giving your approval, please contact us at email@example.com.
Right to Access
Under the applicable laws and regulations of certain jurisdictions, some of our Users have the right to access and review the PII about them that has been collected online and that is retained in our server networks and computer databases. If you would like to exercise your right to access and review your information, so that you may subsequently correct or request the deletion of any of such information, please submit a request for access in writing to firstname.lastname@example.org.
15. Contact Us
Should you have any questions, comments or concerns, please feel free to send us an email message (and please describe the matter that you’d like to discuss in reasonable detail) to email@example.com.
Vegas Games Inc. 850 Stanton Road Burlingame, CA 94010
Vegas Games is a licensee of the ESRB's Privacy Certified Program. If you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact the ESRB at http://www.esrb.org/privacy_wc_hotline.asp. Please note that the ESRB is not affiliated with Vegas Games and cannot help you with non-privacy-related issues.
ESRB Attn.: Privacy Certified Program 420 Lexington Avenue, Suite 2024 New York, NY 10170 firstname.lastname@example.org