Privacy Policy | MobilityWare

Last Updated: February 2, 2023

APPLE ARCADE

This section applies if you are playing a MobilityWare app that is part of Apple Arcade.

Data. MobilityWare does not collect, access, or store any of your data as part of the normal operation of our Apple Arcade games.

iCloud. Our Apple Arcade games provide full support for Apple’s iCloud service. This means they automatically save some of your game information (such as progress, daily challenges, and current game state) in a special way that allows the iCloud service to access it. If you have iCloud enabled on your device, the iCloud service will send that data into the cloud, on your behalf. It will also pull that data back down so that you can continue your experience on any of your devices. This process never involves MobilityWare servers or storage, in any way. You can enable/disable iCloud through your device settings.

Customer Support. We want you to have the best experience possible. If you choose to contact customer support from within our Apple Arcade games, we will populate an email with information that will help us solve your problem. This email will show all the information we are sending, in human-readable text. You will have full control over what, when, and how the information is sent. As this email is outside of the normal operation of our Apple Arcade games, any data sent to MobilityWare is covered by all of the terms of the MobilityWare Privacy Policy.

Anonymized Data. As part of the Apple Arcade service, MobilityWare may periodically receive data from Apple about the general usage of our games. This data is anonymized, which means it cannot be connected to individuals in any way.

Children. Apple allows children to play Apple Arcade games. Fortunately, MobilityWare does not collect, access, or store any of your data as part of the normal operation of our Apple Arcade games. As a guardian, you can provide additional protection by restricting access to iCloud, email, or websites on your devices. Please note that our customer support team and the MobilityWare websites are outside the normal operation of our Apple Arcade games – they should never be accessed by children or minors. Please see the “Use By Minors” section for more information.

NOTICE

The Vegas Blvd Slots game and the MobilityWare Real World Rewards Program are being terminated on June 10, 2020. Starting May 10, 2020, you will no longer be able to purchase or earn Vegas Blvd Slots coins or other Vegas Blvd Slots Virtual Items, or accumulate additional Loyalty Points. All Vegas Blvd Slots coins or other Virtual Items, and Loyalty Points must be used or redeemed by June 10, 2020. All Loyalty Points not redeemed by June 10, 2020 will expire.

You can find our Terms of Service here, which is incorporated herein:https://mobilityware.com/terms-and-service

Your right to privacy is one of our primary concerns. This Privacy Policy applies whenever you play our games or otherwise access any of our other products, services, content and/or websitewww.mobilityware.com(together, our “Services”). This Privacy Policy describes how MobilityWare collects, uses and discloses information about you collected through our website and Services. BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING OUR SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT PLAY MOBILITYWARE’S GAMES OR OTHERWISE USE OUR SERVICES.

MobilityWare reserves the right to periodically modify this Privacy Policy. We encourage you to review the Privacy Policy from time to time for the latest information on our privacy practices. If we make any changes to the Privacy Policy, we will revise the date at the top of the Privacy Policy with an updated revision date. In case of material or significant changes, we may provide an additional notice (such as emailing you, or placing a notice on our website or in-game). Please note that your continued use of our Services will signify your acceptance of any updates to this Privacy Policy.

WHO WE ARE

MobilityWare develops and publishes games for mobile devices. “MobilityWare”, “we” or “us” refers to MobilityWare, LLC and its subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership and/or any of their agents, consultants, employees, officers and directors.

The terms “personal information” or “personal data” as used in this Privacy Policy shall mean any information that enables us to identify you, directly or indirectly, by reference to an identifier such as your name, identification number, location data, online identifier or one or more factors specific to you.

