Privacy policy
Microsoft Word – 21-03-12 Privacy Policy
Magic Marlo, LLC and its subsidiaries (collectively “Magic Marlo”) respects the privacy of its players and online visitors; and recognizes the importance of providing a secure environment for them. We have adopted a company-wide online Privacy Policy (“Privacy Policy”) that explains how we collect, store, and use the information you provide us. This Privacy Policy details how Magic Marlo safeguards the privacy of its online visitors and does not apply to information that may be collected by Magic Marlo offline, including but not limited to employment related interactions. When you click a link to other sites from a Magic Marlo website, this Privacy Policy does not apply to, and cannot control the activities on, those other sites. We highly recommend that you read the privacy policy of any third party website you may be directed to before providing any personally identifiable information.
The personal information you provide may be transferred to, stored, and processed within the United States or other countries where Magic Marlo maintains facilities or business operations.
By using this website and/or any of Magic Marlo’s online products or services, you acknowledge the terms of this Privacy Policy. If you object to anything described in this Privacy Policy, please do not use our websites or play our games. This Privacy Policy may change from time to time, so please check back periodically to ensure that you are aware of any changes. If we make a material change to this Privacy Policy, we will notify you by posting the change on our websites or in this Privacy Policy and, if necessary, give you additional choices regarding such change before the change becoming effective. Your continued use of the Magic Marlo websites will signify your acceptance of these changes.
1. What personal information is collected and how do we use it?
Information collected from you. If an online visitor submits information to Magic Marlo, it will usually be through either: (1) the purchase of goods or services though our online platforms, (2) account registration or registration for online game participation, (3) player match-up services, (4) message boards or forums, (5) the playing of a game or use of a service, (6) surveys, (7) customer service or technical support. Personal information collected may include your name, home address, phone number, and/or e-mail address. We do not require this information to gain access to our services, however, you will not be able to utilize certain products, services, or features that require registration unless such information is provided.
Visitors purchasing products or services may have to provide additional information such as a valid credit card number, expiration date, and shipping and billing addresses.
For some activities, we may ask you to create a username and password and/or to provide other personal and non-personal information including but not limited to your age, date of birth, gender, and/or game and platform preferences; and, we may combine such information with other personal and/or non-personal information.
In specific cases, we may ask you to provide a copy of a document or government-issued ID to verify your identity, location, and/or account ownership. When photo identification is provided
to us, it is normally deleted as soon as the identification verification is complete or after 30 days if the case was not addressed within this period of time, unless otherwise required to establish, defend, or exercise our legal rights.
Any communications made using a product or service should not be considered private. Magic Marlo may monitor and/or record your communications (including without limitation chat text) when you are using a product or service or for enforcement of Magic Marlo’s terms of use or any other reason in Magic Marlo’s sole discretion. You hereby provide your irrevocable, express consent to such monitoring and recording. You acknowledge and agree that you have no expectation of privacy concerning the transmission of any user generated content or communications, including without limitation chat text. Because communications may be viewed by other users, users should avoid revealing any personally identifiable information in those communications.
Information Collected Automatically. In addition, your web browser or app may transmit certain geographic information or information regarding your device (capabilities, game data processing, etc.) to Magic Marlo. Magic Marlo may use this information to generate aggregate statistics about our user community. In addition, Magic Marlo may use such information for security, system integrity (the prevention of hacking, cheats, etc.), or enforcement purposes. Magic Marlo may also collect IP information, which it may use to infer your approximate location.
Information collected from third parties (our vendors, affiliates, and business partners). Magic Marlo may enhance or merge the personal information collected via a Magic Marlo app or website with data from third parties in order to update your contact information, perform market analysis, or improve our products, services, or systems. If you register an account using your Facebook credentials, the following information may be collected: (1) your first and last name and other information made publicly available by you, (2) your friends list, and (3) the email address associated with your account. Similar data exchanges will occur when you link your Magic Marlo account with other companies, such as Google, Unity, Ironsrc, and Apple.
How we use your information. The personal information you provide Magic Marlo, and that Magic Marlo collects automatically, will allow us to provide our games and services, fulfill your product or service order; alert you of new products or services, features, or enhancements; handle/route your customer service or technical support questions or issues; and/or notify you of upgrade opportunities, contests, promotions, or special events and offers. We also use this information to secure our services and users, to prevent cheating and fraud and to enforce our agreements with you.
