Last updated: June 11, 2021
Effective: December 08, 2021
NOTE: THIS WEBSITE AND THE SERVICES PROVIDED HEREIN DO NOT OFFER "REAL MONEY GAMBLING" OR AN OPPORTUNITY TO WIN REAL MONEY OR PRIZES BASED ON THE OUTCOME OF PLAY.
The games and other activities offered on the Website and Apps are referred to in this Privacy Policy as the "Services".
Please read this Policy carefully before accessing the Website, the Apps or using our Services as it provides important information about how we collect, store, use and disclose your personal and other information when providing our Services to you or when you access the Website or Apps. You should also review the TERMS OF USE for important information about your use of the Website or Apps and our Services. DoubleDown Website and Apps are managed and operated by DoubleDown Interactive, LLC ("DoubleDown" or "our" or "we" or "us"). Visitors to the DoubleDown Website or Apps and users of the Services are referred to as "you."
Passive Information
Passive information refers to information that is automatically collected from your device(s) when you access the Website or Apps and use the Services. DoubleDown may collect passive information such as your device ID, IP address, referral data, browser type, browser language, platform type, type of mobile or other computing device, and geographical data, such as zip code and geographic location. Your browser or device typically sends passive information to our servers without your intervention whenever you visit our Website or Apps and use the Services. For example, your browser or device may tell us your IP address (which may tell us generally where you are located) and the type of browser and device you are using. When you visit our Website or Apps, your browser may also tell us information such as the page or link that led you to our Website or Apps and, if applicable, the search terms you typed into a search engine that led you to our Website or Apps.
Cookies
While you are using the Services, we may seek to place a "cookie" (a small data file) or other tracking technology on your mobile device, computer or other participating device. If you access our Website, Apps or Services via a Partner Site, the Partner Site may also place cookies on your device as permitted by the terms of the agreement and your privacy settings with the Partner Site. Cookies placed by us are not used to obtain any personal data, and the information that is tracked is used only for internal purposes, such as to improve the Services. If you prefer not to accept cookies, you can set your web browser on your computer or device to reject them or to alert you before one is placed. Be advised, however, that some of our features and services may not function properly if you disable cookies.
Personal Information
Personal information, which is sometimes referred to as personally identifiable information, means information that is specific to you and can be used to contact or identify you. Unless you are using the Services on a guest basis, you must have a valid, active Facebook account to use and access the Services. Accordingly, we receive from Facebook certain categories of personal information about you that you authorize Facebook to disclose, such as your user name, date of birth, friend list, email address and profile picture, or you may voluntarily disclose information such as your gender or your play preferences to us through your use of the Services. Any information directly collected through your Facebook account and shared with us will be imported, used and stored in a manner consistent with the Facebook Platform Policy applicable to developers in effect at the time of collection (see HTTPS://DEVELOPERS.FACEBOOK.COM/POLICY/) and in compliance with any specific privacy settings set by you of which we are aware.
We may also collect certain categories of personal information from vendors that help us to operate the Website and Apps and provide services such as processing credit card payments and sending emails on our behalf. For example, we may receive confirmation that you have made a payment by credit card and other information related to any of your gaming transactions associated with your use of the Services. To help keep our databases current and to provide you the most relevant content and experiences, we may combine personal information from you with information from public sources and our trusted partners, in accordance with applicable law and this Privacy Policy.
Please note that because a third-party vendor manages your purchases of virtual currency for use the Services, we do not have access to your credit card or billing information. Be advised that this Privacy Policy does not apply to this and other third-party vendors.
We use Google Analytics to help us manage and improve the Websites and Services. For more information on how Google Analytics collects and processes data, see www.google.com/policies/privacy/partners/. Google provides a Browser Add-On that allows you to opt-out of Google Analytics by downloading and installing the add-on for your web browser, available at: https://tools.google.com/dlpage/gaoptout.
DoubleDown Online Advertising
DoubleDown utilizes online advertising, including displaying DoubleDown advertisements to you across the Internet on websites and in applications. We collect information about which of our advertisements are displayed, which advertisements are clicked on, and on which web page the advertisement was displayed.