For the purposes of the EU General Data Protection Regulation 2016 (the “GDPR”), MobilityWare LLC is the “controller” and responsible for your personal information.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below:

– Email address: [email protected]
– Postal address: MobilityWare LLC, 440 Exchange, Suite 100, Irvine CA 92602
– Telephone number: (949) 788-9900

VeraSafe has been appointed as MobilityWare’s representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. VeraSafe can be contacted, in addition to MobilityWare, for matters related to the processing of your personal data only. To make such an inquiry, please contact VeraSafe using the details set out below:

– Online form: https://www.verasafe.com/privacy-services/contact-article-27-representative
– Postal address: VeraSafe Netherlands BV, Keizersgracht 555, 1017 DR Amsterdam, The Netherlands
– Telephone number: +420 228 881 031

CHANGES TO THIS PRIVACY POLICY

INFORMATION COLLECTION

Information You Provide

We collect information that you voluntarily provide MobilityWare, such as when using our Services or registering an account with us, participating in a promotion or survey, requesting customer support or otherwise communicating with us. The type of information that we may collect includes your first and last name, email address, geo-location, password, or other identifying information you choose to provide. We do not collect credit card information or government ID numbers.

Information We Collect Automatically

When you use our Services, we automatically collect information about you, including:

Device information: We collect device specific information when you access our Services from a mobile device, including your hardware model, operating system and version, unique device identifiers, device software platform and firmware, data about usage of our Services while connected to devices that you authorize us to integrate, geographical data and mobile network information, and other anonymous or aggregated data as reasonably required by MobilityWare to enhance our Services and products. We may on occasion match or combine the information automatically collected from your device with personal information we obtain from you or other sources, including publicly available databases or third parties from whom we have purchased data or that is already in our records. This sort of combined information may be used in the ways described in this Privacy Policy.
Use Information: We collect information about your use of the Services, including the type of browser you use, access times, pages viewed, game play activity, interactions with other players, your IP address and the page you visited before navigating to our Services

Information Collected by Cookies and Other Tracking Technologies: We, and our partners acting on our behalf, use cookies, web beacons, and similar technologies to collect information about the pages you view, your movements around our website, the links you click and other actions you take on our Services. We may also use this technology to gather demographic information about our user base as a whole. We may receive reports from our partners (e.g. Google Analytics) providing us with this collected information on an individual and aggregated basis based on your use of our Services. You can control the user of certain cookies at the individual browser value. You can learn how Google uses data when you use our partners’ sites or apps here. Please review your browser or device setting for more information. If you reject cookies, you may still use our website and Services, but your ability to use some features may be limited. Web beacons are electronic images that may be used in our Services or emails to help deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. For more information about how we use cookies and similar technologies, please see our Cookie Notice.

Information We Collect from Other Sources

We may also collect information from features and functions offered by other sources such as social networking sites like Facebook, Twitter or LinkedIn. These features may collect your IP address, pages you visit on our website, or set a cookie to enable the feature to function properly. Please note that these features are subject to the privacy policy associated with the third parties providing them. For example, if you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information, profile picture, phone number, email address, gender, date of birth, and friends list. We may process, use, combine, disclose, and retain such information in accordance with this Privacy Policy. In some instances, you may log in to our website or Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal information with us (such as your name and email address) and to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on our website or Services to your profile page to share with others within your network.

Subscription Terms

MobilityWare may use Apple Inc.’s billing software to process purchases of, and paid subscriptions to, MobilityWare Apps made through the iTunes Store. As a result, when arranging your purchase via your mobile device or through the iTunes Store, you may be asked to provide personal information to Apple Inc., such as your name, email address or zip code (for billing purposes). This information is collected via Apple as part of it’s subscription process. It is neither collected nor used by MobilityWare.

HOW WE USE YOUR INFORMATION

We may use and retain the information that we collect about you for various purposes, in accordance with this Privacy Policy and the applicable law.

We will process your personal information for the following purposes as is necessary for the performance of a contract between you and us (including our Terms of Service), or to answer questions or take steps at your request prior to entering into a contract:

Create your game accounts and allow you to play our games;
Administer your account on any of our Services
Facilitate communication between players;
Fulfill your purchase and send you an order confirmation;
Provide technical and customer support;
Respond to inquiries that you may have about our Service
Enable you to post your resume and contact or be contacted by MobilityWare; and
Confirm your identity.

