Effective date: February 13, 2023
Please note that the scope of this Policy is limited to information and data collected or received by us through your use of the Services. We are not responsible for the actions of individuals with no relationship to us or third-party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.
If you do not want us to collect, store, use, or share your information in the ways described in this Policy, you should not use our Services.
When you use our Services, you may give us your contact information directly on our website, generally your name and email address.
We may also offer you the option to complete a user profile that is visible to other Apps users (“Account”). If you create an Account, you may provide us your name, a username, a password, phone number, email address, and mobile advertising ID (IDFA, Google Advertising ID or other identifiers), and other information that helps us confirm that it is you accessing your Account. You may also choose to upload a picture for your Account. We may do this through in-game dialog boxes, which you may choose to skip. If you sign into the Services with Facebook Connect we will collect information that is visible via your Facebook account such as: (1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4) list of Facebook friends. Your Account may be used to publicly identify you as part of social features of the Services, which may include user-to-user interaction, chat or messaging functionality, public leaderboards, head-to-head competition, and other similar features. Your Account username will be public and will be shown to other users, but will only permit access to information that is considered public or that you have designated as public in your user profile settings.
We may also offer you the ability to import your contacts or manually enter e-mail addresses so that you can locate your contacts and invite your contacts to join you in the Services. We will store those contacts for purposes of helping you and your contacts make connections through our Services.
Technical and Usage Information
When you access our Services, we may collect (i) certain technical information about your mobile device or computer system, including IP Address, mobile advertising ID (IDFA, Google Advertising ID or other identifiers), and the version of your operating system; and (ii) usage statistics about your interactions with the Services. In certain Services we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, character name, or e-mail address. We may also access your contacts to enable you to invite friends to join you in the Services. This information is typically collected through the use of third-party mobile device software development kits. We may occasionally send you push notifications through our Service to send you Apps updates and other service-related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.
Email and Electronic Wallet Address
We may collect your email address and your electronic wallet address to facilitate use of the Services.
When you order a digital blockchain collectible through the Services, we collect some purchase information which is comprised of transaction history, including what you have purchased, the price, and the date. Your in-app purchase transactions are processed by third-party payment processors. The third-party payment processors will collect your name, phone number, e-mail address, mailing address, billing address, and complete credit card information that enables them to receive your payment. Our payment processing service provider may also retain this information to enable you to purchase additional items through our Services without having to re-enter it each time. Please note third party payment processors do not share your financial information, like credit card numbers, with us. Please note that purchases from third parties may also be subject to additional policies.
Information Collected by Customer Support
When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your game-play or activity on the Services, and your user name. We will also store the correspondence and any information contained within.
Our primary goals in using your information are to create your account, provide Services to you, troubleshoot, improve and optimize our Services, contact you, conduct research and create reports for internal use. We use information collected through our Service for purposes described in this Policy or disclosed to you in connection with our Service. For example, we may use your information to:
- Create accounts and allow users to use our Services;
- Identify and suggest connections with other Apps users;
- Operate and improve our Services;
- Understand you and your preferences to enhance your experience and enjoyment using our Services;
- Respond to your comments and questions and provide customer service;
- Provide and deliver products and services you request;
- Deliver advertising and marketing and promotional information to you;
- Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
- Communicate with you about promotions, contests, rewards, upcoming events, and other news about products and services offered by us and our selected partners;
- Conduct and administer contests promoted by us;
- Enable you to communicate with other users; and,
- Link or combine it with other information we get from third parties to help understand your preferences and provide you with better services.
We may share information we collect or derive with third parties for the following purposes:
- With service providers that perform services on our behalf or enhance our Services, including hosting services, payment processing, customer service and to assist us in our marketing efforts;
- With advertising partners like advertisers, ad exchanges and other ad technology companies that require the data to select and serve our relevant advertisements to you and others, and assist us in our marketing efforts;
- With our affiliates;
- We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties;
- With professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us;
- When we have a good faith belief that we have to disclose the information in response to lawful requests by public authorities, including law enforcement or legal process purposes;
- To satisfy any applicable laws or regulations;
- When we believe in our sole discretion that our Services are 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;
- To protect our or a third party’s legal rights, investigate fraud, or to defend against a legal claim;
- With acquirers and other relevant participants (and their advisors) in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Vessel or our affiliates (including, in connection with a bankruptcy or similar proceedings); and
- With your specified recipients. We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction.
We do not share your personal information except as approved by you or as described herein. Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information as required by applicable data protection laws.
We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage.
However, no security system is impenetrable, and we cannot guarantee the security of your personal information. Any transmission is at your own risk.
