CCPA/CPRA Privacy Notice (California Privacy Rights)

If you are a resident of California, please read the following.

CCPA/CPRA Privacy Notice (California Privacy Rights)

This privacy notice section is for California residents, and it supplements the information contained in our Privacy Policy.  It applies solely to all visitors, users, and others who reside in the State of California.

Definitions for the purpose of CCPA and CPRA

Business or business for the purpose of CCPA/CPRA, refers to Reflection Games, Inc. (also referred to as the “Company,” “we,” “us,” or “our”), as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers' personal information, that does business in the State of California.

CCPA and/or CPRA refers to the California Consumer Privacy Act (the "CCPA") as amended by the California Privacy Rights Act of 2020 (the "CPRA").

Consumer or consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in California who is outside of California for a temporary or transitory purpose.

Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

Personal Data, also referred to as “personal information” for the purposes of the CCPA/CPRA, means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

Service Provider or service provider, means any natural or legal person who processes your information on behalf of the Company. It refers to third party companies or individuals employed by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform services related to the Services, or to assist the Company in analyzing how the Services are used.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information, which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact collected by us but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

* We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes. Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed. 

Under CCPA/CPRA, personal information does not include: 

  • Publicly available information from government records 

  • Deidentified or aggregated consumer information 

  • Information excluded from the CCPA/CPRA's scope, such as:  

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data 

  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994. 

For additional information about the data we collect, the sources of the information we collect and how we use the information we colletct, please see our general Privacy Policy.   

If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes, we will update our Privacy Policy. 

Sale of Personal Information 

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit. 

We do not sell personal information, as the term sell is commonly understood. We do allow service providers and partners to use your personal information for the business purposes described in our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA. 

We may sell and may have sold in the last twelve (12) months the following categories of personal information: 

  • Category A: Identifiers 

  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) 

  • Category D: Commercial information 

  • Category F: Internet or other similar network activity 

  • Category G: Geolocation data 

  • Category K: Inferences drawn from other personal information 

  • Category L: Sensitive personal information 

Please note that the categories listed above are those defined in the CCPA/CPRA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return. 

Sale of Personal Information of Minors Under 16 Years of Age 

We do not sell the personal information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by contacting us. 

If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information. 

Your Rights under the CCPA/CPRA 

The CCPA/CPRA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights: 

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used. 

  • The right to know/access. Under CCPA/CPRA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:  

  • The categories of personal information we collected about you 

  • The categories of sources for the personal information we collected about you 

  • Our business or commercial purposes for collecting or selling that personal information 

  • The categories of third parties with whom we share that personal information 

  • The specific pieces of personal information we collected about you 

  • If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:  

  • The categories of personal information categories sold 

  • The categories of personal information categories disclosed 

  • The right to say no to the sale or sharing of Personal Data (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request, please see the "Do Not Sell My Personal Information" section or contact us. 

  • The right to correct Personal Data. You have the right to correct or rectify any inaccurate personal information about you that we collected. Once we receive and confirm your request, we will use commercially reasonable efforts to correct (and direct our Service Providers to correct) your personal information, unless an exception applies. 

  • The right to limit use and disclosure of sensitive Personal Data. You have the right to request to limit the use or disclosure of certain sensitive personal information we collected about you, unless an exception applies. To submit, please see the "Limit the Use or Disclosure of My Sensitive Personal Information" section or contact us. 

  • The right to delete Personal Data. You have the right to request the deletion of your Personal Data under certain circumstances, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:  

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. 

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. 

  • Debug products to identify and repair errors that impair existing intended functionality. 

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. 

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.). 

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent. 

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. 

  • Comply with a legal obligation. 

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer's rights, including by:  

  • Denying goods or services to you 

  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties 

  • Providing a different level or quality of goods or services to you 

  • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services 

Exercising Your CCPA/CPRA Data Protection Rights 

Please see the "Do Not Sell My Personal Information" section and "Limit the Use or Disclosure of My Sensitive Personal Information" section for more information on how to opt out and limit the use of sensitive information collected. 

Additionally, in order to exercise any of your rights under the CCPA/CPRA, and if you are a California resident, you can contact us: 

By email: Privacy@reflection.games 

By visiting this page on our website: www.reflection.games/privacy 

By phone number: 206.420.2386 

By mail: 5001 25th Ave NE, suite 200, Seattle, WA 98105 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. 

Your request to us must: 

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative 

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it 

We cannot respond to your request or provide you with the required information if we cannot: 

  • Verify your identity or authority to make the request 

  • And confirm that the personal information relates to you 

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt. 

For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance. 

Do Not Sell My Personal Information 

As defined in the CCPA/CPRA, "sell" and "sale" mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit. 

We do not sell personal information as the term sell is commonly understood. We do allow service Providers to use your personal information for the business purposes described in our Privacy Policy, for activities such as advertising, marketing, and analytics, and these may be deemed a sale under CCPA/CPRA. 

You have the right to opt-out of the sale of your personal information. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to opt-out, please contact us. 

The service providers we partner with (for example, our analytics or advertising partners) may use technology on the Services that sells personal information as defined by the CCPA/CPRA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA/CPRA law, you may do so by reaching out to us or by following the instructions below. 

Please note that any opt out is specific to the browser you use. You may need to opt out of every browser that you use. 

Website 

Additionally, you can opt out of receiving ads that are personalized as served by our service providers by following through the following: 

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, you will need to opt out again. 

Mobile Devices 

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests: 

  • "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices 

  • "Limit Ad Tracking" on iOS devices 

You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device. 

Limit the Use or Disclosure of My Sensitive Personal Information 

If you are a California resident, you have the right to limit the use and disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such services or goods. 

We collect, use and disclose sensitive personal information in ways that are necessary to provide the Services. For more information on how we use your personal information, please see the "Use of Your Personal Data" section or contact us. 

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA) 

Our Service does not respond to Do Not Track signals. 

However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. you can enable or disable DNT by visiting the preferences or settings page of your web browser. 

Your California Privacy Rights (California's Shine the Light law) 

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes. 

If you would like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided above. 

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581) 

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. 

To request removal of such data, and if you are a California resident, you can contact us using the contact information provided below and include the email address associated with your account. 

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.