We will process your personal information for the following purposes as necessary for certain legitimate interests, or where you have given your informed consent to such processing if required by applicable law (such consent can be withdrawn at any time):

Identify, suggest, and facilitate connections with other players and personalize our Services to you;

Manage and deliver contextual and behavioral advertising;
Notify players of in-game updates, new products, promotions, and/or other marketing communication;
Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by MobilityWare or our business partners, and notify contest winners and award prizes; and
Monitor and analyze usage and trends in connection with our Services;

We will process your personal information for the following purposes as necessary in our legitimate business interests, (provided such interests are not overridden by your interests or fundamental rights):

Operate, improve, and optimize our Services;
Protect safety and well-being of our players;
Protect our legal rights and property in connection with our Services;
Prevent fraud or potentially illegal activities and enforce our Terms of Service;
Investigate potential violations of our policies and Terms of Service;

Comply with our legal obligations, resolve disputes that we may have with you or other players, and to enforce our policies and agreements including our Terms of Service with third parties;
Conduct research; and
Carry out any other purpose for which the information was collected.

We may process your personal information in order to protect your vital interests or the vital interests of another person.

We may use the information you provide about your friends via referral services made available through our Services (such as “Tell a Friend”) for the sole purpose of sending this one-time email and tracking success of our referral program. If you choose to use such a referral service, we will automatically send your friend a one-time email inviting him or her to download our Services.

DATA PROCESSING IN THE UNITED STATES

MobilityWare is headquarteredin the United States. By accessing or using the Services or otherwise providing your information to us, you acknowledgethat your personal information may be accessed by us or transferred to us in the United States and to our affiliates, partners, and service providers who are located around the world; and that your personal data will be transferred to, and stored and processed in, the United States or elsewhere in the world where our servers are located.

If you are based in the EU, we will only process your personal information for a purpose described in this Privacy Policy if (1) you have provided your consent (which can be withdrawn at any time), (2) the processing is necessary for the performance of a contract we are about to enter into or have entered into with you, (3) we are required by law, (4) processing is required to protect your vital interests or those of another person, or (5) the processing is necessary for the purposes of our legitimate commercial interests (except where such interests are overridden by your rights and interests).

HOW WE SHARE YOUR INFORMATION

We may share and transfer your information (both inside and outside the country you live in) as provided in this section or as otherwise described in this Privacy Policy.

Non-Personal Information

We may use, disclose to our partners and vendors acting on our behalf; or to publish aggregated, anonymous information about our players for industry analysis, demographic profiling, marketing, analytics, provision of advertising, and other business purposes.

Personal Information

We may share your information, including personal information, with third parties or allow third parties to collect this information from our Services, as follows:

With your consent or at your direction and in some ways not specifically described in this Privacy Policy, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information;
We may use third party service providers such as credit card processors, email service providers, shipping agents, data analyzers and business intelligence providers; when we transfer any of your personal information to such a third party service provider, that entity will be contractually required, among other things, (a) to use such information only to carry out those services that we have requested, (b) to abide by this Privacy Policy, and (c) to provide adequate protection for such information (as required by applicable legal requirements);
With other players in connection with the social features of the Services (e.g. your username, profile picture and virtual content may be visible to other users of that game);
We may disclose personal information in response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process; or is otherwise required by any applicable law, rule or regulation;
We may disclose your personal information if we have a reason to believe that a disclosure is necessary to address a potential or actual injury or interference with our rights, property, operations, users or other who may be harmed or may suffer loss or damage, or we believe such disclose is necessary to protect MobilityWare’s rights;
MobilityWare may create co-branded webpages or games with our third party partners or contractors and in connection with these relationships we may pass your personal information to these partners in order to offer these co-branded Services. Such transfers are covered by our Privacy Policy, our agreements with those partners and our co-branding partners’ privacy policies. We make reasonable commercial efforts to ensure that all our third party partners and contractors adhere to the terms and conditions of our Privacy Policy;
Any information that you share in the course of contributing to user-generated content to our Services, such as forums, blogs or the like is public information and there is no expectation of privacy or confidentiality. MobilityWare is not responsible for any personal information that you choose to make public in any of these forums; or
In connection with, or during negotiations of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

MANAGING YOUR INFORMATION

MobilityWare does not verify the accuracy of your personal information and the correctness of this information is solely your responsibility. However, we make good faith efforts to enable you to update, confirm, or delete (or otherwise de-identify) your personal information in our possession. Upon request, MobilityWare will let you know whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by opening a help ticket directly in-game via the Help section; emailing us at [email protected], or contacting us via our physical address provided below. We will need sufficient information from you to establish your identity in order to fulfill your request. In some cases, we may not be able to remove your personal information, in which case we will notify you via email that we are unable to do so and why. If you’re playing the Web Solitaire version, click here.