Third Party Advertising
DoubleDown permits third parties to place advertisements on our properties, including our Website, Apps and the Services. When advertisers or advertising networks place advertisements on DoubleDown properties, they may collect or we may share the following types of information from within our properties:
• performance data (like the number of clicks on an advertisement);
• aggregated and/or de-identified information about you and other players collectively that is not intended to specifically identify you (like players between the ages of 30 and 40 who also own a Lamborghini);
• certain technical information (for example, IP addresses, non-permanent and anonymous device identifiers such as Apple Identifier For Advertisers (IDFAs), and Google Advertising ID);
• your social network ID;
• other contextual data about your game play (for example, games played and session length).
After clicking on a third-party advertisement, you may no longer be on a website or other property hosted by DoubleDown or the social network through which you are playing our games. Be advised that any personal information that you disclose in connection with a third-party online advertisement is not governed by this Privacy Policy. See below for information on how to opt-out of being served online advertising by third parties.
Offer Walls
DoubleDown games or their purchase pages may display an "Offer Wall" that is hosted by a third-party provider. The offer wall allows third party advertisers to provide virtual currency or other rewards to players in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These offers are not made by DoubleDown. These offers may be shown to you based on certain technical information, like your geographic area or de-identified demographic information. After clicking on one of these offers, you will no longer be on a site hosted by DoubleDown or the social network through which you are playing DoubleDown's games. To properly credit player accounts and to prevent fraud, a unique identifier, in some cases your social network ID or DoubleDown player ID, will be shared with the Offer Wall provider.
Use of Personal Information
DoubleDown will use personal information in the following ways:
• to fulfill your requests for our Services;
• to process and respond to your inquiries;
• to improve the Services, including diagnosis or problems with the Services;
• to help us better understand demographic characteristics of our users;
• to present advertising that is tailored to your interests;
• to offer you other opportunities that we think may be of interest to you.
Email and Text Messaging Marketing
In addition, DoubleDown may use personal information to communicate with you through email or text messages regarding new products, new features, product updates, enhancements, special offers, or promotions for the application services. These communications may also include offers from DoubleDown marketing partners, although such partners will not be provided with your personal information. Emails and text messages we send you may include a web beacon that tells us whether and at what time you have received or opened the email or clicked a link within the email. If you do not want us to use your personal information in this way, or to provide your personal information to third parties for their marketing purposes, please uncheck the appropriate box when you register or you can opt out by contacting us at [email protected]. You can also opt out by clicking on the “unsubscribe” button on the emails or texts from us or turning off the DoubleDown application notifications in the Services on your smartphone for texts. You can also unsubscribe to marketing messages at any time by clicking “unsubscribe” on the emails or texts that you receive from us or third parties.
Use of Passive Information
DoubleDown collects passive information for purposes of tracking and analyzing user preferences and trends in order to improve the quality and design of the Services and to create new features, promotions, and functionalities; for editorial and feedback purposes; for marketing and promotional purposes; for content improvement; and to customize the Services. This information may also be shared with advertisers and our business partners on an aggregated anonymous basis.
Use of Information Collected by Third Party Advertisers
The information collected may be used to:
• measure how effective advertisements are, to offer you targeted advertising in order to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising);
• undertake web analytics to analyze traffic and other player activity to improve your experience; and/or
• engage in activities such as frequency capping, attribution, conversion events, estimating the number of unique users, advertising fraud detection, and debugging.
Advertisers or advertising networks may collect the foregoing information through the use of tracking technologies like tracking pixels, browser cookies, and web beacons, and they may use a single tracking technology or multiple tracking technologies at the same time.
If you are interested in more information about online behavioral advertising and your choices to prevent third parties from delivering online behavioral web and mobile web advertising, you may visit the following websites:
United States:
• HTTP://OPTOUT.NETWORKADVERTISING.ORG/#!/ or
• HTTP://OPTOUT.ABOUTADS.INFO/?C=2#!/
European Union:
• HTTP://WWW.YOURONLINECHOICES.COM/.
