PRIVACY POLICY


(Last modified:  May 17, 2020)

 

This privacy policy (“Privacy Policy”) governs the data collection, processing and usage made by Gigantic Ltd. (“Company”, “we” or “us”) and our privacy practices with respect to the data we collect from individuals who access and use our website  available at: https://www.clawee.com/ (“Visitors”) and users who have installed and are interacting with our mobile application known as “Clawee” offering real live claw machine game (respectively “App” and “Users”); Each of the Visitors and Users, shall also be referred to herein as “you”.

 

This Privacy Policy explains what information we may collect, how such information may be used or shared with others, how we safeguard it and how each of the aforementioned individuals may exercise their rights related to their Personal Data (as such term is defined below), among others, according to the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”) where applicable.

 

You are not legally required to provide us with Personal Data, however, some of the features on our website and App require you to do so pursuant to this Privacy Policy. In these cases, if you choose to withhold or delete any Personal Data requested by us, it may not be possible for you to access certain features of our website or App. If you do not agree to the terms and conditions of the Terms (as such term is defined below) please do not use or access our website or App.

This Privacy Policy constitutes an integral part of our Terms & Conditions of Use available at: http://www.gigantic.company/clawee/terms (“Terms”). Definitions used herein but not defined herein shall have the meaning ascribed to them in our Terms.

 

If you have any questions about this Privacy Policy, please contact us at: privacy@clawee.com.

 

AMENDMENTS

We reserve the right to periodically amend or revise the Privacy Policy which will go into effect immediately upon the implementation of the revised Privacy Policy on our website or App, as applicable. The last revision date will be reflected in the “Last Modified” heading located at the top of the Privacy Policy. We will make a reasonable effort to notify you in the event that we implement any changes that substantially changes our privacy practices. We recommend that you review this Privacy Policy periodically to ensure that you understand our privacy practices and to check for any amendments. Notwithstanding the above this privacy policy will be updated every 12 months, months in the event requires under applicable laws.

 

types of data we COLLECT

 We may collect aggregated, non-personal non-identifiable information which may be made available or gathered via your use of our website or App (“Non-Personal Data“). We are not aware of the identity of the individual from which the Non-Personal Data is collected.

 

We may also collect from you, during your access or interaction with the website or your use of our App, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Data” or “Personal Information as defined under applicable law). This may include online identifiers, name, emails, etc., subject to applicable law.

 

If we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data.

 

EU General Data Protection Regulation (“GDPR”) & Lawful Basis for Data Processing:

The types of data that we collect, the purpose for processing such data and the lawful basis for which we do so subject to the GDPR, are specified in the table below.

 

Please note that, Gigantic acts as the Controller of the Personal Data detailed herein, as defined under the GDPR

 

Type of Data

How Do We Use It?

Becoming a User:

If you are or wish to become a User of our App you will be required to provide us with certain information such as: your email address, Google account (optional), and Facebook account (optional).

In addition, in order for us to ship the prize (as requested voluntarily by the User) you will be required to provide with additional information such as: your full name, shipping address and phone number (optional).

 

 

 

 

We will use this data for the purpose of designating your App account.

In addition, your email address will be used in order to send you needed information related to our App (e.g., notify you regarding any updates to our App, etc.) and promotional and marketing emails.

In addition, in the event requested by you, we will use the information provided by you for the purpose of shipping your prize.

Our lawful basis under the GDPR for the collection of this information is performance of a contract (i.e., providing you the services you requested) and necessity of processing for the purposes of our legitimate interests.

Contacting Us:

If you voluntarily contact us in any manner whether for support, to submit a request or for other inquiries whether by sending us an email or through other means of communications, e.g., any online form available on our website, you may be asked to provide us with your contact information such as your full name, email address and country.

We will use this data, as well as our contact history, solely for the purpose of responding to your inquiries and provide you with the support or information you have requested. We will retain our correspondence with you for as long as needed, subject to applicable law.

Online Identifiers and Technical Non-Personal Data:

When you access our website or interact with our App, we may collect certain online identifiers which include, as applicable, your IP address, Advertising ID and IDFA.

