We collect information from you when you visit our websites, register on our site/portal, fill out a form or download a mobile or desktop app (together, the “Services”). When ordering or registering on our site or on our app, as appropriate, you may be asked to enter your personal contact information.

This Privacy Policy applies in addition to the terms and conditions of our Services.

2. Consent

By using our Services users agree that they consent to:

The conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by email: legal@sunsightgames.com.

3. Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically

When you use our Services, we may automatically collect and store the following information:

IP address;
Domain name;
Browser language preference;
Location information;
Hardware and software details;
Device ID or other identifier;
Voice recordings, and copies of your correspondence (including email addresses), if you contact us;
Website and communication usage information, such as correspondence and details of your use of our website and services obtained through cookies, web beacons, java script, log files, pixels and other tracking technologies;
Date and time stamp and time spent with the Services;
Referring URL;
Clicks; and
Content viewed and your activity within the Services.

We also collect information from analytic services, to compile and analyze information derived from the use of our Services, such as aggregate usage patterns, user preferences, peak demand times, preferred content and other information.

Data Collected in a Non-Automatic Way

We may also collect the following data when you perform certain functions with our Services:

Contact details, such as name, email address, postal address and telephone number;
Professional information;
Demographic information, such as date of birth, gender, interests and ZIP or postal code.
Interests and communication preferences including marketing permissions where appropriate;
Comments, feedback, posts and other content submitted, including survey information;
Payment information, such as a credit or debit card number or bank account details; and
Auto fill data.

When you submit online forms, participate in surveys, contests, promotions, or sweepstakes, join online chat discussions or post on a blog, request customer support, or submit testimonials, we collect your personal information, such as contact information, and other information you choose to share. Any information you provide in a blog may be read, collected, and used by others who access it. With your consent, we may use your testimonial and your name, e.g., to display personal testimonials of satisfied customers on certain Sites and in print advertisements.

4. How We Use Personal Data

Data collected through our Services will only be used for the purposes specified in this Privacy Policy. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used for the following purposes:

Personalization: To personalize your experience using the Services, such as by tailoring the content we send or display to you in order to personalize help and instructions, and to otherwise personalize your experience using the Services;
Provide Our Services: To provide and operate our Services, respond to your enquiries, for bug and error reporting and resolution, to perform upgrades and maintenance;
Improve Our Services. To better understand how our users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Services, based on the information and feedback we receive from you. We may also generate aggregated, pseudonymized and/or anonymized information about users of our sites and apps for statistical purposes, research, for marketing, advertising, or similar purposes;
Customer Service and Support: Your information helps us to more effectively respond to your customer service requests and support needs;
Transaction Processing: To process transactions, your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering Services requested by you;
Alerts and Required Notices: To send you messages that you have requested, such as service-related alerts and any notices required by contract or applicable law. The e-mail address you provide for order processing or product notifications, may be used to send you information and updates pertaining to your requests, in addition to receiving occasional company news, updates, related product or service information, etc (that you have signed up to receive);
Marketing and Promotions: To send you marketing communications, such as an event, contest, promotion, survey, or other Service feature, that you have signed up to receive;
Advertising and Referrals: To assist in advertising the services on third-party websites ; to track referrals from partner websites; and share leads with referral partners;
Verify Identity and Detect Fraud: To verify your identity and/or location in order to allow access to your accounts, conduct online transactions, and secure your personal information, and for risk control, fraud detection and prevention, and compliance with laws and regulations;
Protect Our Legal Rights and Prevent Misuse: To protect the Services, prevent unauthorized access and other misuse, and where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms;
Comply with Legal Obligations: To comply with the law or legal proceedings such as when required to disclose information in response to lawful requests by public authorities, including responding to national security or law enforcement disclosure requirements; and
General Business Operations: Where necessary to the administration of our general business, accounting, recordkeeping and legal functions.

5. Children

Our Services are not directed to children and we do not knowingly collect or use personal data from children under 18 years of age. If we learn that we have collected personal data from a child under 18 years of age, the personal data will be deleted as soon as possible. If a child under 18 years of age has provided us with personal data their parent or guardian may contact our privacy officer.

6. Do Not Track Notice

Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. We do not respond to web browser “do not track” (DNT) settings or headers with respect to Sun Sight Games public Websites. Currently no common industry standard for DNT has been adopted and there is also no consistent standard of interpreting user intent when the DNT setting is enabled. Sun Sight Games takes privacy seriously and will continue to monitor policy advocates, technical experts, regulators and companies attempting to create a consensus interpretation around DNT browser technology and the implementation of a standard. We are not responsible for and cannot guarantee how any third parties who interact with our Sites and your data will respond to DNT signals.

7. Email

When you send us an email or when you ask us to respond to you by email, we collect your exact email address and any information you have included in the email message.

We use your email address to acknowledge your comments and/or reply to your questions, and we will store your communication and our reply in case we correspond further. We may use your email address to send you information about offers on products or special promotions that we believe may be of interest to you. You may choose to stop receiving our marketing emails at any time by following the unsubscribe instructions included in these emails.

