Privacy Policy

Last Updated February, 2020

Contents

  1. Scope
  2. What data do we use?
  3. Why do we use this data?
  4. Do we use web browser cookies, or pixels?
  5. Will we ever contact you (and how to opt-out)?
  6. Will we share this data?
  7. U.S. Children’s Online Privacy Protection Act (“COPPA”)
  8. California Consumer Privacy Act (“CCPA”)
  9. 8.1 Consumers With Disabilities; Non-Discrimination
    8.2 Designated Methods For Submitting CCPA Requests
    8.3 Personal Information
    8.4 Necessity To Maintain Your Personal Information
    8.5 Opt-out / Opt-in For Sale Of Personal Information
  10. E.U. General Data Protection Regulation (“GDPR”)
  11. 9.1 GDPR Owner
    9.2 Personal Data
    9.3 Disclosure
    9.4 Data Retention
    9.5 Contact GDPR Owner
  12. Policy Updates
  13. Contact Us

This website (“site”) is owned and operated by Tightrope Interactive, Inc. (“we”, “our”, “us”), a Delaware (U.S.) corporation.

1. Scope

This Privacy Policy (“Privacy Policy”) pertains to your use (“user”, “you”, “your”) of our site, which may include web push notifications (“Notifications”) if you choose to opt-in via your web browser to receive them.

2. What data do we use?

The data we may use includes:

  • IP Address – Your public “Internet Protocol” address sent to us by your web browser.
  • GUID – A unique “Generic User Identification” created when you visit our site or subscribe to Notifications.
  • UA – The “User Agent” and version of your web browser; e.g. Chrome 80, Firefox 73, Safari 13, etc.
  • OS – The “Operating System” and version used by your hardware; e.g. Windows 10, macOS 10.15, etc.

3. Why do we use this data?

We may use this data to enable us to make our site and Notifications work for you.

  • We use your public IP address to determine geography, and prevent fraudulent use of our site and Notifications.
  • We use a GUID to ensure the proper functionality of our site and Notifications.
  • We use your UA and OS information to optimize our site and Notifications for your web browser and operating system.

4. Do we use web browser cookies, or pixels?

Cookies are removable text files stored in your web browser. We may ask your web browser to store one or more cookies when you use our site and Notifications in order to make them work for you. Pixels or “web beacons” are similar in function to cookies. We may ask your web browser to load pixels for our site and Notifications to better understand how you use our site and Notifications so we can improve them, and for other business purposes.

5. Will we ever contact you (and how to opt-out)?

  • If you contact us, we may reply using the contact information you provide at that time.
  • If you opt-in via your web browser to Notifications, we may send them to you via the mechanisms built-in to your User Agent and/or OS.
    • This web browser profile is not subscribed to this site’s Notifications.
    • If you are still seeing notifications from the web address of this site, please try our manual unsubscribe instructions.

6. Will we share this data?

Your data may pass through third-party service providers that we use to make our site and Notifications work for you. These third-parties may include:

7. U.S. Children’s Online Privacy Protection Act (“COPPA”)

We do not knowingly collect or sell information from children under the age of 13 pursuant to the Children’s Online Privacy Protection Act of 1998, 15 U.S.C. 6501-6505. We encourage parents and legal guardians to be familiar with the Internet activity of their children. For more information, visit the United States Federal Trade Commission website about protecting kids online.

8. California Consumer Privacy Act (“CCPA”)

This Section 8 applies to you if you are a natural person who is a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations. This section describes our good faith effort to meet our obligations if CCPA applies to you.

8.1 Consumers With Disabilities; Non-Discrimination

Consumers with disabilities can submit a CCPA request as described below in Section 8.2. We will make a reasonable effort to furnish Section 8 in an alternative format that you can consume. You have a right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA.

8.2 Designated Methods For Submitting CCPA Requests

You can contact us to submit a CCPA request via this webform, or by calling our automated, toll-free (within the United States) phone number: 1-833-874-2272. Please be aware that your public Caller ID information may be collected for business purposes if you choose the phone call method.

