Privacy Statement
for Grampy’s Games
Effective
Date: June 15, 2021
Welcome! Here at Fred Engel, LLC, we
respect your privacy. This Privacy Statement describes our privacy practices as
the owner and operator of http://grampysgames.com (we’ll call this “Grampy’s
Games”), including the personal information we collect, how it is used and
shared, and how you can control it. If you are under 13 years old, you
should talk to a parent or guardian before entering information on any website,
including Grampy’s Games, and we will need to collect parental consent before
you can set up an account and use Grampy’s Games.
This Privacy Statement is made in accordance
with the Children’s Online Privacy Protection Act (“COPPA”), as well as other
applicable privacy laws, and outlines our practices regarding personal
information collection from users of all ages. To learn more about our
practices specifically related to children under 13 years old, please refer to
the “Children’s Privacy” section. For more information about COPPA, feel free
to visit https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.
If you (or your child) are a California
resident, you can learn more about your privacy rights under the “California
Privacy Notice” section.
SECTIONS
·
Personal
Information We Collect
·
How We
Use Personal Information
·
How We
Share Personal Information
·
Advertising
& Analytics
·
Data
Storage & Security
·
Cookies
·
Your
Rights & Choices
·
California
Privacy Notice
·
Children’s
Privacy
·
Changes
& Notice
·
Contact
Us
Personal
Information We Collect
In order to use Grampy’s Games, you or your
child must create an account or be added to a community as described in the
Terms of Use Grampy's Games Policy, which may include providing us with the
following personal information:
·
Identifiers,
such as username, nickname, and email addresses
·
Parent
or guardian contact information
·
Communications
with us through email or other user support
·
Contact
information for people you would like to add to a community
We may
automatically collect personal information from you or your child upon access
and use of Grampy’s Games, including:
·
Device,
network, and cookie identifiers
·
Internet
or other electronic network activity information, such as browser type and
operating system version, access times, and page views
·
Communities
you have joined and other community members you interact with
We may
derive information or draw inferences about you, or your child based on the
information we collect. Please note that all the information we collect may be
combined and used for the purposes described in this Privacy Statement.
How We Use
Personal Information
We collect and use information about you or
your child for the following purposes:
·
Provide,
maintain, and improve Grampy’s Games, as well as to develop new content and
features
·
To
invite users and third parties to join a community or seek parental consent
·
Perform
contractual obligations
·
Create,
maintain, and service user accounts
·
Send
notifications related to your or your child’s account
·
Send
newsletters or email communications you have previously consented to
·
Enable
you or your child to participate in interactive features of Grampy’s Games
·
Respond
to communications from users, including customer service requests
·
Conduct
internal research and development
·
Analyze
traffic and user activities on Grampy’s Games, identify popular areas or games,
and optimize Grampy’s Games
·
Debug Grampy’s
Games to identify and repair errors
·
Protect
the rights, property, and personal safety of Fred Engel, Grampy’s
Games, and others, and comply with our legal obligations, including to detect,
investigate, and prevent fraud and other illegal activities, and to enforce our
agreements.
How We
Share Personal Information
We do not sell any personal information
collected by or from Grampy’s Games. We will not share the personal information
we collect with any unrelated third parties other than as follows:
·
Invitations
to Join Communities. When
you provide us with others’ account information to add them to a community you
have formed, we may share your account information and the account information
of other community members with those invitees to notify them of who belongs to
the community and who is available to play.
·
With Our
Service Providers. We may
share personal information with unaffiliated companies or individuals we hire
or work with that perform services on our behalf, such as web hosting,
information technology, and other services.
·
In Connection
with a Corporate Transaction.
Personal information may be disclosed or transferred as part of, or during
negotiations for, any purchase, sale, lease, merger, or any other type of
acquisition, disposal, or financing involving us or Grampy’s Games.
·
With Our
Professional Advisors. We may
share personal information with our legal, financial, insurance, and other
advisors in connection with corporate transactions, the management of our
business and operations, and for compliance purposes.
·
With Law
Enforcement Authorities and Individuals Involved in Legal Proceedings. We share personal information when it is
necessary for us to comply. with applicable law or legal process, to respond to
legal claims, or to protect the rights, property, or personal safety of us,
Grampy’s Games, our users, employees, or the public.
Advertising
& Analytics
We do not allow users
to use social media sharing or login functions or use, or allow our partners to
use, automatically collected information, such as IP addresses, cookie
identifiers, and other device identifiers, other than for purposes of
supporting our internal operations, such as to provide users with access to
features and activities on Grampy’s Games and to customize content and improve
our Site. We never allow interest-based advertising.
Data
Storage & Security
We store the personal information we collect
for as long as it is necessary for the purpose or purposes for which we
originally collected it. We may also retain personal information as required or
permitted by law. The information we collect may be stored and processed in the
United States or any other country in which we or our service providers
maintain facilities. We or our service providers may transfer information that
we collect about you, including personal information, across borders and from
your country or jurisdiction to other countries or jurisdictions around the
world. By using Grampy’s Games, you consent to such transfers and to the use
and disclosure of information about you as described in this Privacy Statement.