Additionally, communications made using a product or service should not be considered private. By using the speech to text feature in voice chat, you understand that your communications may be used for transcription of speech to text, including for accessibility purposes. We do not retain the chat transcription after you end the session and close the chat window. However, by using voice or text chat, you understand that your communications may be monitored and/or recorded for accessibility, toxicity analysis (e.g. toxic player behavior), to prevent cheating and
fraud, or for enforcement of Magic Marlo’s terms of use. You acknowledge and agree that you have no expectation of privacy concerning the transmission of any user generated content or communications, including without limitation chat text. Because communications may be viewed by other users, users should avoid revealing any personally identifiable information in those communications.
Last, we may use your personal information for internal marketing or demographic purposes and so we can adapt our products and services to better suit your needs. We do this to better understand and serve our customers.
Additional Information (California Collection Notice). Below we identify each category of personal information that we have collected in the last 12 months. For each category of personal information we have collected, we also identify (i) the source(s) from which the information was collected; (ii) the purpose(s) for which it was collected; and (iii) the categories of third parties, if any, with which it has been shared.
Each category of information is collected for the purposes listed below and (1) to provide our games and services, (2) for fraud prevention and legal purposes, (3) to secure our services and users, including to prevent cheating and bad behavior, and (4) for audit purposes.
Categories of Personal Information
PERSONAL IDENTIFIERS, for example, account username, name, email address, phone numbers, home address, and social media accounts
Categories of Source(s)
You, both directly and through your use of our games and services
You, both directly and through your use of our games and services Additional Purposes for Collection
You, both directly and through your use of our games and services Additional Purposes for Collection
You, both directly and through your use of our games and services Additional Purposes for Collection
USER GENERATED CONTENT, for example information submitted, chat, or message boards Categories of Source(s)
You, both directly and through your use of our games and services Additional Purposes for Collection
Based upon the personally identifiable information you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account.
3. Who is collecting your information?
When you are asked for information while in a Magic Marlo game or service, you are providing that information to Magic Marlo, LLC and its subsidiaries unless specifically stated otherwise in that location or in this Privacy Policy.
In addition, some services are provided with partner companies. For example, your information may be provided to third party advertising networks in order to provide targeted advertising to you. If you do not want your information shared, you can choose not to allow the transfer of information by not using that service or by not providing any information. Please be aware that we cannot control all of the activities of third parties to whom we provide data, and while we cannot guarantee that they adhere to the same privacy and security procedures as Magic Marlo, we will take reasonable steps to assure that these third parties will sufficiently protect personal information.
4. With whom may your personal information be shared?
Magic Marlo will share your personal information with third parties only in the ways that are described in this Privacy Policy. We may share some of our players’ game data with our community of developers who create applications and websites that benefit our player community.
We reserve the right to disclose your Information if we are required to do so by law. We may also disclose your information to law enforcement or in civil litigation in connection with the enforcement of our rights or your legal obligations.
We may share your information with vendors Magic Marlo engages to perform services for Magic Marlo (for example, platform providers, survey providers, billing, consumer services support, information technology hardware and software). In these situations, a contract between Magic Marlo and the vendor shall control such disclosure, the vendor must agree to reasonable levels of security regarding your data and the vendor will not be permitted to use your data except as required for the performance of those services for Magic Marlo. If your data is anonymized, the vendor may use it for other purposes.
As with any business, your personal information is also an asset of Magic Marlo and will become part of our normal business records. As such, we may also disclose your personal information to a third party if we decide to sell a line of business to that third party, so you can continue to receive service and information in connection with that line of business with as little disruption as possible. Similarly, in the event of a merger, acquisition, reorganization, bankruptcy, or other
similar event, your personal information may be transferred to Magic Marlo’s successor or assign.
5. What choices do you have regarding the collection, use, and distribution of your personal information?
You have choices over the Information provided by you and by other sources, and how Magic Marlo uses that Information. You can exercise your choices by updating your preferences at any time and also by managing your settings in your account, on your devices and third party accounts.
Your Choices About Information Provided by You
If you do not want to provide Magic Marlo with personal information, then you can choose not to provide it. If you choose not to provide us with personal information, we may not always be able to provide you with the Magic Marlo product or service you want. For example, without providing an email address, you cannot create an account.
