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PRIVACY POLICY

 

This Privacy Policy governs the manner in which Vireo Development, LLC (“Company,” “we,” “us,” or “our”) collects, uses, maintains and discloses information collected from users (each, a "User") of our website, applications, products, and other services (collectively, the "Services"). Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us. This privacy policy applies to all Services offered by Vireo Development, LLC. By using our Services, you consent to the practices in this Privacy Policy. This Privacy Policy applies to our websites and applications (our “Platform”).

This Privacy Policy may change over time. When we change our Privacy Policy, we will give you notice either through our website (including by updating the “as of” date of the Privacy Policy), or e-communication as we believe necessary. We encourage you to review this statement periodically.

 

1. WHAT INFORMATION DO WE COLLECT?

Personal Information

For the purpose of servicing your account and communications via email or through our Platform, we may collect information that could identify you (“Personal Information”). Personal Identifiable Information means information that would allow us to determine the actual identity of, or contact, a specific living person. We may collect your Personal Information when you or a third party, to whom you gave permission, give it to us. By providing any information to us, you consent to the collection, use, and disclosure of it as permitted by applicable law. Personal Information we collect may include, but is not limited to, your:

  • Name

  • E-mail address

  • Mobile device ID

 

You may choose not to provide us with Personal Information. However, Personal Information may be required to use our Services. If you do not provide the mandatory information with respect to a particular Service, you will not be able to use or fully use our Services.

 

Children

We do not knowingly target or collect Personal Information from persons under the age of thirteen.

 

Non-Personal Information

We may also collect information that does not identify you (“Non-Personal Information”). Examples of Non-Personal Information we collect may include your:

 

  • Usage on our websites or apps

  • Information posted or collected as a result of a user’s use (including your use) of our Services

  • Zip code by itself, and other demographic data

  • IP address

  • Browser type

  • Information gathered from or about your device (except your mobile device ID)

 

 

2. HOW DO WE COLLECT YOUR INFORMATION?

We collect and store any information you enter on our Platform or provide to us in some other manner.

We also collect information using software or other technologies. To collect information automatically, we may use cookies, web beacons, our own data-collection tools or various third-party services.

  • Google OAuth to obtain permission to store player profile and gameplay data on Microsoft's playfab.com servers

  • Cookies and Use of Cookie Data: When you use our Platform, we may assign your device one or more cookies, to facilitate access to our site and to personalize your online experience. Through the use of a cookie, we may collect information about your activity on our Platform.

  • Other Technologies: We may use standard Internet technology, such as web beacons and other similar technologies, to track your use of our Platform. We also may include web beacons in advertisements or email messages to determine whether messages have been opened.

  • You may learn more about internet tracking technologies on the Federal Trade Commission’s website at https://www.consumer.ftc.gov/articles/0042-online-tracking.

  • When we collect information, we may associate it with a unique ID and a unique device ID when you use our Services.
     


We may obtain your Personal Information from third-party sources when you have granted permission to a third party to share your information. We may also obtain your Non-Personal Information from third-party sources as they collect your Non-Personal Information according to their privacy policies. We encourage you to read the privacy statements of third parties to know what Personal Information and Non-Personal Information you are sharing from other sources.

 

3. HOW DO WE USE YOUR INFORMATION?  

Unless otherwise stated in this Privacy Policy, we may use your Personal and Non-Personal Information for any purpose we deem reasonably necessary to operate our Services or to the extent allowed by applicable law.

 

Examples of how we use your information include, but are not limited to:

  • Operating, improving, debugging, and maintaining our Services and Platform;

  • Developing new services and product offerings;

  • Provide targeted advertising on our Platform or on third party websites or apps;

  • Studying and personalizing user experiences;

  • Fulfilling legal requirements;

  • Conducting business analysis and research, and marketing campaigns; and

  • For security and fraud protection.

We may also use your information to send personalized communications regarding updates, upgrades, enhancements, surveys, recommendations and/or advertisements from us and our affiliates.

 

Sharing Personal Information

We will not share your Personal Information with a third party without your consent, unless:

  • Required by law (for example, a court order, subpoena, or law enforcement investigation);

  • We are involved in a merger, sale, acquisition, or other change of ownership;

  • We use a third-party vendor to operate and maintain our Platform, provide our Services or carry out other business purposes and the vendor agrees to keep your Personal Information confidential and only use it for the purposes for which the vendor was engaged; and

  • If we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

 

 Sharing Non-Personal Information

We may share Non-Personal Information with third parties to the extent allowed by law. Some examples of how we may share your Non-Personal Information are:

  • Sharing with government bodies and law enforcement agencies, for example in judicial proceedings, by court order or other legal process.

  • To enforce or defend our legal rights, including our terms and conditions, and investigate violations thereof.

  • In connection with a corporate event such as a merger, business acquisition or insolvency situation.

  • For marketing, analytical purposes or research.

 

Sharing Non-Human Readable Data.

We may use and share Personal Information and Non-Personal Information in hashed, non-human readable form, including to develop and deliver targeted advertising on our Platform and to analyze and report on advertising you see. We may combine this information with additional Personal Information or Non-Personal Information in hashed, non-human readable form collected from other sources.
 

4. HOW DO WE STORE YOUR INFORMATION?  

How Long We Store Your Information.

We may keep your Personal Information as long as we need it for legitimate business purposes, unless:

  • We keep it to comply with applicable law;

  • We keep it to evidence our compliance with applicable law;

  • There is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

  • The information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security.

We do not promise that any or all information will be deleted within a specific timeframe.

 

How We Protect Your Information.

We take what we believe are appropriate security measures to protect your Personal Information. No security system, however, is completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your Personal Information or communications will always remain secure. You should handle and disclose your Personal Information with care. You may learn more on how to protect your personal data on the Federal Trade Commission’s website located at https://www.ftc.gov/bcp/menus/consumer/data.shtm. Our commitment to your privacy does not extend to third-party products and services you may access from our Platform.

 

5. CALIFORNIA RESIDENTS

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclose to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.  If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

 

6. THIRD-PARTY WEBSITES

This Privacy Policy does not cover third-party apps, websites and services you access and use through our Platform. We do not control the privacy and security practices and policies of these third parties and their sites. We encourage you to read the privacy statements of the third-party apps and websites you use.

 

7. USING OUR PLATFORM FROM OUTSIDE THE UNITED STATES

If you are using our Platform from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States. By using our Platform, you understand and agree that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy, and you agree that you have come to the United States to do business while you are using our Platform.

 

8. YOUR RIGHTS AND CHOICES

You may choose not to provide your information, but some Services may require it to function properly. You may also control the information collected by internet cookies. To opt-out of cookies that may be set by third-party data partners or third-party advertising partners, please go to https://www.aboutads.info/choices/.

 

9. CONTACT INFORMATION

If you have questions or comments about this policy or our Platform, you may contact us by e‑mail at info@vireodev.com.

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