LIVE PLAY MOBILE INC.
Last updated: 11/22/2021
References to the “App” mean the mobile software application developed, owned, and operated by us bearing the name “Live Play Bingo” and available for download on the iTunes and Google Play stores.
References to the “Services” mean, collectively, the Web site, App, and any and all features thereof.
References to “us,” “we,” “our,” and/or “Live Play Mobile,” mean Live Play Mobile, Inc., a Delaware corporation, including any and all trade names utilized thereby.
References to the “Web site” mean, collectively, the Web site bearing the URL www.liveplaymobile.com as well as any other site or social media page operated by us.
References to “you,” and/or “User,” mean a general user of the Web site and/or user of our Services.
Before or at the time of collecting personal information, Live Play Mobile will identify the purposes for which information is being collected.
Live Play Mobile will collect and use personal information solely with the objective of fulfilling those purposes specified by Live Play Mobile and for other compatible purposes, unless Live Play Mobile obtains the consent of the individual concerned or as required by law.
Live Play Mobile will only retain personal information as long as necessary for the fulfillment of those purposes.
Live Play Mobile will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
Live Play Mobile will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
Live Play Mobile will make readily available to customers information about Live Play Mobile’s policies and practices relating to the management of personal information.
Live Play Mobile is committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.
Agreement to be Bound
The Information We Collect
Live Play Mobile does not collect information about its users from third-party sources, such as public records or entities or private organizations.
We collect both personally identifiable information and non-personally identifiable information from you. Often, you choose what information to provide to us, but, sometimes, we may require certain information for you to use and for us to provide the Services. Specifically, we collect the following:
Registration, Purchase, and Provision of our Services. Users can utilize our Services as a guest, in which event no registration information is collected. However, should a User wish to register for our Services (either directly or via a social media plug-in), we collect your full name, email, and phone number. Where a User has utilized a plugin (e.g. Facebook) for creation of their Account, we also collect and display such User’s public profile photo.
The Information You Share. Our Services contain interactive features, such as public chat rooms, through which Users may share personal information about themselves, should they desire. The sharing of such information is not required or monitored by us. Be advised that whatever information you share will be public and may not be removeable. Use good sense when sharing such information.
Automated Information. Live Play Mobile uses web-based analytics to automatically receive and record information from each User’s browser or your mobile device when you use the Services, such as your IP address or unique device identifier, cookies and data about which pages you visit in order to allow us to operate and provide the Services, data about the type of device you use to connect to our Services, and information about the pages you visit before and after use our Services. This information is stored in log files and is collected automatically. We may combine this information from your browser or your mobile device with other information that we or our partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyze and understand how the Services work for our Users, and to provide advertising, including across your devices, and a more customized experience for all Users.
We may also automatically collect device-specific information when you access or use our Services. This information may include information such as the hardware model, operating system information, browser information, IP address, human readable hardware name, and device identifiers. This information is necessary to identify you and to determine the hardware requirements of Live Play Mobile’s Users.
Finally, we may also collect general demographic information, such as your gender, age, income, or occupation. Such information is anonymized and used to better improve your customer experience.
Use of Your Information
We may use your personally identifiable information to identify Users; to provide and improve customer service administration; to personalize your User experience; to respond to inquiries; to send company news, updates and other related information; to facilitate registration for and use of our Services; and to ensure legal compliance.
We may use your non-personally identifiable information to create traffic statistics for our Services; to create User statistics for our Services; and to improve customer service.
Your Rights & Preferences
Live Play Mobile gives you the choice of providing, editing, or removing certain information, as well as choices about how we contact you. Note that you may not be able to access all functionality of the Services should you choose to decline to provide some personal information.
You may change or correct your Live Play Mobile information via your Account or by emailing us at firstname.lastname@example.org.
You can also request the deletion of the personal information via your Account or by emailing us at email@example.com.
Furthermore, should you not wish for us to reach decisions affecting you using automated profiling or processing, you may decline such participation by emailing us at firstname.lastname@example.org.
