PRIVACY POLICY

PRIVACY POLICY

Girlsgogames.com privacy policy

Date last updated: 16/09/2020

 

This Privacy Policy applies to our website www.girlsgogames.com (“Website”), owned and operated by Azerion. 

 

Azerion is dedicated to protecting the privacy of our users and handling any data we obtain from our users with care and respect. An overall principle is that we do not collect more information than is reasonably necessary to provide our users with the best user experience. As the Website is meant for children, we do not collect any personally identifiable information about our users through the Website, except as set forth in this Privacy Policy. We also do not use cookies or other technologies to track the users of our Website, and we do not engage in targeted advertising to users of the Website.

 

Azerion may use affiliates’ or reputable third parties’ services for the processing of personal data collected on or through the Website.

 

1. ABOUT THIS PRIVACY POLICY

1.1. This privacy policy (“Privacy Policy”) explains how information about our users is collected, used, and disclosed by Azerion when a user visits our Website. The Privacy Policy applies in addition to our terms of use and other policies. In the case of a contradiction between the Terms of Use and this Privacy Policy, this Privacy Policy will prevail. This Privacy Policy differs from our other Privacy Policies.

 

2. ABOUT US

2.1. Azerion is the data controller as referred to in the General Data Protection Regulation (“GDPR”). Azerion based at Beechavenue 182 1119 PX, Schiphol-Rijk, The Netherlands.

 

2.2 Our Website offers a diverse, and exciting mix of online games as well as games created by independent developers and others with whom we do business. Users can access our Website to play games without registering. Certain games on our Website are controlled by third parties, including third parties located outside of the European Economic Area (“EEA”). Our own hosting facility for the Website is located within the EEA. We use commercially reasonable efforts to ensure that no personal data of children is being processed via our Website. Privacy safeguards we take are contractual safeguards with third parties and the employment of technical privacy solutions, such as monitoring and blocking tools. However, as we do not control all games, data may be collected and transferred of which we are not aware. If we become aware of any third party violating our agreement with them by collecting personal data of children without verifiable parental consent, we will take appropriate action to terminate our relationship with such third party or otherwise take corrective measures.

 

3. WHAT INFORMATION DOES AZERION COLLECT?

3.1. Azerion collects certain information when a user visits our Website (“User Information”). The User Information we collect is:

 

Unique personal identifier (UPI)

IP address

Geolocation (on a country level)

We do not collect any additional information from or about the users of our Website.

 

4. WHAT IS THE PURPOSE FOR THE INFORMATION WE COLLECT?

 

 

Data Collected

 


Purpose(s)

 

Unique personal identifier

 


To identify user’s behavior for analytics, such as retention, gameplays, time spent on our Website, and other anonymous metrics that are used only for support for the internal operations of the Website

 

 

IP address

 


To identify the country in which the user is located while using the Website, which data is used only for support of the internal operations of the Website

 

 

Geolocation data to identify country only

 

 

To identify the country in which the user is located while using the Website, which data is used only for support of the internal operations of the Website

 

 

           

           

           

5. HOW DO WE USE THE USER INFORMATION?

5.1. We will NOT knowingly collect, use or distribute personal information from children under the age of 16 without prior verifiable consent from a parent or guardian. We use the User Information only for the support of the internal operations of the Website, such as activities necessary for the Website to maintain or analyze its functioning; perform network communications; authenticate users or personalize content; serve contextual advertising or cap the frequency of advertising; protect the security or integrity of the user, Website, or online service; ensure legal or regulatory compliance. No other personal information is collected and the User Information is not used or disclosed to contact a specific individual, including through behavioral advertising; to amass a profile on a specific individual; or for any other purpose not specified in this Privacy Policy.

 

We may also use User Information:

 

To prevent fraud and crime;

To meet legal and tax obligations; and/or

To protect our valid legal interests or the legal interests of others.

5.2. This Website is hosted within the EEA, and the User Information will be stored by Azerion in the EEA. To the extent that any User Information is processed by anyone outside of the EEA, we have taken such measures as are reasonably necessary to ensure an adequate level of protection for the User Information in accordance with the requirements of applicable data protection legislation, including but not limited to contractual safeguards.

