1. Purpose
This Privacy Policy describes how Market Games Inc treats the information we collect from users who visit our website, register for an account, and/or use our Services.
By visiting our website, registering for an account or using our Services in any other way, you expressly consent to Market Games collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy. Market Games does not sell your Personal Information to any third-parties.
2. Scope
This Privacy Policy applies to Personal Information that is Processed by Market Games in the course of our business, including Market Games’ website and game applications. All individuals whose responsibilities include the Processing of Personal Information on behalf of Market Games are expected to protect that data by adherence to this Privacy Policy.
3. How We Collect Your Information
3.1 Types of Personal Information We Collect
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Market Games and the requirements of applicable law. Some of the ways that Market Games may collect Personal Information include:
Personal Information you provide directly to Market Games through interacting with our website and/or requesting Services or information. This includes name, email address, and phone number. As you navigate our website, certain passive information may also be collected about your visit, including through cookies and similar technologies.
Personal Information you provide directly when you use the Services or engage in certain activities, such as registering for an account with Market Games and/or playing our game application. This includes names, email addresses, and game performance data.
Personal Information obtained from Third Party sites that we may receive about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, we may collect information that you have made public via your privacy settings on these sites (e.g. LinkedIn, your educational institution’s website). This information includes, names, emails, and job title and responsibilities.
3.2 How We Use Your Information
Market Games Inc. generally uses this information to provide you with better service. We acquire, hold, use, and process information for a variety of purposes, including:
To provide products, services, or information requested. Market Games may use information about you to fulfill your requests for products,
Administrative Purposes. Market Games may use Personal Information about you for its administrative purposes, including to:
Measure interest in Market Games’s Services;
Develop new products and Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about individual accounts and activities on Market Games’ Services and systems, and, in Market Games’ discretion, changes to any Market Games’ policy;
Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
Process payment for products or services purchased;
Process applications and transactions;
Prevent potentially prohibited or illegal activities;
Enforce our Terms.
Marketing Market Games’ Products and Services. Market Games may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Market Games may provide you with these materials by email, phone, postal mail, or facsimile, as permitted by applicable law. Such uses include:
To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Services to you and Third-Parties;
For other purposes disclosed at the time that individuals provide Personal Information; or
Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
Market Games may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third-Parties, may receive periodic emails and newsletters from us with information on Market Games’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by unsubscribing to our communication.
Anonymous and aggregated Information Use. Market Games may use Personal Information and other information about you to create anonymized and aggregated information, such as non-identifiable, de-identified demographic information, de-identified location information, information about the computer or device from which you access Market Games Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Market Games may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Market Games and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Sharing Content with Friends or Colleagues. Market Games Services may offer various tools and functionalities. For example, Market Games allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Market Games or any other Third Parties for any other purpose.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information and Interest-Based Advertising
We, as well as Third-Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device“) that allow us to record certain pieces of information whenever you visit or interact with our Sites, Services, applications, messaging, and tools, and to recognize you across devices.
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Social Media Widgets: Our Website includes links to social media features such as Facebook and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third-Party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
Analytics. We may also use analytics tools including Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Sites, Services, applications, and tools. This includes technologies that allow you access to our Sites, Services, applications, and tools; that are required to identify irregular Site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Sites, applications, Services, and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content, applications, Services, or tools;
Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Sites, Services, applications, or tools. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites;
Advertising or Targeting Related. We may use first-party or Third-Party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on Third-Party Sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third-Party Websites and Social Media Platforms
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Market Games does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
Market Games’ Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
4. Onward Transfer - Market Games May Disclose Your Information
4.1 Information We Share
We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.
Instructors. The Instructor who is running the game will be given or provided access to the following information about the Participants in that game: name, User ID, Virtual Player Number, Game Data, and Posts. Instructors will only have access to any Demographic Information in an aggregated, anonymous form (see “All Instructors” below).
Participants. Each Participant will have access to his or her own Gate Data and, if the Instructor elects, the collective Game Data for the class. Fellow Participants in each game will have access to the content from in-game chats and will see the Virtual Player Number associated with chats. Please do not identify yourself in your in-game chats – chat information is collected along with all other Game Data. We will not share your Personal Information or Demographic Information with other Participants.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site.
Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, Demographic Information. Game Data, User ID, Posts and other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Market Games policies or contracts; (v) to collect amounts owed to Market Games; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such an event, Market Games will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.
4.2 Data Transfers
All Personal Information, Demographic Information, Game Data, User ID’s and other account information collected via or by Market Games may be stored anywhere in the world in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. In addition, this information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Market Games, you consent to the storage of your Personal Information in these locations.
5. Opt-out (Right to Restrict Processing)
5.1 General
You have the right to opt-out of certain uses and disclosures of your Personal Information. Where you have consented to Market Games’ Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt-out of further Processing by contacting info@marketgames.io. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
5.2 Email and Telephone Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Market Games and our Services and you will not be able to opt-out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).
5.3 Mobile Devices
Market Games may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. Market Games may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
5.4 "Do Not Track"
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.
6. Rights of Access, Rectification, Erasure, and Restriction
You may inquire as to whether Market Games is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to info@marketgames.io or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Market Games. Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with local laws.
Although Market Games makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which Market Games is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Market Games determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Market Games will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
Market Games retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
8. Security of Your Information
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. Children's Privacy
Our primary users are individuals 16 years of age and up. In most countries, individuals must be at least 13 to use our Services, and we do not knowingly collect Personal Information from Individuals under 13. In the European Union, Individuals under 16 may not use our services, and we do not knowingly collect Personal Information from individuals under 16 in the EU. If you are a parent of a child who has registered for our Services and does not meet these age requirements, please contact us at info@marketgames.io, and we will delete your child’s account upon confirmation of your identity.
10. Redress/Compliance and Accountability
If you have any questions about our privacy practices or this Privacy Policy, please contact Market Games by email at info@marketgames.io. We will address your concerns and attempt to resolve any privacy issues in a timely manner.
11. Other Rights and Important Information
11.1 Changes to Our Privacy Policy and Practices
This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.
Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the Services made available to you after such changes have been made, you hereby provide your consent to the changes.
Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Market Games will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Market Games will endeavor to comply with the law or contract.
11.2 California Privacy Rights
Under California Civil Code sections 1798.83-1798.84, also known as the “Shine the Light Law,” any of our users who are California residents are entitled to request and receive once a year, free of charge, a notice from us describing what categories of personal customer information we share with Third-Parties for their direct marketing purposes. That notice will identify the categories of information shared, the Third-Parties and affiliates with which it was shared, and their names and addresses. Currently, Market Games does not share any personal information with Third-Parties for direct marketing purposes. If you are a California resident and would like a copy of the notice that the law requires, please submit a written request to the following address info@marketgames.io. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty days for a response.
12. Compliance
This Policy shall be implemented by Market Games and all its operating divisions, subsidiaries and affiliates. Market Games has put in place mechanisms to verify ongoing compliance with this Policy. Any Employee that violates these privacy principles will be subject to disciplinary procedures.
13. Contact Us
If you have any questions about our privacy practices, please email us at info@marketgames.io. In addition, if you wish to exclude your Personal Information from our direct marketing, or if you would like to review, update or delete your email address, mailing address or other Personal Information, or otherwise manage communications you receive from Market Games, please use the My Account link on our Site or contact us at the address above.
14. Definitions
The following capitalized terms shall have the meanings herein as set forth below.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Third-Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Market Games or Market Games’ Agents.
“Sites” includes our website and game applications.