Depending on your location, you may also have certain additional rights with respect to your information, such as: (i) data access and portability if we are processing your data for reasons of consent or to fulfill a contract (including the right to obtain a copy of your personal data you provided to Live Play Mobile, via your settings); (ii) data correction (including the ability to update your personal data, in many cases via settings); (iii) data deletion if we are processing your data for reasons of consent or legitimate interest (including the right to have Live Play Mobile delete your personal information, except information we are required to retain, by contacting us); and (iv) withdrawal of consent or objection to processing (including, in limited circumstances, the right to ask Live Play Mobile to stop processing your personal data, with some exceptions, by contacting us).
You may also control the receipt of certain types of communications from Live Play Mobile. Live Play Mobile may send you messages about the Services or your activity. Some of these messages are required, service-related messages for Users (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive via the unsubscribe link in our emails.
If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your Account.
Sharing Information with Third Parties
Although Live Play Mobile does not directly sell, rent, lease, trade, or otherwise give away its customer lists to third parties, it does share its Users’ data with third parties who may sell, rent, lease, trade, or otherwise give away such data, unless restricted by law. Live Play Mobile may share your data only with those third parties who may be necessary to provide the Services and/or for legitimate business purposes and process your data and with other Users with whom you connect via the Services. We utilize the following third-party services to provide the Services, which are subject to change at any time:
Facebook for the purpose of login accessibility
Microsoft for the purpose of player account registration and storage and various game services, such as push notifications, analytics, CRM, etc.
Amazon AWS for the purpose of hosting and data warehousing
Microsoft Playfab for the purpose of cloud service hosting
Leanplum for the purpose of delivery of our marketing and customer messages
Agora for video streaming purposes
Disclosure of Information
Performance Tracking; Advertising
The Services may use activity and performance tracking, bug reporting, and personalized advertising to help you personalize your online experience and improve our Services. These are small pieces of code placed in our Services to monitor the behavior and collect data about Users. For example, web beacons may be used to count the users who visit a Web page.
We use the following advertising networks in order to be able to integrate advertising within Services. In addition, should you make in-app purchases, your data may be shared with our advertisers for legitimate business purposes. The sharing of such data is pursuant to a data processing agreement, if applicable. This may include your email address, IP address, device id, and/or google ad id. We may also share anonymized IDFA and IDFV identifiers. Our current advertising partners include:
Kochava, which measures our mobile platform and provides attribution of mobile ad campaigns
Blkbox, which is a media buying agency that interfaces with our analytics providers
Facebook SDK, which we use for advertising purposes
Google Firebase SDK, which we use for advertising and analytics purposes
AppLovin, which we use for advertising purposes
Unity, which we use for advertising and analytics purposes
TapJoy, which we use for advertising and analytics purposes
Singlular, which we use for attributing marketing spend for advertising campaigns
You can object to the use of personalized advertising by making the following settings depending on your device type: On iPhone or iPad, first open “Settings,” tap on “Privacy,” and open “Advertising.” Here you can enable “Limit Ad Tracking.” If you use devices with Android and Google Play Services, first open “Google Settings,” tap on “Advertising,” then open “Disable interest-related ads,” then tap on “OK.”
Use of the aforementioned advertising networks and the transmission of the data mentioned is based on our legitimate interest in recouping our investments for operation of our Services through advertising and the fact that your justified interests are not overriding.
Security of your Personal Information
Live Play Mobile secures your personal information from unauthorized access, use, or disclosure by restricting the same using secure sockets layer (“SSL”) and other encryption methods. We further restrict access to all personally identifiable information by user role.
We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed. Please note that non-encrypted communication using email is not secure. Thus, we cannot guarantee data security in email communication and, therefore, recommend using physical mail for confidential information.
We offer a US-based service. Thus, your information will likely be transferred to and processed via servers located in the United States. Canada, the United States, the European Economic Area (“EEA”) Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live.
Children Under Thirteen; Notice to Minors
These Services are not aimed at nor intended for children under the age of 13. If you are under the age of 13, please do not use the Services, and if you are over the age of 13 but under the age of 18, you should use the Services only with the permission and/or supervision of a parent or legal guardian. Our Services do not accept registration from children under the age of 13. No personal information is purposefully or knowingly collected from children under the age of 13 by Live Play Mobile. Parents are put on notice that as a result of the foregoing, Live Play Mobile does not provide a mechanism to obtain parental consent.