Google, as a third-party vendor, uses cookies to serve ads on our site. Google's use of the cookies enables it to serve ads to your users based on their visit to our Websites and other websites on the Internet. Users may control their ad settings with Google at: https://adssettings.google.com/authenticated?hl=en.
Be advised that these opt-out tools are provided by third parties, not DoubleDown, and may not be available with respect to all online advertising that is presented to you. DoubleDown does not control or operate these tools or the choices that advertisers and others provide through these tools.
In addition, if you do not want to receive tailored in-application advertisements from third parties that relate to your interests in apps on your mobile device, 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 mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous "Advertising Identifier."
DoubleDown works with third-party vendors that help us provide the Services and operate the Website and Apps. These companies provide services such as processing credit card payments and sending emails on our behalf. In some cases, these companies have access to those portions of your personal information that are necessary in order to provide a product or service you have requested or in conjunction with your use of the Services. Unless we inform you otherwise, these companies are not permitted to use your personal information for any other purpose.
DoubleDown will not disclose your personal information to third parties except in the following circumstances: (1) We may disclose personal information in response to legal process; for example, in response to a court order or a subpoena; (2) We may disclose personal information in response to a law enforcement agency's request, or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, or as otherwise required by law; (3) We may disclose personal information if we are acquired by or merged with another company or in the unlikely event that DoubleDown is dissolved; (4) If we need to disclose your personal information to provide the product or service you have requested;; (5) We may disclose personal information to third parties for analytics purposes. Such personal information may not be used by the third party for any purpose other than this analysis; or (6) We may disclose personal information to our corporate affiliates.
Access to and Ability to Correct Personal Information
If you have questions or requests about this Privacy Policy, you may contact us by e-mail at [email protected]. Upon request via our online HELP CENTER, or e-mail, we will provide you a summary of your personal information, if any, retained by us. We will respond to requests to correct, amend, delete, update or delete personal information that is inaccurate within a reasonable timeframe. You can help us maintain the accuracy of your personal information by notifying us of any changes to your information. We will only send personal records to the e-mail address on file for the username associated with it.
Users may also modify, correct, change, or update their personal record through their Facebook account or request that their personal information be removed from our database.
Access Through Third-Party Sites
The privacy controls for your personal information that is transmitted to us from Facebook are managed through your Facebook account. You should carefully consider and establish your own privacy preferences for the Services through your Facebook account. We are not responsible for personal information, your profile, your location information or other information that you choose to disclose on the Services through synchronization with your Facebook account. Any personal data or other information obtained from your Facebook account will be shared publicly in the Services in accordance with the privacy settings you have applied to such data through your Facebook account.
If you access the Services through a third-party website ("Partner Site"), you should review the Privacy Notice and Terms of Use for the Partner Site. We do not have responsibility for any information you provide on the Partner Site except the information received from our Partner Sites in a manner consistent with this Privacy Policy and as permitted by the terms of your agreement and privacy setting with the Partner Site.
Opt Out
If you wish to change how the personal information that you provide to Facebook is used by us, including opting out of using your personal information to send promotional messages to you, you may change your settings on your Facebook account or contact us at [email protected].
In the event you want to opt-out of DoubleDown marketing emails or texts, you may do so at any time by clicking on the unsubscribe links located within each DoubleDown email or turning off the DoubleDown application notifications on your smartphone for texts. You can also contact as at [email protected] to opt out. Please note that opting out may affect your ability to receive information from DoubleDown or to have access to all of the Services.
You may also request that your DoubleDown account be disabled by emailing [email protected].
You may "opt out" of the use of your personal information for third party analytics purposes by emailing (using the same email address as when you registered) your request to [email protected]
Except as described herein, we will not trade, lease, exchange or sell your personal information with or to any other third party.
International Transfer of Information
We are located in the United States. Information that we collect will be stored and processed in the United States in accordance with this Privacy Policy. We may transfer and access personal information from around the world, including but not limited to the United States. This Privacy Policy shall apply even if we transfer personal information to other countries. By accessing the Website, the Apps or our Services, you consent to this transfer, processing, and storage of your personal information in the United States or other jurisdictions, including to jurisdictions in which the privacy laws may not be as comprehensive as those in the country where you reside. Note that your personal information may be available to the United States government or its agencies under legal process in the United States.
