TRANSGAMING INTERACTIVE LTD./GAMETREE TV PRIVACY POLICY

Committed to Protecting your Privacy

TransGaming Interactive Ltd., its related and parent companies, subsidiaries and affiliates (collectively, “TransGaming”) recognize the sensitive nature of personal information. TransGaming adheres to rules governing the protection of confidential information and complies with the principles of The Personal Information Protection and Electronic Documents Act (“PIPEDA”), the National Standard for the Protection of Personal Information (CAN/CSA-Q830-96) and data protection rules of other countries where applicable to its processing. This Privacy Policy governs TransGaming’s collection, use and disclosure of “Personal Information” (as defined below) in the course of our commercial activities.

WHAT DOES PROTECTION OF YOUR PRIVACY MEAN?

  • The collection, use, and disclosure of your personal information will be done in a manner that recognizes your privacy rights
  • You have the right to access the information we have about you
  • Our staff is familiar with this Privacy Policy and they understand the importance of abiding by the policies and procedures set out in this Privacy Policy

We have developed this Privacy Policy to outline our commitment to maintain your privacy when we collect, use and disclose Personal Information.

Scope and Purpose: This Policy applies to the collection, use and disclosure of Personal Information acquired by TransGaming, for example when you use the GameTreeTV service (the “Service”), are on the TransGaming site or when you use other TransGaming services and software. The TransGaming site may contain links to other third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your Personal Information. Please check these policies before you submit any personal information to such third party websites.

By submitting your Personal Information to TransGaming you agree and consent to the processing, uses and disclosures set out in this Privacy Policy. Further notices highlighting certain uses we wish to make of your Personal Information together with the ability to opt in or out of selected uses may also be provided to you when we collect Personal Information from you.

Definition of “Personal Information”: “Personal Information” is information about an identifiable individual.

When We Collect: We collect information at various times, including when:

  • When you access the Service
  • You register for an account or sign up at one of our websites
  • When you use certain other TransGaming products or services, and when you enter promotions or sweepstakes
  • When you access online features and/or services in the Service or otherwise provided by Transgaming
  • When you download and/or upload content
  • When you activate updates
  • TransGaming may also receive Personal Information from our business partners
  • When you make payment through one of our third party payment processors (“Third Party Payment Processor”) through one of our applications and/or services.

Type of Information Collected: By using TransGaming products or services you are deemed to have expressly consented to the collection of the information set out below:

  • When you register with TransGaming, we may ask for your name, email address, postal address including country, phone and fax number (once you register with TransGaming and sign in to our services, you are not anonymous to us)
  • Additional surveys and forms may request more information and the purposes for which such information will be collected and used will be identified (for example, to contact you in relation to TransGaming products or services)
  • We may collect your user-name, user-profile and Game ID
  • If you so elect and consent, we may store the payment information you provide to our Third Party Payment Processor in order to expedite payment on future transactions
  • We will collect technical and related information that identifies your computer, such as an internet protocol address and serial key
  • We will collect hardware information, information concerning your operating system, application software and peripheral hardware such as MAC model, CPU model and speed, RAM size, VRAM size and graphics card model and vendor ID
  • TransGaming also automatically receives and records information on our server logs from your browser including, but not limited to your browser version, your IP address and domain name, TransGaming cookie information, download tracking and the page you requested (TransGaming may set and access cookies on your computer. TransGaming uses web beacons to access our cookies inside and outside our network of web sites and in connection with TransGaming products and services.); TransGaming uses this traffic data to help diagnose problems with its servers, analyse trends and administer the website.

Cookies and other tracking technologies: The TransGaming site and/or third parties (including the Third Party Advertising Providers, as defined below) may use “cookies” (which are small data files containing information about your use of a site that are stored on your hard drive), “web beacons” (also known as image tags, GIF or web bugs) and other similar tracking technologies which allow information as to whether an email has been opened, as part of a Service or site has been accessed by your device, to ensure that compatible advertising formats are delivered to your device, or for general reporting purposes (collectively, “Tracking Technologies”) to collect information automatically as you use the Service, browse the TransGaming site and the web, or access or use other products or services provided by Transgaming.