We may also collect technical data transmitted from your device  (e.g. actions in the website or App, your browser type, language used, type of operating system, type of device etc.) and approximate geographical location (country).

We use this data for our legitimate interests of (i) operating, providing, maintaining, protecting, managing, customizing and improving our website and App and the way in which we offer it; (ii) enhancing your experience; (iii) auditing and tracking usage statistics and traffic flow; (iv) protecting the security of the website and App, as well as our and third parties’ rights (subject to applicable law requirements); and (v) advertising purposes.

If we use third party cookies on our website, or in the event the collection of online identifiers, we will obtain your consent if required under applicable law.

Online Campaigns and Information Requested from you:

 

We sometimes launch online campaigns, such as promotional campaigns in social media. In such cases we may invite you to post pictures and user experience or other information online as part of the campaign. If you participate in the campaign (e.g. by posting on the campaign page or in the campaign post or using the campaign hashtag) then we may collect and use such information and photos.

 

We may also approach you and ask for your specific permission to use photos, user experience information and other information posted on social media, which we will collect and use if you grant your permission.

 

By posting any photos on our social media pages or accounts you agree that we may collect, retain and process such photos and post, modify and reshare them for promotional purposes.

We use such information for: (i) operating, providing, maintaining, managing, customizing and improving our website and App and the way in which we offer it; (ii) enhancing your experience; (iii) for advertisements and promotional activity.

Information From Other Sources:

 

Users may be able to login to the App and website through third-party services such as Facebook or interact with third party platforms and services through the App or website, such as by clicking on the share or like buttons of Facebook. By logging-in using a third-party service or interacting with such third party services through the App or website, you allow the Company and its affiliates to access information related to your account with such third party, which may include friends, your profile information and photo and privacy settings. Furthermore, you acknowledge that such third-party may be able to access information concerning your use of the App or Company’s website subject to such third party's privacy policy.

We will use this data for: (i) user verification and login.

 

 

California Consumer Privacy Act 2018 (“CCPA”) & Categories of Personal Information Collected and Shared

Under the CCPA, “Personal Information” is defined as any 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, household or device.

 

Please note that, under the CCPA Personal Information does not include: publicly available information from government records and DE identified or aggregated consumer information, information excluded from the CCPA’s scope (e.g., health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA)); and information covered by certain sector-specific privacy laws (e.g., the California Financial Information Privacy Act (FIPA)).

 

As required under the CCPA, please see below a table detailing the categories of Personal Information that we collect (and has collected within the last 12 months):

Category

Examples of Personal Information that We Collect

Identifiers.

Such as a real name, alias, postal address, unique personal identifier, online identifiers (such as IDFA and Google advertising IDs), Internet Protocol address, email address, account name, or other similar identifiers.

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

Such as a name, address, telephone number, four last digits of your credit card number or debit card number.

Some personal information included in this category may overlap with other categories.

Commercial information.

Such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Internet or other similar network activity.

Such as information on a consumer's interaction with the application, or advertisement.

Geolocation data.

Such as geolocation and physical location.

 

As required under the CCPA, please see below information regarding disclosures of Personal Information for a business purpose:

 

In the preceding twelve (12) months, Company has disclosed the following categories of Personal Information for a business purpose:

A.     Identifiers.

F.       Geolocation data.

 

We disclose your Personal Information for a business purpose to the following categories of third parties:

·       Service providers – for shipment services, etc.

·       Data aggregators.

 

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.

 

HOW WE COLLECT DATA

Depending on the nature of your interaction with the website or App, the above detailed data is collected as follows:

·       In the event you voluntarily choose to provide us with information, e.g., when you contact us, create and account or request us to ship your prize.

·       Automatically, including through the use of cookies (as detailed below), and other similar tracking technologies.

 

We will ask for your consent to collect Personal Data and offer you the choice to opt-out of such collection if we are required to do so in accordance with applicable law.

 

COOKIES & TRACKING TECHNOLOGIES 

We use cookies and other similar tracking technologies when you access the website or interact with the App we offer. This use is a standard industry-wide practice.

A "cookie" is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes and advertising purposes. You can find more information about cookies at: www.allaboutcookies.org and https://cookiepedia.co.uk/.