Access to and Ability to Correct Personal Information
For residents of the European Economic Area (EEA), we advise that your personal information will be transferred to and processed in the United States, which has data protection laws that are different than those in your country and may not be as protective. The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR.
Our legal basis for collecting and using your personal information or information is to do so with your consent; where we need the personal information for performance of a contract, or where the collection and use is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question. If we collected your Personal Information with your consent, you may withdraw your consent at any time.
Residents of the EEA have the right to:
• Access your personal information;
• Delete, or request deletion of, your personal information;
• Object to or restrict processing of your Personal information;
• Request portability of your Personal information;
• Complain to your local data protection authority at any time;
• Object to automated decision making; and
• Update your personal Information.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal information conducted in reliance on lawful processing grounds other than consent.
If we ask you to provide Personal information to us to comply with a legal requirement or enter into a contract, we will inform you of this and let you know whether providing us with your Personal information is required and if not, the consequences of not sharing your personal data with us.
Similarly, if we collect and use your Personal information in reliance on our or a third party's legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.
We endeavor to apply suitable safeguards to protect the privacy and security of your Personal information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also take steps to minimize the risk to your rights and freedoms by not collecting or storing sensitive or special categories of Personal information about you.
If you are a Canadian resident, you may withdraw consent, request information about our collection, use and disclosure of your Personal information, and request information on our policies and practices relating to disclosure of information to our service providers.
To withdraw consent or exercise these rights, please:
Contact us via email at [email protected];
or Adjust your preferences through the Account preferences (if available).
UK and EEA Privacy Representative
In accordance with Article 27 of the GDPR, VeraSafe, LLC (“VeraSafe”) has been appointed as DoubleDown’s representative in the United Kingdom and in the EEA for data protection matters. If you are located within the United Kingdom or EEA, VeraSafe can be contacted related to the processing of personal data by DoubleDown on the App. To make such an inquiry, please contact VeraSafe using the contact form available at: https://verasafe.com/public-resources/contact-data-protection-representative. For users outside the EEA and UK, email us at [email protected] for privacy questions.
To contact VeraSafe via telephone or mail, please use the information below, respective of your location:
For users in the United Kingdom:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London, SE1 7TL
United Kingdom
Telephone: +44 (20) 4532 2003
www.VeraSafe.com
For users in the European Economic Area:
VeraSafe Ireland
Unit 3D North Point House
North Point Business Park New Mallow Road
Cork T23AT2P
Ireland
Telephone: +420 228 881 031
www.VeraSafe.com
You may also contact DoubleDown on privacy matters via email at [email protected].
California Do Not Track Disclosures
The California Online Privacy Protection Act (“CalOPPA”) requires that online privacy notices disclose how a site responds to "Do Not Track" signals ("DNT"). We currently do not honor DNT signals.
California “Shine The Light”
If you are a California resident, California Civil Code Section 1798.83 (“Shine-The-Light” law) permits you to request information regarding the disclosure of your personal information by us, or our subsidiaries or affiliates, to a third party for the third party’s direct marketing purposes. To make such a request, please contact us as provided below. Except as may be provided in this Privacy Policy, we do not trade, sell, lease or otherwise provide any personal information regarding our users to any third parties for their direct marketing purposes.
California Consumer Privacy Act (“CCPA”)
The California Consumer Privacy Act (CCPA) gives California consumers enhanced rights with respect to their personal information that is collected by businesses. First, California consumers may opt out of having their personal information sold to other persons or parties. Second, they can request to know:
What specific pieces of information a business has collected about the consumer;
Categories of personal information it has collected about the consumer;
Categories of sources from which the personal information is collected;
Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
The business or commercial purpose for collecting or selling personal information.
Third, California consumers can request that a business delete personal information about the consumer that a business has collected from the consumer.
DoubleDown may be considered a covered business under the CCPA as it collects and processes the personal information of California consumers. This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the Act.
DoubleDown does not presently sell any personal information to third parties for any purpose.