We and Third Party Advertising Providers use Tracking Technologies to collect “click stream” data and additional information regarding your use of the games and other usage of the Service, visits to the TransGaming site, use of our features, and purchasing history or preferences and may also collect your IP address or some other identifier unique to the device you use to access the Service and/or Transgaming site (“Identifier”). Your Identifier is automatically assigned to the device you use to access the Service and/or Transgaming site. The information collected through Tracking Technologies is used to better customise your experience and provide tailored advertisements and promotions relating to your specific interests.

The Service, TransGaming sites and other unrelated third party websites may additionally use a variety of third party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties (collectively, “Third Party Advertising Service Providers”) to serve advertisements on the TransGaming site or Service, facilitate targeting of advertisements and/or measure and analyse advertising effectiveness and/or traffic on the TransGaming site (“Targeting Services”), and in particular, to direct advertising content to you via the Service. These Third Party Advertising Service Providers may enable us to display advertisements based on your use of the Service and your visits to the TransGaming site and other websites you have visited. Targeting Services enable us to, among other things, help deliver advertisements or other content to you for products and services that you might be interested in, to prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you.

Although these Third Party Advertising Service Providers do not have access to Tracking Technologies set by the TransGaming Service and/or site, the Third Party Advertising Service Providers, as well as advertisers, may themselves set and access their own Tracking Technologies on your device if you choose to have Tracking Technologies enabled and/or they may otherwise have access to other information about you.

By using the Service and/or TransGaming site, you will be deemed to consent to the use of the Tracking Technologies described above. However, you may opt out of the use of such Tracking Technologies as set out below:

  • With respect to the Tracking Technologies set by Third Party Advertising Service Providers, advertisers and us, you have a number of options to disable such Tracking Technologies:
    • In connection only with the TransGaming site, you can choose to delete the Tracking Technologies through the “Internet Options” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature.
    • In connection with the TransGaming site or Service, and only if made possible by such device manufacturer, you can choose to have the device you use to access the sites warn you each time a cookie, image tag or other Tracking Technology is being sent, or you can choose to turn off such warnings. This is done through your browser on the device you use to access the sites, or through the Options menu available on the Service.
  • With respect to the Tracking Technologies set by Third Party Advertising Service Providers and Advertisers, you may opt out of such Third Party Advertising Service Providers Tracking Technologies by sending an inquiry to privacy@transgaming.com.

Opting-out of, deleting or disabling Third Party Advertising Service Providers’ Tracking Technologies does not mean that you will no longer receive online or embedded ads. Opting-out, deleting or disabling Third Party Advertising Service Providers’ Tracking Technologies only means that such ads will no longer be tailored to your specific viewing habits or interests, but you will continue to see ads on these sites or within the games accessed by you through the Service.

Further, if you delete or disable Tracking Technologies, you may not have access to certain features of the Service or the TransGaming site and some of our other services may not function properly.

Personal Information may be used:

  • To customize the advertising and content you see on the Service or on our pages to ensure that it is presented in the most effective manner for you and your device(s)
  • To fulfill your requests for certain products and services
  • To improve products and services, to conduct research and to provide software updates and any dynamically served content, product support and other services to customers, including marketing and online play and to allow you to participate in interactive features of our service, when you choose to do so
  • For service announcements or administrative messages relating to the Service and other TransGaming products and services
  • To facilitate technical protection measures
  • To assess our clients ongoing needs and offer products and services to meet those needs
  • For billing, collection and accounting services relating to our products and services
  • To meet communication, service and administration needs, in particular to monitor calls and transactions to ensure service quality, compliance with procedures and to combat fraud
  • For internal, external and regulatory audit purposes
  • To identify customer preferences
  • In relation to contests, promotions, and surveys
  • To protect you, our other customers and TransGaming
  • To notify you about any changes to our service
  • To comply with legal requirements.

For statistical purposes we may collect, summarize and use customer information in a format that does not identify the individual. This anonymous aggregate data may be shared with our third party providers and business partners.

We may also use your information for marketing our own and selected third parties’ products and services to you by post, email, SMS, phone and fax and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.