If you are a parent or guardian who has discovered that your child has submitted his or her personal information to Live Play Mobile, Live Play Mobile will make commercially reasonable efforts to delete the information from its database, at your request. To request the deletion of your child’s information, please send an email to email@example.com and be sure to include in your message the same member name and password that your child submitted. Your use of the Services indicates that you hereby represent and warrant that all information you provide, including but not limited to age, shall be truthful and correct.
Do Not Track Disclosure
Live Play Mobile will retain your information only for as long as is necessary for the purposes set out in this policy, or as needed to provide the Services to you. If you no longer want Live Play Mobile to use your information to provide the Services to you, you may cease use of the Services by deactivating your account or by emailing us at firstname.lastname@example.org. Live Play Mobile will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.
E-mail Communications; How to Opt-Out
It is Live Play Mobile’s policy not to send unsolicited emails or allow third parties to contact you via the email address that you provide to Live Play Mobile except for as may be intended by the Services.
Live Play Mobile may, from time to time, contact you to discuss business relevant to your use of the Services and, naturally, Live Play Mobile will contact you to respond to inquiries that you may send to Live Play Mobile.
In addition, from time to time, Live Play Mobile may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication.
Please note that or marketing and promotional communications are opt-in. If you have opted-in but would like to stop receiving marketing or promotional communications via email from Live Play Mobile, you may opt out of such communications by clicking on the UNSUBSCRIBE link contained in each email.
Email marketing campaigns published by us may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include but shall not be limited to: the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates, and frequency of activity. This information is used to refine future email campaigns and supply the User with more relevant content based around their activity.
You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal information, you can do so by contacting us. Upon request, Live Play Mobile will provide you with information about whether we hold any of your personal information. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format. If you need further assistance, you can contact Live Play Mobile through one of the channels listed below under “Contact Information.” We will respond to your request within a reasonable timeframe.
If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications.
Where you have provided your consent, you have the right to withdraw your consent to our processing of your information. For example, you can withdraw your consent to email marketing by using the unsubscribe link in such communications. You can email email@example.com at any time to request that your personal information be deleted, except for information that we are required to retain. This deletion is permanent.
Address: Live Play Mobile, Inc. 2140 S. Dupont Highway, Camden, Delaware 19934
Phone: +1 415-800-1461
Email Address: firstname.lastname@example.org
Special Notice to California Resident
Information We Collect
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular User or device (” personal information”). In particular, our website has collected the following categories of personal information from its Users within the last twelve (12) months:
Category A: Identifiers
Examples: A real name, Internet Protocol address, email address, or other similar identifiers.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: YES. Should a User elect to register for our Services, Live Play Mobile collects Users’ name, email, and phone number. Furthermore, should a User utilize Facebook to access or Services or otherwise provide a profile picture, Live Play Mobile will collect such User’s physical characteristics.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Personal information does not include:
Publicly available information from government records.
De-identified or aggregated User information.
Information excluded from the CCPA’s scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
Directly from you. For example, from forms you complete to utilize or register for our Services.
Indirectly from you. For example, from observing your actions on our Web site or interactions with our advertisers or others.
Use of Personal Information
We may use, or disclose the personal information we collect for one or more of the following business purposes:
To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase a product or Service, we will use that information to process your payment and facilitate delivery of such Service.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract, unless otherwise agreed. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Live Play Mobile has disclosed personal information for a business purpose.
Sales of Personal Information
In the preceding twelve (12) months, Live Play Mobile had not sold personal information; however, Live Play Mobile has provided User information to third parties, who may sell such information.
Your Rights and Choices
The CCPA provides Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable request, we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
sales, identifying the personal information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another User to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with User expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable User request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable User request related to your personal information. You may also make a verifiable User request on behalf of your minor child.
You may only make a verifiable User request for access or data portability twice within a twelve- (12)-month period. The verifiable User request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable User request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable User request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve- (12-) month period preceding the verifiable User request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.
We do not charge a fee to process or respond to your verifiable User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are sixteen (16) years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of User we actually know are less than sixteen (16) years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the User who is between thirteen (13) and sixteen (16) years of age, or the parent or guardian of a User less than thirteen (13) years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Deny you goods or services except whereas necessary for local, state, or federal compliance.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website 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 us an electronic message through our website or write us at our address listed on our webpage.
To make any such a request, please contact us through one of the channels listed below under “Contact Information.”