If you use any of our services that allow you to send online recognitions to other people, we may use your email address to send you information about our products. When you provide us with someone else’s email address, we will only use it to send them the recognitions that you have requested. The emails we send may contain web beacons (described below).

8. Web Beacons

Sun Sight Games uses images imbedded in email messages called “web beacons.” Web beacons are clear images that allow Sun Sight Games to determine if a message has been opened. It also allows Sun Sight Games to determine the IP address of the user that opened it and to access any Sun Sight Games cookies. We may use this information in the aggregate to assess and improve our email messages.

Email web beacons can be disabled by turning off HTML display and displaying text only or by turning off image display while still using HTML within your email client.

9. Cookie Policy

A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user's browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Sites:

Functional cookies: Functional cookies are used to remember the selections you make on our Sites so that your selections are saved for your next visits;
Analytical cookies: Analytical cookies allow us to improve the design and functionality of our Sites by collecting data on how you access our Sites, for example data on the content you access, how long you stay on our Sites, etc;
Targeting cookies: Targeting cookies collect data on how you use the Sites and your preferences. This allows us to personalize the information you see on our Sites for you; and
Third-Party Cookies: Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes monitor user preferences to tailor advertisements around their interests.

10. Who We Share Personal Data With

Internal Staff

We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Service Providers

To ensure that we efficiently provide the Services you have requested from us, we may share your information with Service Providers, such as those needed to deliver our services to you, and those that provide marketing services and event communications to you, but such service providers are bound by law and contract to only use your information for the purposes we specify. Service Providers may be located in the EU, United States, Canada, and other jurisdictions. For example, we may work with Service Providers to track and manage the request that you have made on a Website for demos, merchandise, information about Service offering, etc. Such Service Providers are provided only with information as is necessary to perform their function, which may include your physical mailing address, email address and name. Information provided to Service Providers may be used only for the purpose stipulated and is subject to strict terms of confidentiality.

Sun Sight Games represents that any third party for which Personal Information may be disclosed by Sun Sight Games is in compliance with GDPR (the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)), Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA), California Consumer Privacy Act (CCPA), and other applicable laws or contractual provisions requiring the same level of privacy protection.

Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

As permitted or required by law, such as to comply with a subpoena, court-ordered discovery, a warrant, a government request, or similar legal process;
When we believe in good faith that disclosure is necessary to respond to claims asserted against us; to protect our rights; to protect vital interests including your safety or the safety of others; or, to investigate or prevent fraud;
If Sun Sight Games is involved in a merger, acquisition or sale of all or a portion of its assets, or in the event of bankruptcy or dissolution of our business, your Personal Information may be transferred to an acquiring business or third party, including contemplation of or related to due diligence for such business transactions, subject to any applicable restrictions under applicable laws;
We may also use, or disclose your Personal Information to third parties, if Sun Sight Games has reason to believe that using or disclosing such information is necessary to: (i) conduct investigations of possible breaches of law; (ii) identify, contact, or bring legal action against someone who may be violating an agreement they have with us; (iii) investigate security breaches or cooperate with government authorities pursuant to a legal matter; or (iv) to protect our rights, safety or property, and/or the rights, safety, and property of our clients, users of our platform, and any other persons; and
We may disclose your Personal Information for any other purpose to which you consent g.

If you follow links from our Services to another third party service, please note that we are not responsible for and have no control over their privacy policies and practices.

11. Retention

It is our policy to retain your information only for as long as is necessary to fulfill the purpose for which it was collected and processed. We will retain your information for as long as your account is active or as needed to provide you services and for as long as may be required to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. Even if you request for your information to be deleted, laws and regulations may require us to retain a copy of your information in our files for a longer period of time. Unless a specific applicable law requires a different retention period, most data will be retained for no longer than seven (7) years.

12. How We Protect Your Personal Data

In order to protect your security, we use generally accepted standards of technology and operational security and store all of our data on servers in secure facilities. All data is only accessible to our employees, contractors or our contracted hosting vendors. Our employees, contractors and contracted hosting vendors are bound by strict confidentiality agreements and a breach of this agreement would result in their termination.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

13. Your Rights as a User

For EU Residents

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

GDPR gives you certain rights, including: a right to be notified of our data collection practices; the purposes and lawful bases under which we process your data; if our legitimate interests are a basis for processing, what those interests are; the categories of data processed; the categories of third parties with whom data is shared; the details of any data transfers outside of the EU and the safeguards in place; the applicable retention periods or policies; the right to access, correct, and delete (under certain circumstances) your personal information; the right to receive a copy of your information in a “portable” form so that you may transfer it to other services; the right to withdraw consent for processing; the right to lodge a complaint with a data protection authority; the right to be advised of the existence of any automated decision-making, including profiling, and the right to object such decisions; and, the right to withdraw consent without detriment. This Notice provides details on how we honor those rights and the process for exercising them.