We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you. Disclosure: TransGaming will not sell or rent your Personal Information to anyone.

We may permit selected third parties and agents to use your personal information for the purposes set out above who will be subject to obligations to process such information in compliance with the same safeguards that we deploy and within the terms of this Privacy Policy.
We may also disclose your personal information to third parties in the following circumstances:

  • In the event that TransGaming (or a part thereof) is sold to a third party or undergoes a re-organisation, your personal information may be transferred to that re-organised entity or third party and used for the same purposes.
  • For the purpose of collecting a debt owed by you to TransGaming
  • In connection with proceedings or investigations in relation to the enforcement of a law, compliance with subpoenas, warrants, court orders or procedural rules or in relation to national security and/or defence
  • If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We can provide the names and addresses of the agencies we use if you would like a copy of your information held by them. Please contact us at the address below. The agencies may charge a fee.

Limiting the Use, Retention, and Disclosure of Personal Information: TransGaming will only use or disclose Personal Information for the purpose for which it was collected and in accordance with this Privacy Policy, unless the individual consents, or if the use or disclosure is authorized by PIPEDA or another legal authority. We will only keep your Personal Information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law. Certain transaction details and correspondence may be retained until the time limit for claims in respect of the transaction has expired.

Your personal information may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the United Kingdom or the European Economic Area in which data protection laws may be of a lower standard than in those countries. Regardless of location or whether the person is an employee or a third party we will impose the same data protection safeguards that we deploy inside the United Kingdom.

Security of Personal Information: No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Personal Information in accordance with PIPEDA and/or other applicable data protection legislative requirements.

Our soft copy data storage will be protected by the appropriate technological measures (e.g. passwords and encryption) and any hard copies of Personal Information will be kept in locked filing cabinets or kept in offices with restricted access. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the TransGaming site, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

Individual Access to Information: You have the right to access, verify and update your Account Information and preferences at any time, including whether you want TransGaming to contact you about specials and new products. You may request deletion of your TransGaming account by contacting the Privacy Officer at the address set out below.

Upon request and following appropriate identification of the requestor that is satisfactory both to TransGaming and under PIPEDA or other applicable laws, an individual will be informed of the existence, use and any disclosure of his/her Personal Information. The individual will be given access to that information if requested. A reasonable administration fee may be charged to supply the information. The approximate cost of the administration fee will be communicated to the individual prior to the release of the information.

TransGaming will use reasonable endeavours to ensure that your Personal Information is accurate. In order to assist us with this, you should notify us of any changes to the Personal Information that you have provided to us by updating your Account Information and preferences or by contacting the Privacy Officer at the address set out below.

In limited circumstances, TransGaming may refuse an individual access to their Personal Information; however, access will only be refused in accordance with PIPEDA or other applicable laws. For instance, if the Personal Information is protected by solicitor-client privilege, or would reveal confidential commercial information, TransGaming may refuse access to such information.

Products Offered in Partnership with Third Parties and Third Party Links: This policy does not apply to the practices of companies that TransGaming does not own or control, or to people that TransGaming does not employ or manage, including without limitation, any of TransGaming’s affiliates or business partners.

Children: We assume, in those cases in which you legally provide us with credit card information, that you are an adult or are otherwise authorized to do so. We encourage parents and guardians to participate in their children’s activities and to supervise them when they access the Service or on-line resources. We do not knowingly collect Personal Information from children under the age of 13. No information should be submitted to or posted through the Service or on TransGaming sites by users under 13 years of age. If a child under the age of 13 submits Personal Information to TransGaming, we will delete the information as soon as we discover it was provided by a child under 13 years of age. We will not and do not use such information for any purpose.

Compliance and Complaint Resolution: TransGaming is the data controller in respect of your Personal Information processed by us under this Privacy Policy. Our Privacy Officer ensures that we comply with this Privacy Policy, receives and responds to your questions, comments or complaints and deals with requests for access to, and rectification of, files. You can contact our Privacy Officer by email at: privacy@transgaming.com, marked ‘Attention: Privacy Officer’, and by mail at:

Attention: Privacy Officer
TransGaming Interactive Ltd.
Third Floor
56A Poland Street
London
W1F 7NN