California, Connecticut, Virginia, Colorado and Utah Rights

If you are a resident of California, Connecticut, Virginia, Colorado, or Utah, in certain circumstances you have rights under the data protection laws of your state in relation to personal information we hold about you. We are fully compliant with the privacy regulations of these states. Should you wish to exercise any rights afforded to you, or have any questions, please email [email protected]

Your European Rights

If you are based in the EU, in certain circumstances you have rights under data protection laws in relation to personal information we hold about you – specifically:

Request access to your personal information. You have the right to request access to any personal information we hold about you as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
Request correction of your personal information. You have the right to obtain without undue delay the rectification of any inaccurate personal information we hold about you.
Request erasure of your personal information. You have the right to request that personal information held about you is deleted.
Request restriction of processing your personal information. You have the right to prevent or restrict processing of your personal information.
Request transfer of your personal information. You have the right to request transfer of personal information directly to a third party where this is technically feasible.

You may exercise your rights by opening a help ticket directly in-game via the Help section; emailing us at [email protected] or contacting us via our physical address provided above.

We may need additional information from you to establish your identity in order to fulfill your request. In some cases, we may not be able to delete your personal information, in which case we will notify you via email that we are unable to do so and why.

Where you believe that we have not complied with our obligation under this Privacy Policy or European data protection law, you have the right to make a complaint to an EU Data Protection Authority.

Privacy Notice for California Residents

This Privacy Notice for California Residents supplements the information contained in this Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Services 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 (“Personal Information”). In particular, our Services have collected the following categories of Personal Information from its consumers within the last twelve (12) months:

Identifiers.
1. User Names (e.g. a real name, alias, etc.) , unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
2. Collected: Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
1. A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
2. Collected: No
Protected classification characteristics under California or federal law.
1. Age, sex (including gender) as self identified by You in opt-in surveys
2. Collected: Yes
Commercial information.
1. Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
2. Collected: Yes
Biometric information.
1. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
2. Collected: No
Internet or other similar network activity.
1. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
2. Collected: Yes
Geolocation data.
1. Physical location or movements.
2. Collected: Yes
Sensory data.
1. Audio, electronic, visual, thermal, olfactory, or similar information.
2. Collected: No
Professional or employment-related information.
1. Current or past job history or performance evaluations.
2. Collected: Yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
1. Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
2. Collected: No
Inferences drawn from other personal information.
1. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, and behavior
2. Collected: Yes
Equipment information.
1. Information about your internet connection, the equipment you use to access our Services, and usage details
2. Collected: Yes

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- 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.

Information Sources

MobilityWare obtains the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from contacting Customer Service or from products and services you purchase.
Indirectly from you. For example, from observing your actions on our Services.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Website, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Website and Services experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of MobilityWare’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by MobilityWare about our Website users is among the assets transferred.

MobilityWare will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

MobilityWare may disclose your Personal Information to a third party for a business purpose or sell your Personal Information, subject to your Right to Opt-Out (defined below) of those sales (see Personal Information Sales Opt-Out and Opt-In Rights, below). When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the Personal Information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your Personal Information with the following categories of third parties:

Service providers.
Data aggregators.