Our goal is to maintain the security of information, but we cannot guarantee
that information security measures are fail-safe or guarantee that information
on Grampy’s Games may not be accessed, disclosed, altered, or destroyed.
Grampy’s Games uses administrative, technical, and physical steps to keep
collected information secure, including limiting the number of people who have
access to our database servers and the use of password protections to guard
against unauthorized access.
Cookies
We may use cookies, which are small text files
that help store user preferences and activity, and similar technologies to
recognize you when you visit our Site and to collect analytical data, such as
the number of visits to Grampy’s Games and which games are popular. These
technologies allow us to optimize the operation of Grampy’s Games, including
ensuring Grampy’s Games is functioning properly and improving Grampy’s Games.
You can opt out of or disable cookies in your browser by updating the settings
and preferences, but it may affect the functionality of Grampy’s Games.
Your
Rights & Choices
Marketing
Communications
We may send marketing emails from time to time.
You may opt out of receiving promotional communications from us by following
the instructions in those messages. If you opt out, we may still send
non-promotional communications, such as emails about your account. We do not
send marketing communications to children.
Location
Data & Do Not Track
We do not collect any location data. We do not
support Do Not Track signals. Do Not Track is a preference you can set in your
web browser to inform websites that you do not want to be tracked. You can
enable or disable Do Not Track by changing the settings in your web browser.
Other
Rights
Depending on the law in your jurisdiction, you
may have additional rights, such as rights to access, correct, and delete your
personal information. If you would like to exercise those rights, please feel
free to contact us at info@grampysgames.com.
California
Privacy Notice
If you are a California resident, please review
these additional privacy disclosures, which provide a summary of how we
collect, use, and disclose personal information from you or your child, and explain
your rights under California law.
Categories
of Information for Business Purposes
We may collect the following categories of
personal information as described in the “Personal Information We Collect”
section:
·
Identifiers,
such as a username and email address
·
Internet
or other electronic network activity information, such as log data, and
information about the devices and computers you or your child uses to access Grampy’s
Games
·
Other
information you or your child provides, such as email communications
We
collect this information from you, your child, or as otherwise provided in this
Privacy Statement. We use these categories as described in the “How We Use
Personal Information” section, and we disclose these categories personal
information for business purposes as described in the “How We Share Personal
Information” section.
Your
Rights
Under the California Consumer Privacy
Protection Act (“CCPA”), California residents have the right to request access
to or deletion of their personal information, to request additional details
about information practices, and to not be discriminated against for exercising
their rights from eligible businesses. If you contact us regarding your rights
under the CCPA, we will consider any such requests in accordance with
applicable laws. Note that even if we honor your request to delete your
information, we may retain certain information as required or permitted by law.
Likewise, California residents under 18 years old may request and obtain
removal of any of their own content they posted or shared on Grampy’s Games by
emailing us at info@grampysgames.com. Please
also note that any requests for removal do not ensure complete or comprehensive
removal of the content or information from Grampy’s Games.
Children’s
Privacy
Grampy’s Games was made to connect grandparents
with their grandchildren of all ages through free online games, and we need to
provide further privacy protections for the children under 13 years old who use
Grampy’s Games. Some portions of Grampy’s Games may be directed to children or
may allow children to submit personal information, which we will collect, use,
and disclose as described in this Privacy Statement and as more specifically described
below:
Parental
Consent
If a child wants to create an account, we will
seek parental consent prior to the collection of the child’s personal
information, which may include asking the child to provide a parent’s email
address to notify the parent of our privacy practices and obtain consent. If a
parent does not provide consent within a reasonable amount of time after the
request, we will delete the child’s and parent’s email addresses provided. We
will not condition a child’s participation in any activity on Grampy’s Games on
the disclosure of more personal information than is reasonably necessary to
participate.
Communications
We may allow children to receive one-time emailed
communications from us. When we do that, we will use the child’s account email
address and send a copy to the parent’s email address, and may provide an
opportunity for the parent to opt the child out of the communications. We will
only use the child’s email address to maintain the child’s account and for
purposes of such communications, and will delete the information from our
records once it is no longer required. We do not send text messages or other
non-email communications to children.
Parental
Controls
A parent can refuse or revoke consent for us to
collect personal information from that parent’s child at any time and can
request that we delete the personal information collected from our records. If
you have any questions or concerns about our approach to children’s privacy or
you are a parent who wants to request access to or the deletion of your child’s
personal information, please email us at info@grampysgames.com from the email address that provided initial
consent, which is one way we can verify that you are authorized to make such
requests. We will only provide access to or delete the personal information of
a child if we can verify parental authority. For information on how teens under
18 years old can request access or removal of their personal information,
please see the “California Privacy Notice” section.
Changes
& Notice
We may change this Privacy Statement from time to
time. When we make any changes, we will update the “Effective Date” at the top
and, in some cases, notify you through Grampy’s Games, email, or other
communication. We will not change how we handle previously collected
information without providing prior notice and obtaining any applicable
parental consent.
Contact Us
If you have any questions about how we handle
information, including children’s personal information, email us at info@grampysgames.com with the subject line “Privacy”.