There are several types of cookies, the three main and common ones are:

·       Essential, Functionality, Operation & Security Cookies - essential for enabling user movement around the website, for the website to function properly, and for security purposes. Please note that these cookies either cannot be disabled, or if disabled, certain features of the Services may not work.

·       Analytic, Measurement & Performance Cookies - used to collect information about how users use the website (clickstream, navigation, time and date of access, etc.) in order to improve our Services and the way we offer them, as well as assessing performance of the content available in the website. We further use this information to compile reports and calculate payments in the course of relationship with our business partners which their services are displayed in our website.

·       Preference, Targeting & Advertising Cookies - used to advertise across the internet and to display relevant ads tailored to users based on the parts of the website they have (e.g., the cookie will indicate you have visited a certain webpage and will show you ads relating to that webpage).


The specific cookies and other tracking technologies (such as SDKs implemented in our App) (ours and third party’s) we currently use, purpose of use, their privacy policies and opt-out controls are set forth in the table below:

 

Third Party

Purpose

Privacy Policy

Facebook

Targeting & Advertising

https://www.facebook.com/about/privacy/update
https://www.facebook.com/policies/cookies/

Youtube

Essential, Functionality, Operation. & Security Cookies

https://www.youtube.com/yt/about/policies/#community-guidelines

Targeting & Advertising

Analytic, Measurement & Performance Cookies

Google Analytics

Analytic, Measurement and Performance

https://tools.google.com/dlpage/gaoptout

www.google.com/policies/privacy/partners.

Google DoubleClick

Targeting & Advertising

https://policies.google.com/privacy?hl=en

Crashlytics

Essential, Functionality, Operation. & Security Cookies

https://policies.google.com/privacy

Firebase

Essential, Functionality, Operation. & Security Cookies

https://firebase.google.com/support/privacy

Appsflyer

Analytic, Measurement and Performance

https://www.appsflyer.com/privacy-policy/

Braze

Targeting & Advertising

https://www.braze.com/privacy

Zendesk

Targeting & Advertising

https://www.zendesk.com/company/customers-partners/privacy-policy/

 

For additional information of our use of Google products, click here.

 

Cookies Opt-Out

Please note that, most browsers will allow you to erase cookies from your computer's hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. By following the instructions of your device preferences, and by adjusting the privacy and security settings of your web browser, you may remove cookies, however, if you block or erase cookies some features of the Services may not operate properly and your online experience may be limited.

Please refer to the support page of the browser you are using. In this regard, following are some links which you may find useful: Google Chrome; FireFox; Internet Explorer; Safari; Edge; Opera

You may opt-out directly from third party retargeting cookies or other ad-technology trackers through self-regulator services like the Network Advertising Initiative’s (“NAI”) website – NAI consumer opt-out page or the Digital Advertising Alliance’s (“DAA”) website – DAA opt-out page;

Other tracking technologies opt out:

Android – https://support.google.com/ads/answer/2662922 or

iOS – https://support.apple.com/en-il/HT205223.

You may also contact us (see our contact details below), and we will make efforts to assist you.

 

SHARING DATA WITH THIRD PARTIES

We do not share any Personal Data collected from you with third parties or any of our partners except in the following events:

·       Legal Requirement: We will share your information in this situation, only if we are required to do so in order to comply with any applicable law, regulation, legal process or governmental request (e.g., to comply with a court injunction, comply with tax authorities, etc.);

·       Policy Enforcement: We will share your information, solely to the extent needed in order to: (i) enforce our policies and agreements; or (ii) to investigate any potential violations thereof, including without limitations, detect, prevent, or take action regarding illegal activities or other wrongdoings, suspected fraud or security issues;

·       Company’s Rights: We will share your information in order to establish or exercise our rights, to prevent harm to our rights, property or safety, and to defend ourselves against legal claims when necessary, subject to applicable law;

·       Third Party Rights: We will share your information, solely to the extent needed in order to prevent harm to the rights of our users, yourself or any third party’s rights, property or safety;

·       Business Purpose - we may disclose your personal information to a third party for a business purpose, as detailed above.