We retain your personal data for as long as needed to provide you Services, unless we are required by law to delete or if we accept your request to delete the information. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements
We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. In the event that we learn that we have collected personal data from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us.
We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal data, as described in this Policy.
Accessing and Correcting Your Personal Information. You may request to access the personal data that we hold about you. We may need to ask you to provide certain information to make sure you are who you claim to be. If you find the information on your account is not accurate, complete or updated, then please provide us with the necessary information to correct it.
Withdrawing Your Consent. You may withdraw your consent to the processing of your personal data. Exercising this right will not affect the lawfulness of processing based on consent before withdrawal.
Erasing or Restricting Access to Your Information. You may request to delete or restrict access to your personal data. We may postpone or deny your request if your personal data is in current use for providing Services or for other legitimate purposes, in which case we will let you know if we are unable to do so and why.
Transferring your Personal Data (Otherwise known as Your Right to Data Portability). You have the right to receive your personal data that you have provided us in a structured, commonly used and machine readable format and the right to transmit that data to another party of your choice, where technically feasible. However, this right shall not apply where it would adversely affect the rights and freedoms of others.
Right to Make Complaint. If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
If you have any concerns about the way we process your personal data or would like to make any of the above requests regarding your data, you are welcome to contact our data protection officer at [email protected] or write to us at the address set forth in the “Contact Us” section. We will look into your request and make good faith efforts to resolve any concern you may have.
On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide the Services to you. We may also process your personal data to respond to your inquiries concerning our products and services.
On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.
Additionally, we process your personal data when necessary to do so for fraud prevention, improving our network and services, and marketing our services to advertisers and publishers; where these interests are not overridden by your data protection rights.
If the processing of personal data is necessary and there is no other lawful basis for such processing, we will generally ensure that consent has been obtained from you. You have the right to withdraw your consent to processing of personal data at any time.
For questions about data processing, please contact our Data Protection Officer. Visit the “Contact Us” section below for contact information.
These additional provisions for California consumers apply only to individuals who reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Rights Act of 2020 (“CPRA”) provide additional rights to know, access, correct, delete, and opt out, and requires “businesses” collecting or disclosing personal information to provide notice and a means to exercise those rights.
Your California Privacy Rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties to whom we disclose Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Correct. You can request that we correct any information on your account that is not accurate, complete, or updated by providing us with the necessary information to correct it.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out of sales. You can opt-out of any sale of your Personal Information.
Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
Right to Opt Out of Information Sales
We do not “sell” information about our users as most people would commonly understand that term. However, consistent with common practice among companies that operate online, as part of Vessel Earn, we do “share” information in the sense that we allow certain third-party advertising networks and other third-party businesses to collect and disclose your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our Vessel Earn app or otherwise engage with us. These third parties use your personal information for purposes of analyzing and optimizing our Service and advertisements on our websites, on other websites or mobile apps, or on other devices you may use, to personalize content or to serve ads that may be more relevant to your interests, and to perform other advertising-related services such as reporting, attribution, analytics and market research.
How to Exercise Your Rights
To exercise your right to know, right to access, right to correct, right to delete, right to opt out of information sales, or any other right you may have under applicable law, please submit a request by emailing [email protected] or by writing to us at the physical address in the “Contacts” section below, with the subject line “California Rights Request” and specifying which right(s) you would like to exercise (for example, your right to delete). We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
We aim to respond to a consumer request within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
Financial Incentive Notice.
Vessel Earn is a reward program we offer where users can earn the virtual currency Vessel Coin by viewing advertisements on their mobile phone. Vessel Coin can be spent in the Vessel marketplace or converted to cash and withdrawn at any time in the Vessel Earn app. In order to sign up for Vessel Earn, users must provide their phone number. Users can receive additional Vessel Coin by providing their email address and/or mobile advertising ID. This data will be used to show more relevant ads to the user.
Under California law, the provision of additional Vessel Coin may be considered a financial incentive provided in exchange for the collection and retention of personal information. While we do not assign a monetary value to the data we collect through the Vessel Earn services, based on our reasonable estimate, the value we receive from your personal information is reasonably equal to the value of the financial incentive we provide to users of Vessel Earn. The method for calculating the cost would include costs associated with facilitating and managing the incentive or program, investing in enhancing user data and leveraging the relationship with users, and all other costs reasonably related to the incentive or program.
Participation in Vessel Earn is always optional, and you can terminate program participation at any time by deleting the Vessel Earn app or by contacting us at [email protected]
We may update this Policy to reflect changes to our data and information privacy practices. If we make any material changes we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices. Please note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required.
Our Data Protection Officer
You may contact our Data Protection Officer at [email protected] or at the address below for further information.
Data Protection Officer
1100 Page Mill Road
Palo Alto, CA 94304
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