CCPA

 

Memory Lane Games is committed to and compliant with the CCPA

Below we detail Memory Lane Games’s updated compliance with the 2018 CCPA regulations regarding data privacy

The California Consumer Privacy Act ("CCPA") is a new and important legislation designed to make data protection laws clearer and more accessible to Californian consumers. This new regulation was approved and adopted in 2018 and is enforceable as of January 1, 2020.

Memory Lane Games is committed to the new CCPA laws. Below we explain in plain language what is the CCPA, what information we collect about our users, and how this information is used.

Please note: The content of this page may change from time to time. We encourage you to revisit this page periodically to stay updated with the most recent adjustments to Memory Lane Games’s TCPA compliance.

What is the CCPA?

The California Consumer Privacy Act (CCPA) establishes and enhances consumer privacy rights for California Residents (as defined below) and imposes rules on businesses that handle their personal information. The CCPA grants consumers the right to know what personal information about them is collected by a business, as well as the purposes for which such personal information is used and to whom it is transferred or sold. Consumers have the right to obtain a copy of personal information collected about them by making “verified consumer requests.” Consumers then have the right to receive such information in a portable and readily usable format enabling them to transmit the information from one entity to another.

What if you’re not a resident of California?

As we mentioned above, the CCPA protects privacy by affording Californians the right to access, delete, and opt-out of the sale of their data (unless such data was collected and processed wholly outside of California and wasn’t sold in California). The CCPA protects “consumers,” which are defined as California residents. “Californian Consumers” extends to both California residents currently in the state and those traveling outside of the state. If you are not a consumer according to the CCPA, this is still information you should be aware of and understand but in this event the CCPA shall not apply to your information. For more information on these new changes and what they include, please visit the CCPA official page.

Information Memory Lane Games collects and why

We may collect the following 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”):

CATEGORYEXAMPLESCOLLECTED

A. Identifiers.

Real name, alias, email address, or other similar identifiers.

YES (if you explicitly provide such information)

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Name, telephone number Some personal information included in this category may overlap with other categories.

YES (including photos and which you upload)

C. Protected classification characteristics under California or federal law.

NO

D. Commercial information.

NO

E. Biometric information.

NO (some of your photos or videos might include faces). We do not use any information for Biometric purposes

F. Internet or other similar network activity.

Information on a consumer’s interaction with a website or application, device information (such as operating system and its versions).

YES (information on your activity within the app for analytics purposes and personalized user experience)

G. Geolocation data.

Time zone, location, Information about your mobile service provider and language settings.

YES

H. Sensory data.

NO (you have the ability to add sound recordings)

I. Professional or employment-related information.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

NO

K. Inferences drawn from other personal information.

NO

Note: our apps are intended for photo sharing. You may select to upload and share documents which include some of the information included in categories which are marked as “NO” above. We have no way to prevent you from doing so and if you decide to share such documents, we do not use them or analyze them. If these documents include information in any of the categories above, we have no way to know that this is the case. We urge you NOT to share documents in general and specifically those which might include personal information.

Information we don’t collect

  • Any personal information on your mobile device unrelated to the Memory Lane Games apps (including other photos on your device, contacts, calendars, phone calls, messages, etc.);

Why? Because it’s none of our business :)

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients. For example, your email address or other identifiers that you provide to us when you register to or use the apps.

  • Indirectly from our clients. For example, device information, inter alia, in order to provide personalized user experience.

  • Directly and indirectly from activity on our website (www.memorylanegames.com). For example, submissions through our website portal or website usage details collected automatically.

  • From third-parties that interact with us in connection with the services we perform, for further information please see our privacy policy available at https://memorylanegames.com/privacy-policy-full.

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 for which the information is provided;

  • To get in touch with you, offer support and special offers and send you security alerts;

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;

  • For billing and collections, account management and other administrative purposes, if applies;

  • To verify your identity and to respond to your comments, questions and requests and provide customer service;

  • To improve our website and present its contents to you;

  • For testing, research, analysis and product development;

  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others;

  • 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

  • We 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.

How long we hold personal information for

Your personal information will be retained as following:

  1. For no longer than is necessary in relation to the purposes for which such personal data was collected or otherwise processed, including for the purpose of ensuring your photos and videos are saved and backed up for easy retrieval, should you need it; or

  2. As long as you did not implement your right to request the deletion of your personal information. We will execute such requests as long as there are no more legitimate grounds for the processing of your personal information. For further information please see the “Deletion Request Rights” section below.

Please be aware that deleting the Memory Lane Games apps does not mean your personal information is deleted. In order to delete your personal information please submit a verifiable consumer request, in accordance with the “Exercising Access, Data Portability, and Deletion Rights” section below.

If you have any questions in this regard, you’re welcome to contact us, in accordance with the “Contacting Us” section below.

As necessary to comply with legal obligations, resolve disputes and enforce our agreements. Once data is no longer lawfully required it will be destroyed securely.

Important information about sharing your Memory Lane Games photos

Your uploaded photos or videos could also find their way to strangers on the web. Memory Lane Games has no control over how other people may interact with your published photo or video (taking a screenshot, downloading the photo or video, etc.). Please keep that in mind before uploading a photo or video.

Third parties associated with the Memory Lane Games service

We may disclose your personal information to a third party for a business purpose. 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 for performing the contract.

CATEGORY

REASON FOR COLLECTION

Identifiers

Analytics and support

Internet or other similar network activities

Analytics and personalized user experience

Geolocation data

Analytics and personalized user experience

We may disclose some or all of your personal information for a business purpose to the following categories of third parties:

  • Service providers – for a full list please see our GDPR page.

  • Third parties to whom you authorized us to disclose your personal information in connection with products or services we provide to you.

  • Legal Process Requests. We may share your information with law enforcement or other third parties in connection with legal requests.

Californian Consumer’s Rights and Choices

The CCPA provides California Consumers with specific rights regarding their personal information. This section describes your CCPA rights (if you are a California Consumer and the CCPA applies to you) and explains how to exercise those rights.

Access to specific information and Data Portability Rights (as defined below):

You have the right to request us to 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, we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources of 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 Data Portability Request).

Deletion Request Rights

You have the right to request that we 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, 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 providers 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 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:

Emailing us at support@memorylanegames.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

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

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 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. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option (after providing us with contact details). Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. 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 usable 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.

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 good or services;

  • Charge you different price 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 a 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 incentives program requires your prior opt-in consent, which you may revoke at any time.

Contact us

If you have any questions or concerns regarding how we use your information, please contact us at support@memorylanegames.com and mention “CGPA” in your message’s subject line.

Last updated: 11 June2020