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal bases to collect and process the personal data of users in the EU:

Users have provided their consent to the processing of their data for one or more specific purposes; and
Processing of user personal data is necessary for us or a third party to pursue a legitimate interest. Our legitimate interest is not overridden by the interests or fundamental rights and freedoms of users. Our legitimate interest(s) are listed in the section “How We Use Personal Data”.

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

For California Consumers

California law gives you certain rights, including: a right to be notified of (and to request more information about) our data collection practices; the categories of data we process; the categories of third parties with whom data is shared; the right to request disclosure (up to twice per year) of the personal information we have about you or have had within the last 12 months: the right to delete that information (under certain circumstances) or correct that data if it is inaccurate; the right to know if your data is being sold (we do not sell your data); the right to know what personal information is being sold and to opt-out of such sales (if applicable); the right to receive a copy of your information in a “portable” form so that you may transfer it to other services; and, the right to not be discriminated against for exercising these rights. This Notice provides details on how we honor those rights and the process for exercising them.

In accordance with California law, we provide the following notice regarding:

Identifiers: including name, address, email address, IP address, cookie-related IDs;
Other personal information: phone number;
Demographic information: age, gender (if you provide that information to us);
Commercial information regarding your interactions with this site: including purchases and requests for information regarding our services;
Biometric information: we do not collect this data;
Internet or other electronic network activity information: browsing activity on our website, browser type, browser language, browser and system configuration information, including information that may get automatically collected when you use our site or interact with us via social media or click on advertisements or emails;
Geolocation data: inferred from your IP address to help us deliver relevant information such as language specific pages;
Audio, electronic, visual, thermal, olfactory, or similar information: we do not collect this data;
Professional or employment-related data: employer name, job title (if you provide that information to us);
Education information: we do not collect non-public personally identifiable information as defined under FERPA; and
Inferences drawn from any of the above personal information: we may infer your preferences and interests regarding our products and services based upon the information collected above.

The purposes for which we collect the above-described personal information are detailed in the “How We Use Personal Data” section of this Notice.

We do not sell personal information, therefore we do not offer a process by which you can opt-out of the sale of your personal information.

We may retain your personal information for the duration of any business relationship we have with you, and for only as long as is reasonably necessary after the conclusion of that relationship, or for as long as may be required by law.

How to Access, Modify, Delete, or Challenge the Data Collected

You have the right to access, correct (“rectify”), or delete your Personal Information held by us or may ask for a restriction of processing. You may also have the right to ask for an overview or copy of your Personal Information or to request that certain of your personal information be provided to you or to another provider in a machine-readable format where technically feasible (data portability).

You can exercise these rights by sending an email to privacy@sunsightgames.com.

Except in limited circumstances, as specifically provided by applicable privacy legislation, Sun Sight Games can tell you whether we hold Personal Information about you.

Please note that there are some limitations to these rights. For example, we will not be able to delete your personal information if we are required by law to keep it or if we hold it in connection with a contract with you. Similarly, access to your personal information may be refused if making the information available would reveal personal information about another person or if we are legally prevented from disclosing such information.

Sun Sight Games will only refuse access to your Personal Information in those circumstances permitted and required by applicable laws or regulations. If we cannot fulfill your request, we will inform you about why we cannot comply with your request.

Withdraw of Consent

Where we process your personal information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Applicable law may also give you the right to object to certain elements of our processing or to lodge a complaint.

Object to Processing

You have the right to object to processing (including profiling) based on legitimate interest grounds, where we are relying upon legitimate interests to process personal information. If you object, we must stop that processing unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or we need to process the personal information for the establishment, exercise or defense of legal claims. Where we rely upon legitimate interest as a basis for processing, we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

Object to Marketing

You have the right to object to our use of your personal information (including profiling) for direct marketing purposes, such as when we use your personal information to invite you to our promotional events.

Right to Lodge a Complaint

You have the right to lodge a complaint with your supervisory authority, if you consider that the processing of your personal information infringes applicable law.

14. Enforcement

Sun Sight Games will conduct periodic assessments to validate its continued adherence to this Notice.

Where Sun Sight Games has knowledge that one of Sun Sight Games employees or Service Providers is using or disclosing Personal Information in a manner contrary to this Notice, Sun Sight Games will take reasonable steps to prevent or stop the use or disclosure. Sun Sight Games holds its employees and Service Providers accountable for maintaining the trust that employers and users place in our company.

15. International Data Transfers

The personal information we collect from you may be transferred to, stored at or processed in other countries, including the United States or other locations outside the European Economic Area, which may not provide equivalent levels of data protection to your home jurisdiction.

When we transfer user personal data we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring personal data internationally.

If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:

The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient.

16. Dispute Resolution

Sun Sight Games will investigate and attempt to resolve complaints and disputes regarding the use and disclosure of Personal Information in accordance with the principles contained in this Notice.

17. Modifications

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the "Effective Date" at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

18. Complaints

If you have any complaints about how we process your personal data, please contact us at privacy@sunsightgames.com so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority.

Last Updated: October 29, 2023

Privacy Policy

1. General