This Privacy Notice will be effective from January 10th, 2023.
This Palm Slots Privacy Notice (the “Privacy Notice” or “Notice”) is provided to help you understand our practices regarding how we collect, use, share, and protect personal data. In this Privacy Notice, “Palm Slots” refers to Palm Slots Holding Corp. and its subsidiaries. We may also refer to Palm Slots as “we” or “us”. This Privacy Notice applies whenever you visit our websites, play the games that link to this Notice, or otherwise access any of our other products and/or services, mobile applications, or any other applicable platforms and/or devices (the “Service”). This Privacy Notice does not apply to games offered specifically by the following Palm Slots subsidiaries: Wooga GmbH, Seriously Digital Ltd, Supertreat GmbH, Reworks Oy, and JustPlay.LOL Ltd; the privacy notices for those games are available via the respective applications and websites.
By using the Service, you agree to the collection, disclosure, storage and use of personal data as described in this Privacy Notice. If you do not want Palm Slots to collect, store, use or share the personal data you provide in the ways described in this Privacy Notice, you should not play Palm Slots games or use our Service.
1. Personal Data We Collect
Palm Slots collects personal data to fulfil one or more of its functions and activities, as described in this Privacy Notice.
A. Personal Data That You Share with Us Directly
When you use our Service (including through a social network), you may give us information directly in a number of ways, including:
• to set up your account;
• in response to surveys or other research we conduct;
• to participate in contests and sweepstakes;
• by participating in group communications or chats;
• in communications with customer support agents and account managers;
• at conferences, conventions, and other events.
The information you share with us may include, for example:
• your age or birthday;
• your first and/or last name;
• your e-mail address;
• the password you use to access our Service;
• information about your account, a device on which you are playing one or more of our games and/or trying to access our Service, and/or other information about a request or inquiry you make;
• other information that helps us make sure it’s you accessing your account, including as necessary for us to provide the support you request, or information you provide to help us improve our Service (such as answers to an online survey or a feedback form).
When you use our Service, you may also have an option to create a profile that other Palm Slots players can see. In your profile, you may be able to include information like:
• game username(s);
• a country, state, and/or city where you live
B. Cookies and Automated Information Collection
For more information on how you can opt-out of or disable cookies, please see the “Your Rights” section below.
We, our service providers, and third parties may also employ other technologies including (i) web beacons, which may allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which may allow us or our advertising partners to advertise more efficiently and effectively by recognizing your device(s) on, off, and across different services and devices and identifying the source of a new installation; and (iii) local shared objects, also known as flash cookies, which may help us to reduce fraud, remember your in-game preferences, and speed up load times.
• the type of device you are using;
• your device’s operating system and version;
• your mobile device’s identifiers, like your MAC Address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
• your browser type;
• your browser and/or device language;
• referring and exit pages and URLs;
• platform type;
• the number of clicks on a page or feature;
• domain names;
• landing pages;
• pages viewed and the order of those pages;
• the amount of time spent on particular pages;
• in-game activity, including the date and time of activity.
2. How We Use Personal Data
Palm Slots may use personal data for a variety of business purposes as described in this Privacy Notice, including to fulfill our contractual obligations, complete transactions you request, comply with law, and for other legitimate business purposes, such as to:
• create game accounts and allow gameplay;
• operate, improve, and optimize our Service and our players’ experiences, including by measuring interest in and engagement with our Service;
• facilitate in-game purchases;
• provide technical support and respond to player inquiries;
• authenticate and/or verify individual identities;
• protect the safety and well-being of our players;
• protect Palm Slots’s rights and property in connection with our Service;
• address technical issues and maintain and/or enhance network and information security;
• conduct audits, ensure internal quality control, and take safety precautions;
• prevent, investigate, and/or prosecute fraud or potentially illegal activities and enforce our Terms of Service;
• manage and deliver contextual and behavioral advertising;
• conduct research, including by using personal data to create de-identified and/or aggregated data. De-identified and aggregated data are not personal data and we may use and share such data for any legally permissible purposes.
Your interactions with our Service may be tracked across platforms and/or devices.
In addition to the above, if you have provided your e-mail address to Palm Slots we may use it to communicate with you in a number of ways, including to respond to customer support inquiries; keep you and others informed of your gameplay, comments from friends, and in-game status and promotions; and tell you about gift and neighbor requests. Some messages, like invitations for friends to join you in a game, may include your name and profile photo. We may also send promotional messages (“Promotional Communications”) directly or in partnership with other parties. For more information on how you can opt-out of Promotional Communications, please see the Your Rights section below.
We may use technologies that (a) may be considered automated decision-making or profiling, and/or (b) include artificial intelligence to evaluate personal data that we collect (including, for example, in-game activity and communications within our Service) to improve our Service (for example, to prioritize customer support inquiries to shorten response times, personalize the game experience, and to understand trends in response to certain features in our Service) and for other legitimate business purposes. We will not use these technologies in a way that has a legally significant impact on you, unless we have your consent, or we are otherwise legally permitted to do so.
We may use personal data for any other purposes communicated to you at the point of collection, or otherwise with your consent.
3. How We Share Personal Data
We may disclose or publish aggregated and analytical information (information about you and other players collectively that is not intended to specifically identify any individual player, for example, players between the ages of 25 and 30 who live in Chicago) and other non-personal data about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes.
In addition, we may share information (which may include personal data) with third parties (in other words, parties other than Palm Slots) or allow third parties to collect this information from our Service as described in this Privacy Notice.
A. Service Providers
Palm Slots uses its subsidiaries and other unaffiliated companies (“Service Providers”) to support the Service, for example, to assist us with processing payments, analyzing data, optimizing game play and enhancing player experience, e-mail delivery, hosting services, and managing and delivering contextual and tailored advertisements.