Disclosure of Personal Information for a Business Purpose

In the preceding twelve (12) months, MobilityWare has disclosed and/or sold the following categories of personal information for a business purpose: (A) Identifiers, (C) Protected Classification Characteristics, (D) Commercial Information, (F) Internet and other similar network activity, (K) Inferences drawn from other personal information and (L) Equipment information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that MobilityWare disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 purpose 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 (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that MobilityWare delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), 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 provider(s) 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.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Calling us at (949) 788-9900
Emailing us at[email protected]
Going directly in the Settings of the application you are using

Only you, or a person that you authorize to act on your behalf (“Authorized Agent”), may make a verifiable consumer request related to your personal information. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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 personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through the mobile application sufficiently verified when the request relates to personal information associated with that specific application.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights below.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

We will deliver our written response to you electronically.

The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “Right to Opt-Out”). We do not sell the Personal Information of Users we actually know are less than 18 years of age, unless we receive affirmative authorization (the “Right to Opt-In”) from the parent or guardian of a consumer who is between 13 and 18 years of age. If you are under the age of 13, you are not permitted to access the site, use any of our Services, or play any of our games.

Users who opt-in to Personal Information sales may opt-out of future sales at any time.

California law requires that we maintain a separate link that allows you to opt out of the sale of your information. To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us: [email protected]

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Contact Information

If you have any questions or comments about this notice, the ways in which MobilityWare collects and uses your information described below [and in the Privacy Policy], or your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: www.mobilityware.com

Email: [email protected]

Phone: (949) 788-9900

Push Notifications

With your consent, we may send push notifications (or “alerts”) to your mobile device to provide game activity information, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notifications settings via your mobile device.

Promotional Communications

You may opt out of receiving promotional messages from MobilityWare by following the instructions in those messages or contacting us at[email protected]. If you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

If you are based in the EU, we will only send you promotional messages where you have provided your consent in line with applicable law. You may withdraw your consent by following the instructions in those messages or contacting us at [email protected]. If you withdraw consent, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations.

Geo-location Information

When you use a smart phone or other mobile device to access our Services, with your permission we may collect your geo-location information to optimize user experience, such as for localization accuracy, language display, or the provision of relevant advertising. We will only collect such information if (a) “location services” for the mobile application is enabled; and (b) the permissions in the mobile device allow communication of this information. If you have previously allowed us access to your geo-location data, you can opt out of making this information available to us by visiting your mobile device’s settings for the relevant application or the “settings” page for the relevant game.

Third Party Tailored Advertising

We use cookies to present tailored advertising, provided you have given your consent if required by applicable law. For information about how we use cookies, including how you can withdraw consent or opt-out, please see our Cookie Notice.

Please note, you may still receive advertisements from third parties within MobilityWare’s games even if you withdraw consent or opt-out of tailored advertising but they will not be based on your activity across unrelated websites or apps.

THIRD PARTY SERVICES

Our website or Services may contain links to other websites or online services or allow others to send you such links. A link to a third party’s website or online service does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites or online services. You access such third-party websites or online services at your own risk. You should always read the privacy policy of a third-party website or online service before providing any information to the third party.

DO NOT TRACK

At this time, there is no general agreement on how companies like MobilityWare should interpret Do Not Track signals. MobilityWare does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device. You can learn more about Do Not Trackhere.

USE BY MINORS

If you are under the age of 18, you must obtain your parent’s permission to access the site and our games. If you are under the age of 13, you are not permitted to access the site, use any of our Services, or play any of our games. This site and all of our games are not intended for children under the age of 13 and we do not knowingly market to or collect, use or disclose information from children under the age of 13. If MobilityWare learns that we have inadvertently gathered personal information from children under such age, MobilityWare will take reasonable measures to promptly erase such personal information from our records.

DATA RETENTION

How long we retain your information depends on why we collected it and how we use it. We generally retain your personal information as long as your account is active andfor no longer than isnecessary forthe purpose for which such personal information is processed. Please note, however, that we may retain and use your personal information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it is not technically and reasonably feasible to remove such information from our databases. Consistent with these requirements, we will endeavor to delete your personal information promptly upon your written request.

SECURITY

MobilityWare takes appropriate technical and organisationalmeasures to help protect the security, integrity, and privacy of your information in our possession.

If you have any questions or concerns about this Privacy Policy, including any requests to exercise your rights, please contact us using the details set out below:

Email address: [email protected]
Telephone number: (949) 788-9900