Your Choices About Information Provided by Third Parties
You may control how third parties collect and share your Information by changing your preferences or opting out of collection directly with those third parties. Before disclosing Information to third parties, we recommend you check their respective privacy policies for further details.
Your Choices About Magic Marlo Using Your Information
You can exercise choices over how Magic Marlo uses your personal information and update your preferences at any time. To disable selected Cookies from collecting information relating to the effectiveness of advertising campaigns or analytics data and from serving you with personalized advertising, please see our Cookie Policy.
6. California Residents: Your California Privacy Rights
California Consumer Protection Act
Without being discriminated against for exercising these rights, California law gives its residents the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information (if we sell such information), subject to certain restrictions. For security purposes, we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. You also have the right to designate an agent to exercise these rights on
your behalf. This section describes how to exercise those rights and our process for handling those requests.
Right to Know:
If you are a California resident, you may submit, free of charge, but no more than twice in a 12- month period, a verifiable request for the following information:
• The specific pieces of personal information we have about you;
• The categories of personal information we collected, sold, or disclosed for a business purpose about you within the last 12 months;
• The categories of sources from which the personal information was collected; • The purposes for which the information was collected or sold; and
• The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.
If possible, we will provide this information to you in a readily usable format that allows transmission to another entity. The easiest way to submit a request and receive your report is to mail your request to Magic Marlo Entertainment, 3501 N. Southport Avenue, Suite 333, Chicago, Illinois 60657, USA, Attention: California Data; or email support@solitairefreezewar.com. If we need additional information to verify your identity, we will contact you to request that information, which may include personal information about you or information about your past purchases or use of Magic Marlo’s products or services. If we deny your request, even if only in part, we will explain the reason in our response.
Right to Data Portability:
Data portability is the ability to move data from one company to another (for instance, when you transfer your mobile phone service to another carrier). While this right is not very applicable to Magic Marlo’s current business, we will provide you with an electronic file with your most basic account information, should you request it. The easiest way to submit a request is to mail your request to Magic Marlo Entertainment, 3501 N. Southport Avenue, Suite 333, Chicago, Illinois 60657, USA, Attention: California Data; or email support@solitairefreezewar.com.
Right to Delete:
If you are a California resident, you may submit a verifiable request for us to delete the personal information we have collected about you. We may retain personal information necessary to: (a) protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality, (c) necessary for us, or others, to exercise their free speech or other rights, (d) comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. Additionally, we need certain types of
information so we can provide our games and services to you. The easiest way to submit a request for deletion is to mail your request to Magic Marlo Entertainment, 3501 N. Southport Avenue, Suite 333, Chicago, Illinois 60657, USA, Attention: California Data; or email support@solitairefreezewar.com. If we need additional information to verify your identity, we will contact you to request that information. If we deny your request, even if only we will explain the reason in our response.
Right to Opt-Out:
California residents may opt out of the “sale” of their personal information, as defined by the CCPA. This does not include when:
• You direct us to disclose your personal information or use us to interact with a third party and the third party does not sell the personal information;
• We use or share an identifier solely to alert a third party you have opted out of the sale of your personal information;
• Your personal information is transferred as an asset as part of a transaction in which the third party assumes control of all or part of our business, in which case the third party would have to tell you in writing if it materially changes how the information is used or shared; and
• We use or share your personal information under a written contract with a service provider necessary to perform a business purpose. Here, the service the service provider performs is on our behalf, and our written contract prohibits it from keeping, using or disclosing your personal information for any purpose other than for the specific purpose identified in the contract.
In these cases, the disclosure of your personal information would not be considered a “sale” under CCPA. We use and share your information as described in this privacy policy and do not believe this use and sharing is a sale as defined by the CCPA. We have not sold personal information about you in the last 12 months and currently have no plans to do so in the future.
Right to be Free from Discrimination:
We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
Authorized Agents:
If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
California Shine the Light Law
Since 2005, California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to
third parties for their direct marketing purposes. We do not share our customer’s personal information with unaffiliated third parties for their own direct marketing purposes. For inquiries regarding our disclosure policy, please write us at: Magic Marlo Entertainment, 3501 N. Southport Avenue, Suite 333, Chicago, Illinois 60657, USA, Attention: California Data. We will be happy to honor your request.