B. Advertising, Including Third-Party and Tailored Advertising
We may have advertising on our Service. When advertisers or ad networks place ads in our Service, they may collect, or we may share the following types of information from within our Service:
• performance data (like the number of clicks on an advertisement);
• aggregated and/or de-identified information about players that is not intended to specifically identify any individual player (For example, players between the ages of 45 and 65 who live in San Francisco);
• certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs, and device identifiers);
• your in-game activity (for example, your level).
The information collected may be used to:
• measure how effective ads are;
• personalize the player experience by showing advertisements for products and services that may be more likely to appeal to you;
• undertake web analytics (like Google Analytics) to analyze traffic and other player activity.
Advertisers or ad networks may collect this information through the use of tracking technologies like browser cookies and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time.
C. Legal Compliance
We may share personal data in the following circumstances:
• when we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena);
• to satisfy any laws or regulations;
• where we believe in our sole discretion that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
• when we believe in our sole discretion that there is an emergency that poses a threat to the health and/or safety of any person or the public generally;
• to protect the rights or property of Palm Slots and other applicable third parties, including to enforce our Terms of Service.
4. Your Rights
Depending upon the applicable law where you live, you may have the right to make requests with respect to personal data that Palm Slots processes about you, for example to request:
• correction (or rectification) of personal data that you think is incorrect;
• erasure (or deletion);
• an electronic copy (or portability).
You may also have the right object to certain processing, including to opt out of targeted advertising.
A. Manage Information We Get from Platforms
B. To manage the information Palm Slots receives about you from a third-party platform where you play our games, like Facebook, Apple, Amazon, etc. you will need to follow the instructions for the relevant third-party application(s) for updating your information and changing your privacy settings.
C. Opting Out of Promotional Communications
If you want to stop receiving Promotional Communications from Palm Slots, you can click on the “unsubscribe” link in any promotional email from Palm Slots. If you want to stop receiving texts or SMS messages from us, you can also use the “unsubscribe” link or reply “STOP” to any promotional message. Please note that it may take us some time for your opt-out to become effective.
D. Opting Out of Facebook messages
If you want to stop receiving messages through our game pages on Facebook, you can turn off all messages through your Facebook “settings”.
E. Opting Out of Push Notifications
When you install our apps on your mobile device, you can choose to receive push notifications, which are messages an app sends you on your device even when the app is not on. You can turn off notifications by visiting your mobile device’s “Settings”.
Additionally, in some of our game apps, you may find an option under “Settings” to turn off push notifications.
F. Opting Out of Third-Party Tailored Advertising
In games that serve third-party tailored ads, we provide a toggle button to disable them.
For more information about tailored advertising and your choices to prevent third parties from delivering tailored web and mobile web advertising you can visit www.aboutads.info. To opt out, for businesses that participate in the Digital Advertising Alliance, you can exercise that option at www.networkadvertising.org/choices and www.aboutads.info/choices.
If you live in the EU, you can get information and exercise your choices at www.youronlinechoices.com.
These opt-out tools are provided by third parties, not Palm Slots. Palm Slots does not control, operate, or endorse these tools or the choices that advertisers and others provide through these tools. They are listed here only as a convenience for players.
In addition, if you do not want to receive third-party tailored ads, you may opt-out by adjusting the ad tracking settings on your device. You can also reset the advertising identifier (like an IDFA) from your device’s Settings, which will prevent continued use of existing behavioral data tied to the previous advertising identifier. Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties, not Palm Slots. Palm Slots does not control, operate or endorse these tools or the choices that advertisers and others provide through these tools.
Please note that you may still receive advertisements from Palm Slots and third parties within Palm Slots games even if you opt out of tailored advertising; these ads will not be tailored to you.
G. Opting Out of Cookie Tracking
You can set your web browser to warn you about attempts to place cookies on your device or limit the type of cookies you allow. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
If you disable cookies, you may lose some of the features and functionality of our Service because Palm Slots cookies are necessary for providing the Service.
H. Do Not Track
Note that Palm Slots does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.
5. Children’s Privacy
In accordance with the Terms of Service, you may not use the Service if you are under 21 years old.
Palm Slots is committed to complying with laws protecting children. If you believe that your child has submitted personal data to Palm Slots, please contact us. Palm Slots will take reasonable steps to delete such information as soon as possible.
6. International Transfers, Retention, Security, Links, Updates, and How to Contact Us
A. International Transfers
Palm Slots may send, access, use, and/or store personal data outside of the country or region where you live including, for example, to the United States and Israel. We may transfer personal data to our subsidiaries, vendors, business partners, and others as described in this Privacy Notice.
Laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where personal data is transferred to or stored, used, or processed in, may be different from the privacy laws in place where you live. When we transfer personal data outside of the location where it was collected, we put into place appropriate safeguards (including, for example, contracts) or otherwise make efforts to ensure that such transfers meet applicable local legal requirements.
By using the Service, you consent to the transfer of personal data outside of the country or region where you live. If you do not consent to such transfer, please do not use our Service.
We may retain personal data for as long as you use the Service and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.
We take reasonable steps designed to protect personal data; however, no system or network can be guaranteed to be 100% secure and therefore we cannot guarantee the security of data. To the fullest extent permitted by law, we do not accept liability for unauthorized disclosure.
D. How to Contact Us
If you have any questions, comments or concerns about our Privacy Notice or any other privacy issue please contact Palm Slots DPO at [email protected]
If you have any questions or concerns that you think we have not adequately addressed, you may have the right to bring your question or concern to the privacy authority in the location where you live.