Phrazle may retain users’ data for the following purposes: To develop new features and improve the Phrazle Site; To support subsequent customer service inquiries; To improve the safety and security of the Phrazle Site; orComply with our legal obligations. We will retain your information for as long as is reasonably necessary in relation to the purposes for which this data was collected.
Phrazle may share your persistent identifiers with third parties such as business partners under the following circumstances:Security: We may release information about our Users, including IP address, when legally required to do so, at the request of governmental authorities conducting an investigation or to verify or enforce compliance with the policies governing the Phrazle Site and applicable laws. We may also disclose such user information whenever we believe disclosure is necessary to protect the rights, property or safety of Phrazle, or any of our respective business partners, customers or others. Aggregate Information: We may disclose non-identifying, aggregated user statistics to third parties for a variety of purposes, including describing our services to prospective partners and other third parties. Examples of such non-personal information include the number of users who visited this Phrazle Site during a specific time period or played a specific game on this Website. Advertising: We may share technical information such as IP address or device ID with our advertising partners. For advertising on the Phrazle General Site, this information may be used to serve behaviorally targeted ads or profiling. For advertising on the Phrazle Kids Site, this information will only be shared for the purposes of serving contextual advertising and capping the frequency of ads.
Phrazle may work with third parties that are based outside of the European Economic Area (EEA), and may transfer data about you to the countries in which these parties reside. Whenever we share personal data originating in the EU with an entity outside of the EEA, we will do so on the basis of the EU standard contractual clauses, with your consent, or because such transfer is necessary performance of a contract.If you have any questions about our policy regarding international data transfers, please contact us at [email protected]
We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children’s use of online activities regularly. This is why we created a separate age-appropriate experience for Children Users through the Phrazle Kids Site, or through an age-gate in certain games on the Phrazle General Site: in order to comply with the legislation, you could be presented to an age screen when starting the game. When presented with this age screen, it is important that you state the correct age. Based on your age information and your device settings, Phrazle does not process personal data of children under the minimum age limit (Children Users) that is prescribed by the legislation in the individual jurisdictions for behavioral advertisement.The Children Users’ experience of games with an age-gate on the Phrazle General Site, and the Phrazle Kids Site supports and complies with the Children’s Online Privacy Protection Act (“COPPA"). The Children Users’ experience of games with an age-gate on the Phrazle General Site and the Phrazle Kids site will not request any personal information from Children Users. There is no registration required for the Phrazle Kids Site and any advertising shown on the Phrazle Kids Site, or in the the Children Users’ experience of games with an age-gate on the Phrazle General Site, is age-appropriate. The Phrazle Kids Site and the Children Users’ experience of games with an age-gate on the Phrazle General Site will not show behaviorally targeted ads or allow third parties to track the activity of Children Users for that purpose.The Phrazle Kids Site and the the Children Users’ experience of games with an age-gate on the Phrazle General Site may collect and use IP addresses and other persistent identifiers, including cookies, from Children Users, but only for purposes of supporting our internal operations, such as to help us: Identify whether you are a child or adult for data protection purposes to determine the legal requirements for our processing of your dataMaintain or analyze the functioning of the Phrazle Kids SitePerform network communicationsAuthenticate users of, or personalize the content on, the Phrazle Kids SiteServe contextual advertising on the Phrazle Kids Site and cap the frequency of advertisingWe have separated our platform into a few sections. Phrazle Kids was created for our youngest audience and is fully COPPA compliant. If you are a Child User, you should only use the Phrazle Kids Site and only with the permission of a parent or legal guardian. On Phrazle .com, you’ll find games that are intended at users that are over 13. Phrazle .com is not targeted towards children under the age of 13 and it will not knowingly collect personal information from children under 13. To learn more about COPPA, please reference this simple one-page informational guide from the kidSAFE Seal Program: https://www.kidsafeseal.com/knowaboutcoppa.html.
If you are an individual in the European Union (EU), we collect and process data about you only where we have legal bases for doing so under applicable EU laws. This means we collect and process your data only when:It is necessary for a legitimate interest (which is not overridden by your individual privacy interests), such as preventing fraud, improving the Service, and increasing the security of the Service and network infrastructure;You have consented to this collection and processing for a specific purpose; It is necessary to fulfil our contractual obligations; or It is necessary to comply with a legal obligation. Where we rely on our legitimate interests to process your personal data, you have the right to object. More information on exercising this right can be found in section 11 addressing Individual Rights. Some examples of our legitimate interests and the data being processed include: Network and information security (IP address, user/device ID) Customer Support and fraud prevention (email address) Improving our products and services (activity logs) Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. If you wish to withdraw your consent, please contact us using the information in section 12 regarding the Contacts for Individual Rights Requests. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us at [email protected]
Phrazle makes certain choices available to you when it comes to your personal data. Please review the below information outlining your choices and how to exercise them. We will respond to all requests within a reasonable timeframe. If our full response will ever take more than a month due to complexity or scope, we will notify you of this and keep you updated. We may request more information to confirm your identity before acting on any request.Delete your data: You also hold the right to have your personal data deleted. This is sometimes known as the ‘right to be forgotten’. To request that we delete all personal data about you, please submit a request using the contact information at the end of this section.After you delete your personal data from our services, we may not immediately delete residual copies from our active servers and may not immediately remove data from our backup systems for archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We may also decline to honor this request in certain specific situations, such as if the data is necessary to comply with a legal obligation or to exercise/defend a legal claim.Restrict Processing: You have the right to restrict how we process your personal data in certain circumstances. This is an alternative to requesting the deletion of your data. Rather than requesting we delete all of your personal data, you may request that we limit our uses of your personal data to specific purposes. You may wish to request we restrict our processing if you contest the accuracy of your personal data and we are working to verify this information, or if you want us to retain your personal data in connection to a legal claim but cease processing it. Data Portability: You have the right to obtain copies of your information in a structured, commonly used format that you can move your data between our service and the services of others. We may request more information to confirm your identity before providing any personal data. Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or when our processing of your data is based on legitimate interests. You may request that we stop processing your personal data for direct marketing purposes. This is an absolute right and we cannot refuse this request. Beyond direct marketing, if you wish to exercise this right, you must give specific reasons why you object to our processing of your data, based on your particular situation. Even after receiving such a request, we may continue processing if it is necessary for the exercise/defense of a legal claim or if we can demonstrate a compelling legitimate ground for the processing.If any request made under this section is clearly unfounded or excessive, we may reject the request or require a reasonable fee to honor the request. If we decide to reject your request, we will inform you of the reasons for not taking action and provide information on other possible remedies. If we decide that a reasonable fee is necessary, we will promptly inform you and will comply with the request upon receipt of this fee.