 

5.3. The User Information will only be stored for a period necessary for the use of the Website for the purposes as described in this Privacy Policy. We will, for example, periodically delete User Information, and we regularly review and anonymize unnecessary data.

 

6. WHICH THIRD PARTIES HAVE ACCESS TO USER INFORMATION?

 

The Website works with the following third party service providers.

 

 

Third Party

 

 

Usage

 

Privacy Policy

Google Analytics

Analytics

Link

Google Cloud

Cloud Service

Link

Zendesk

Customer Support

Link

 

 

6.1. Analytics

 

The Website uses third-party analytics companies (Google Analytics) in order to help get insights into the usage of the Website (“Usage Data”). These analytics companies process Usage Data, which may include, among others, User Information. This data is used to analyze the use of the Website and to improve the Website and related services. These analytics companies will act as a data processor in relation to the Usage Data. The legal basis for the processing of the Usage Data is legitimate interest.

 

6.2. Customer Support

 

This Website uses third party service providers (Zendesk) in order to offer our users customer support services. We may share User Information with these service providers. The legal basis for the processing of the User Information is legitimate interest or consent depending on the service provided.

 

6.3. Cloud Service

 

This Website uses third party service providers (Google Cloud) in order to host the servers and website to provide the service. These cloud service providers will act as a data processor in relation to the data usage. the legal basis for the processing of the User information is legitimate interest.

 

 

7. PARENTS RIGHTS

 

We do not actively collect any information from your child when using the Website. If you would like to know more about the information we collect from the use of our website (as described in Section 3 ), review the information or request to have it deleted please contact us: dpo@azerion.com

 

 

7. YOUR RIGHTS

7.1. Your User Information may be stored by Azerion and our service providers. In case the applicable data protection laws provide so, a user has the right to access, rectify, and erase the User Information we hold about the user and to restrict or object to our processing of the User Information.

 

7.2. If a user wishes to exercise these rights, the user can do so by sending a written request to Beechavenue 182 1119 PX, Schiphol-Rijk, The Netherlands, detailing the request, (to prevent misuse of requests for information), or sending an email containing the request to: dpo@azerion.com

 

7.3. As we do not collect email or street addresses, we will not send any marketing communications to our users by email or otherwise.

 

7.4. This Website does not knowingly process personal data from anyone under the age of 16 without verifiable parental consent, unless the applicable law allows Azerion to do so. In the event we find out that we have processed personal data of anyone under the age of 16 without parental consent and/or without a legal basis to do so, we will promptly delete such data.

 

7.5 In the event there are any questions or concerns in relation to the processing of User Information, please send an email to our Data Protection Officer by email at dpo@azerion.com. If you are an EU subject, and you are not satisfied with our responses and/or support to resolve your concerns, you have the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) Member State where you work, normally live, or where any alleged infringement of data protection laws occurred.

 

8. SECURITY

8.1. Azerion has implemented appropriate measures to safeguard and help prevent unauthorized access, to maintain data security, and to correctly use the information we collect in relation to the Website.

 

8.2. Although we take reasonable and appropriate measures to protect the security of User Information, please be aware that no security measures are perfect or impenetrable. We are not responsible for the circumvention of any privacy settings or security measures.

 

9. NOTICE TO CALIFORNIA RESIDENTS – THIS SECTION IS ONLY APPLICABLE TO YOU IF YOU ARE A RESIDENT OF CALIFORNIA.

9.1 We do not share any User Information with third parties for direct marketing purposes. In addition, please note the following:

 

·         Users can visit the Website anonymously;

·         We will add a link to this Privacy Policy on our home page, or at a minimum, on the first significant page after entering the Website;

·         Our Privacy Policy link includes the word “Privacy” and can easily be found on the page specified above;

·         Users will be notified of any privacy policy changes on our Privacy Policy page;

·         We do not track our users across the Internet or deliver targeted advertising;

·         We do not allow the collection of personal information by third parties through our Website.