Privacy Rights for California Minors in the Digital World
Since January 1, 2015, California Business and Professions Code Section 22581 permits California residents under the age of 18 to have the right to view, correct and request the removal of content or information they have posted to the message boards or forums. This request can be made by contacting us at Magic Marlo Entertainment, 3501 N. Southport Avenue, Suite 333, Chicago, Illinois 60657, USA, Attention: Minor Data.
Residual copies of content and/or information that have been deleted may remain on our backup servers or third party servers. We do not have to remove posted content or information if it has been rendered anonymous. We may retain your Information to resolve disputes, enforce our user agreements, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose. Additionally, we do not have control over third parties (e.g., other users) who may have copied or reposted the content or information.
Do Not Track
California Business and Professions Code Section 22575(b) (as amended effective January 1, 2014) permits our customers who are California residents to be informed as to how Magic Marlo responds to Web browser “Do Not Track” settings. As Do Not Track is a standard that is currently being developed, Magic Marlo does not take actions to respond to Do Not Track settings, and instead we adhere to the standards set out in this Privacy Policy. To find out more about Do Not Track you may find the following link useful: http://www.allaboutdnt.com/ .
7. Privacy Information for Nevada Residents
Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. At Magic Marlo, we do not sell your personal information.
8. Children and Parents
Children Under 13
Once a child states that his/her age is under 13, they will be unable to register an account with
us. We do not knowingly collect or store any personally identifiable information from children under 13. If parents believe that we have unintentionally collected their children’s’ personal information, they may request the deletion of the information by contacting us at Magic Marlo Entertainment, 3501 N. Southport Avenue, Suite 333, Chicago, Illinois 60657, USA, Attention: Minor Data.
9. What is Live Play?
Certain Magic Marlo games feature “Live Play,” which allows you to play with other players outside of the region associated with the creation of your Magic Marlo account. This feature requires that some or all of the personal information that you provided when you created your Magic Marlo account be transferred to servers operated or utilized by Magic Marlo in other regions.
10. What are tracking technologies and how are they used?
As is true with most apps and websites, we gather certain information automatically and store it in log files. This information may include a unique identifier such as your Internet Protocol (IP) address and non-personal information such as your browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you, to improve marketing, analytics, or website functionality.
Magic Marlo and our partners, such as marketing partners and analytics providers, may use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used in analyzing trends, administering the app and websites, tracking users’ movements around the apps and websites, and gathering demographic information about our user base. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
We use cookies for various purposes including to remember users’ settings (e.g. language preference), and for authentication. If you reject cookies, you may still use our websites, but your ability to use features or areas of our websites may be limited.
11. What are Internet Protocol addresses?
An Internet Protocol (“IP”) address is the unique number assigned to your server or Internet Service Provider (“ISP”). Magic Marlo may track such IP addresses for system administration, to report aggregate information, site tracking, security purposes, or to prevent our servers from being abused.
12. What do you do to obtain a report about the personal information Magic Marlo holds about you or delete your personal information?
You may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the personal information we have about you. To obtain the report, send a request via mail to Magic Marlo Entertainment, 3501 N. Southport Avenue, Suite 333, Chicago, Illinois 60657, USA, Attention: Data Request; or email support@solitairefreezewar.com.
You may also submit a verifiable request for us to delete either: (1) your marketing information; or (2) your account and your marketing information. We may retain personal information to: (a) protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality, (c) necessary for us, or others, to exercise their free speech or other rights, (d) comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations. To submit a request for deletion, send a request via mail to Magic Marlo Entertainment, 3501 N. Southport Avenue, Suite 333, Chicago, Illinois 60657, USA, Attention: Data Request; or email support@solitairefreezewar.com.
13. How secure is your personal information?
Magic Marlo takes a range of security measures designed to protect your personal information and keep it confidential (unless it is non-confidential by nature, for example, publicly-available information like leaderboard rankings, scores, etc.). We also take steps to ensure that the personal information collected is protected from misuse and alteration. In addition, we request vendors who process personal information on our behalf to themselves take a range of security measures designed to help protect your personal information. However, the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. The complete security of any personal information collected, stored or used by us or our vendors cannot therefore be guaranteed.
14. Questions or Complaints
If you have questions or wish to file a complaint, please mail us at Magic Marlo Entertainment, 3501 N. Southport Avenue, Suite 333, Chicago, Illinois 60657, USA, Attention: Data Request; or email support@solitairefreezewar.com.
This Privacy Policy was last updated on February 21, 2021.