For inquiries about our Privacy Policy that are not related to CCPA, please use the contact information at the end of this Privacy Policy.

8.3 Personal Information

The State of California Civil Code, Division 3, Part 4, Title 1.81.5. California Consumer Privacy Act of 2018 [1798.100 – 1798.199], CCPA, defines “personal information” as including “…information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

For the purposes of our Privacy Policy, the “person” is “you” (“your”, “user”). The personal information we collect may include:

  • IP Address – Your public “Internet Protocol” address sent to us by your web browser.
  • GUID – A unique “Generic User Identification” created when you visit our site or subscribe to Notifications, which may be stored in a cookie.
  • UA – The “User Agent” and version of your web browser; e.g. Chrome 80, Firefox 73, Safari 13, etc.
  • OS – The “Operating System” and version used by your hardware; e.g. Windows 10, macOS 10.15, etc.

8.4 Necessity To Maintain Your Personal Information

The personal information we collect may be used for the following business purposes, which are necessary for us in order to:

  • Offer you our site and Notifications.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity.
  • Debug to identify and repair errors that impair existing intended functionality.

8.5 Opt-out / Opt-in For Sale Of Personal Information

We do not explicitly sell your personal information; therefore, there is no need to opt-out of the sale of your personal information. You may submit a CCPA request as described in Section 8.2 to preemptively opt-out or opt-in your personal information to a sale if one is made within 12-months from the date we receive your request.

9. E.U. General Data Protection Regulation (“GDPR”)

This Section 9 applies to you if you are a national of a European Economic Area (“EEA”) member state. This section describes our good faith effort to meet our obligations if GDPR applies to you.

9.1 GDPR Owner

You can contact our GDPR owner via this email link, or post:

Tightrope Interactive, Inc.
ATTN: GDPR Request
588 Sutter Street #551
San Francisco, California 94102-1102
United States of America

For inquiries about our Privacy Policy that are not related to GDPR, please use the contact information at the end of this Privacy Policy.

9.2 Personal Data

European Union regulation 2016/679, GDPR, defines “personal data” as “…any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”

For the purposes of our Privacy Policy, the “data subject” is “you” (“your”, “user”). The personal data we collect may include:

  • IP Address – Your public “Internet Protocol” address sent to us by your web browser.
  • GUID – A unique “Generic User Identification” created when you visit our site or subscribe to Notifications.

The personal data we collect may be used for the following purposes:

  • Fraud detection to prevent abuse of our site and Notifications.
  • Geography detection to aid with fraud detection, and the delivery of our site and Notifications appropriate for your location.

Our basis for processing personal data includes:

  • GDPR Recital 47: “The processing of personal data strictly necessary for the purposes of preventing fraud also constitutes a legitimate interest of the data controller concerned.”
  • GDPR Article 6(1)(f): “processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party…”

9.3 Disclosure

We may pass your personal data without first obtaining your consent to third parties listed in Section 6.

9.4 Data Retention

We may retain your public IP address in server logs for a time period of at least 20 days. GUID data may be retained for a period of at least 90 days after the last use of our site and Notifications by a user with a GUID.

9.5 Contact GDPR Owner

Please contact our GDPR owner as described in Section 9.1 to exercise your rights as a GDPR data subject, or to file a complaint. The GDPR owner can help you with GDPR-specific matters including:

  • Request a copy of information, if any, stored about you.
  • Correct information, if any, stored about you.
  • Erase information, if any, stored about you.
  • Restrict how information, if any, about you is used.
  • Transfer the information, if any, about you.
  • Object to how your information, if any, is used in certain cases.
  • Request why we are unable to fulfill your request, if applicable.

10. Policy Updates

We reserve the right to modify this Privacy Policy at any time. We will update this Privacy Policy if we make material changes to it.

11. Contact Us

If you have questions or concerns about this Privacy Policy, its implementation, or feel that we have not followed it, please let us know by email or post:

Tightrope Interactive, Inc.
ATTN: Privacy Policy – General Inquiry
588 Sutter Street #551
San Francisco, California 94102-1102