9.2. Information We Collect From California Consumers

 

 

Category

Examples

Collected

Identifiers

Unique personal identifier, Internet Protocol (IP) address

YES

B. Personal Information described in the California Customer Records statute (Cal.Civ.Code §1798.80(e))

Unique personal identifier, Internet Protocol (IP) address:

YES

C. Legally Protected Characteristics

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)

NO

D. Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

NO

E. Biometric information

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or similar network activity

Browsing history (information regarding the page the consumer visited prior to coming to our website); , information regarding a consumer's interaction with a website, mobile application, or online advertisement; device type, brand, and platform; timestamp; whether consumer is a registered user or guest; game and page views

YES

G. Geolocation data

Physical location or movements

YES – on a country basis only

H. Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information

NO

I. Employment information

Professional or employment-related information

NO

J. Education information, defined as nonpublic personally identifiable information under the Family Educational Rights and Privacy Act (FERPA) (20 U.S.C. § 1232g and 34 C.F.R. Part 99)

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records

NO

K. Inferences drawn of other categories of Personal Information

A profiles created about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

NO

 9.3. Personal information does not include:

 

·         Publicly available information that is lawfully made from federal, state, or local government records

·         Deidentified or aggregated consumer information

·         Medical information or protected health information governed by California and federal health information privacy laws

·         Clinical trial information subject to the Federal Policy for the Protection of Human Subjects (the Common Rule)

·         Personal information regulated by the Fair Credit Reporting Act (FCRA)

9.4. We obtain the categories of Personal Information listed above from the following categories of sources:

 

·         Indirectly from activity on our Site. For example, from website usage details collected automatically

9.5. Use of User Information

 

We may use or disclose the User Information we collect for one or more of the following internal business purposes:

 

·         To improve our Website and present its contents to our users

·         For internal testing, research, analysis and product development

·         To aggregate anonymous analytics about the usage of our Website and portals

·         As necessary or appropriate to protect the rights, property or safety of us, our customers, or others

·         To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

·         To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the User Information held by us is among the assets transferred

We will not collect additional categories of personal information or use the User Information we collected for materially different, unrelated, or incompatible purposes.

 

9.6. Sharing Personal Information

 

We may disclose your User Information to a third party for internal business purposes. When we disclose User Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that User Information confidential and not use it for any purpose except performing the contract on our behalf.

 

In the preceding twelve (12) months, we have disclosed the following categories of User Information for an internal business purpose:

 

·         Category A: Identifiers.

·         Category B: California Customer Records personal information categories.

·         Category F: Internet data.

·         Category G: Geolocation data.

We disclose User Information for an internal business purpose to the following categories of third parties:

 

·         Our affiliates.

·         Service providers.

In the preceding twelve (12) months, we have not sold any User Information.

 

9.7. Under California Civil Code Section 1789.3, residents of California who use this Website are entitled to know that they may file grievances and complaints with: the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs, in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210, or by email at dca@dca.ca.gov.

 

10. MISCELLANEOUS

10.1. We reserve the right to amend our Privacy Policy. Amendments will be effective from the moment of publication, so please check regularly to be sure you are familiar with the latest version. We will include the date of the last amendment of this Privacy Policy at the beginning and end of this Privacy Policy.

 

10.2 We may freely assign this Privacy Policy or any of our rights and/or obligations hereunder to any successor.

 

10.3 We may disclose User Information and/or any of our users’ personal information (if we are aware of the same) pursuant to judicial and administrative proceedings and to law enforcement or government agencies if we reasonably believe the disclosure is necessary or appropriate to protect our legal interests or the legal interests of another. We may also disclose such information if we believe the disclosure is necessary or appropriate in the event of an investigation of improper or illegal conduct in connection with the Website, such as fraud, misrepresentation, intellectual property infringement, or other activity that may put us at risk for liability.

 

10.4 If you have any additional general questions or requests about our Website, you may send an email to dpo@azerion.com or call +184 34838199 In the event you have any questions or concerns in relation to the collection or processing of User Information, please send an e-mail to dpo@azerion.com

 

Date last updated: Sep 16, 2020