To make a “request to know” or “request to delete” your personal information, send us an e-mail at the addresses below corresponding to the app of which you are inquiring. Please put either “Request to Know” or “Request to Delete” in the subject heading of your email. For more information on how to submit data privacy requests, please see this link.
DoubleDown Casino - [email protected]
DoubleDown Fort Knox- [email protected]
DoubleDown Classic Slots - [email protected]
Ellen’s Road to Riches - [email protected]
We will confirm receipt of your request within 10 business days. We must provide the requested information or delete your personal information within 45 days of receipt of your request, but we can use up to an additional 45 days if we let you know that additional time is needed.
Before responding, we must verify that the person making the request is the person about whom we have collected their personal information. Therefore, we may ask you to provide certain, limited personal information, such as your name and email address to verify and match your identity with our records and systems. If you have an account with us, we may ask that you verify your identity through our standard account authentication process. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months. There may be cases where we do not have any personal information about you or we are not able to verify your identity for matching purposes. Deleting your personal information may result in the closing of your account and inability to access the Services. However, you can always re-register at any time.
Job Applicants: We collect the following categories of personal information regarding job applicants:
Personal and online identifiers (such as first and last name, email address, cellphone number or unique online identifiers)
Categories of information described in Section 1798.80(e) of the California Civil Code (such as physical characteristics or description, social security number, driver’s license or state identification number, address, insurance policy number, and bank account number)
Characteristics of protected classifications under California or federal law (such as race or gender)
Internet or other electronic network activity information (such as browsing history, search history, interactions with a website, email, application, or advertisement)
Geolocation information
Professional or employment-related information
Education information
Inferences drawn from the above information about your predicted characteristics and preferences
Other information about you that is linked to the personal information above
We use and disclose the personal information to process, evaluate and communicate with job applicants about their application and qualifications for the position applied for, to check your references and to communicate with you about other jobs for which you may be qualified.
Note, however, the CCPA does not currently provide that job applicants may submit either Requests to Know or Requests to Delete regarding what personal information is collected about them.
(Residents of Nevada and other states may also have similar rights to request information about or delete their personal information. To inquire about exercising these rights, please contact us at [email protected].)
Security
We will only collect and use personal information in accordance with this Privacy Policy and to the extent deemed reasonably necessary to serve our legitimate business purposes. We will maintain appropriate administrative, technical, and physical security safeguards to ensure the security, integrity, accuracy and privacy of the information you have provided. Please be aware, however, that no information system is totally secure, and therefore we cannot guarantee against all potential security breaches. While we will use reasonable security and monitoring controls in accordance with general industry standards to secure information you provide to us consistent with our legal requirements, we cannot guarantee that such information will not be unlawfully or illegitimately obtained by unauthorized parties.
Third Party Web Sites
The Services may contain links to other websites, including those of advertisers. DoubleDown is not responsible for the security measures, privacy practices, or content of third-party web sites. Once you leave our Website or Apps using any of these links, although no warning will be displayed, the privacy practices mentioned in this Privacy Policy do not apply. You are advised to examine the privacy policies of these third- party sites before providing any personal information.
Age Restrictions
Our Services do not knowingly solicit information from, or market to, any person under the age of twenty-one (21). In particular, consistent with the Children's Online Privacy Protection Act, we will not knowingly collect any information from children under the age of thirteen (13). If you become aware that a member of your family or any person under your responsibility has provided us with information without your consent, please contact us using the contact information as indicated in this Privacy Policy in order to delete that information as quickly as possible.
Changes to the Privacy Notice
We may revise this Privacy Policy at any time as we may deem appropriate and consistent with the principles described herein, our evolving business needs, or changes in applicable laws or regulations. If we make any changes to this Privacy Policy, we will update the "Last updated" date below. You are advised to consult this Privacy Policy regularly for any changes, and your continued use of this Website, the Apps and our Services after such changes have been made constitutes informed consent of those changes.
If you have any concern about this Privacy Policy or our privacy practices, please contact us at:
Double Down Interactive
605 Fifth Avenue South, Suite 300
Seattle, WA 98104 USA
Or email us at [email protected]
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