·       Service Providers – we share your information with third parties that perform services on our behalf (e.g. customer service, tracking, servers, service functionality, marketing and support, shipment, etc.) these third parties may be located in different jurisdictions.

·       Corporate Transaction - we may share your information, in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy;

·       Authorized Disclosures - we may disclose your information to third parties when you consent to a particular disclosure. Please note that once we share your information with another company, that information becomes subject to the other company’s privacy practices.

 

We may share aggregate or Non-Personal Data with our affiliated companies and additional third parties in accordance with the terms of this Privacy Policy. We may store any type of information on our servers or our cloud servers, use or share Non-Personal Data in any of the above circumstances, as well as for the purpose of providing and improving our website and App, aggregate statistics, marketing and conduct business and marketing analysis, and to enhance your experience.

 

YOUR RIGHTS

Data protection and privacy laws may provide you with some of the principal rights (depending on your jurisdiction) with respect to your Personal Data. Please review our Privacy Rights Overview to learn more.

 

In the event that you contact us and request to exercise any of your rights detailed above, we may request that you provide us with certain information in order to verify your identity and locate your data. Such process may take certain period, subject to applicable privacy laws (for example one month under the GDPR).

 

Please note that, you may have different rights then those which we listed above subject to privacy protections laws in your jurisdiction.

 

If you wish to exercise any or all of the above rights, please fill out the Data Subject Request (“DSR”) form available here, and send it to our privacy team at: privacy@clawee.com.

 

If you wish to receive more information or in the event that you have any additional complaints about your privacy rights, please contact us at: privacy@clawee.com.

 

data retention

Unless you instruct us otherwise and subject to applicable laws, we retain the information we collect for as long as needed to provide our services and to comply with our legal obligations, resolve disputes and enforce our agreements if applicable.

 

SECURITY

We use physical, technical and administrative security measures for the services that we believe are in compliance with applicable laws and industry standards in order to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed or accidentally lost. It is important for you to remember however, that unfortunately, the transmission of information via the internet cannot be 100% secure. As such, although we will do our best to protect your Personal Data, we cannot guarantee the security of data transmitted via our website or our App and any transmission of your data shall be done at your own risk.  

 

Please contact us at: privacy@clawee.com if you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

 

links

Links to other services, sites, documents, files, materials and applications may be provided by the Company as a convenience to our Users. The Company is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. This Privacy Policy applies solely to Personal Data collected by us.

 

CHILDREN

Our App and website are not directed nor is it intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law which with respect to the European Economic Area (“EEA“) is under the age of 16 and with respect to the U.S.A, under the age of 13) and we do not knowingly process a child’s information. We will discard any information that we receive from a user that is considered a "child" immediately upon our discovery that such a user shared information with us. Please contact us at: privacy@clawee.com if you have reason to believe that a child has shared any information with us.

 

Transfer of your data

We may store or process your Personal Data in a variety of countries including the United States. Please note, that if you are a resident of the EEA we will, in the absence of an EC Adequacy decision relevant to the destination country or to the transfer, seek to relay on appropriate safeguards such as a valid Privacy Shield certification (in the case of a data transfer to a Privacy Shield certified US recipient): https://www.privacyshield.gov/welcome), or enter into appropriate EC approved standard contractual clauses (see http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm) when your Personal Data is being transferred out of the EEA. If you are a resident of a jurisdiction where the transferring of your Personal Data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data. By providing any Personal Data to us pursuant to this Privacy Policy, all Users, fully understand and unambiguously consent to this Privacy Policy and to the collection and processing of such Personal Data abroad. By submitting your Personal Data through the website and/or App, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your Personal Data as described in this Privacy Policy.

DO NOT TRACK DISCLOSURE

Our website does not respond to Do Not Track signals. For more information about Do Not Track signals, please see: http://www.allaboutdnt.com/.

 

CONTACT US

If you have any questions about this Privacy Policy, you may contact us as follows:

·       By sending an email to: privacy@clawee.com

·       By mail at:

Gigantic Ltd.
3 Tvuot Haaretz St.

Tel-Aviv 6954627, Israel.

·     Toll free number for California residents: +1 (833) 920-2529