Last Revised: 5 May 2023
YOUR USE OF OUR SERVICES, GAMES AND WEB SITES IS SUBJECT
TO YOUR AGREEMENT TO THE TERMS OF THIS PRIVACY POLICY.
Virtual Play Games Inc. ( VPG ) respects your privacy and is committed to protecting the personal information that you may provide while using our web sites and services. This Privacy Policy (the Policy ) is intended to provide you with notice of the following:
If you have any questions, complaints, suggestions or
comments regarding this Policy, please contact the VPG Customer Service Team
at info@virtualplaygames.com.
The web sites and services covered by this Policy
We currently operate the following web sites (the Sites ) and services (the Services , or Games ):
www.virtualplaygames.com ( Home Page )
Jeopardy Words ( Game )
Wheel of Fortune Words ( Game )
Wheel of Fortune POP! ( Game )
In addition, we own other domain names that may redirect to the home page and/or content-specific subsites of Sites.
From time to time, we may add new Sites that may not be listed above, but they will provide a link to this Policy and will be governed by its terms.
Our policies concerning children
VPG complies with the Children s Online Privacy Protection Act (http://www.ftc.gov/ogc/coppa1.htm) and all other applicable laws and regulations concerning children and the Internet.
Children under the age of 16
Because our Sites and Games are not intended for use by children under the age of 16, VPG does not provide memberships to persons under age 16. If you are under the age of 16, you (1) are expressly disallowed to use our Services or create an account on them, (2) may not sign up for any subscription service or buy anything through the Game Stores, and (3) you are not eligible to enter any of our sweepstakes or promotions. Except as may be required by law, VPG will not knowingly collect, maintain, or disclose any personal information from children under the age of 16.
Kids between the ages of 16 and 18
If you are between the ages of 16 and 18, please let your parent(s) or guardian(s) know about this Policy and get permission from (one of) them before you give us any of your personal identifiable information, before you use any of our message boards, instant message or chat features, before you sign up for any subscription game services, and before you buy anything from the Store. Don t post your real name on a web site or message board, and never tell anyone online anything private about yourself or your family, including your phone number and address. Always be sure to use random nicknames or other non-identifiable names at all times in such online interactions -- never your real name. If you win a sweepstakes that has a prize, your parent or guardian will have to mail or fax us a signed note at the address or fax number listed in the rules for the specific contest that says they granted their permission for you to enter, and confirms they will accept the prize on your behalf, as well as pay any State, Federal or Local taxes that may be due as a result of the prize. Some countries, states, provinces, cities or other areas may have special rules for children under the age of 18 that pertain to online interactions. If you reside in one of those areas, you must follow those rules.
Information for Parents/Guardians
VPG strongly encourages parents and guardians to spend time online with their children and to become intimately familiar with the types of content they are interacting with on the Internet, including our online games. Parents and guardians should regularly oversee their children s use of e-mail, chat, games and other online communications and transactions. Parental control tools are available from online services and software manufacturers that can help provide a safe online environment for kids.
If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, the moment you inform VPG of the situation and request removal, VPG will take all reasonable, rapid steps to remove the personal information from VPG databases as per your request. To request removal of your child s information, please send us an e-mail to info@virtualplaygames.com and be sure to include in your message the exact user name, password, and email address that your child submitted, to enable us to locate and purge the account data in question.
Personal Information: General and GDPR Compliance
We do not collect any personal information from you unless you elect to provide it to us voluntarily. If you decide to provide us with any personal information (e.g., name, email address, and mailing address), we only collect the minimum possible personal information necessary to fulfill your requests and our legitimate business objectives. If, when requested, you refuse to divulge personal information of the sort that falls within this minimum-required amount, you will not be able to access certain areas on the Sites (such as the message boards). Some information, such as your originating IP address (if not using a VPN) is part and parcel of every internet communication, and so is "provided" automatically when you create an Account, but VPG considers your IP Address(es) to be personal data as well. In the case of an official request from you to delete all of your Accounts and Personal Data, your IP Account record is also expunged along with all other Account Data. Consequently, VPG maintains full EU General Data Protection Regulation (GDPR) Compliance.
Memberships and Registration
In order for you to register with VPG, in some areas we may require you to provide us with an email address, state and country of residence, zip/postal code, birth date and gender; we allow you to elect whether to also provide your real name. Some other areas may allow us to grant you use of our services while remaining anonymous, but it is possible that you may not be able to access all the content and features of those areas without registering.
You may be asked to choose a nickname (or a user name) and password. Please do not use your real name or the real name of another person when selecting a user name. Please note that your user name will be available to the Internet s general public while you participate in some services, like chat rooms or message boards, so you should exercise proper discretion when using those services. Personal information voluntarily disclosed by you within such chat areas, instant message services, message boards, or during game play can potentially be collected by other users of such services and may result in unsolicited messages. We are not responsible for protecting such information that you may choose to voluntarily disclose to third parties through our services (e.g. sending your telephone number to another user through the chat service). To the extent that you create a public profile that may be available to others on our sites and services, you are solely responsible for its content and accuracy at all times. To edit, change, or delete such information, follow the instructions provided within that relevant service.
Email Newsletters and Friend to Friend Promotions
You must provide an e-mail address to us in order to receive emails from us. All e-mail received from VPG (and also the Licensor of our Games, Sony) is, consequently, "opt-in". You can always "opt out" of receiving future mailings resulting from this by following the directions contained in any received email to unsubscribe. Also, except in jurisdictions where it may be prohibited by law to do so, some VPG sites and Services may ask you to submit information about other people. For example, we may offer Send to a Friend promotions, like electronic postcards on our sites or through our newsletters. In these situations, users are asked to provide the e-mail address and, sometimes, the name of a friend. After the Send to a Friend transaction is completed, that information is deleted.
Sweepstakes, Contests, and Promotions
To participate in some of our sweepstakes, contests, surveys, and other promotions, you may be asked to provide additional personal information such as a physical mailing address. In each such case, no new personal information will be collected from you without your consent. This information may be collected by VPG or by third parties such as co-sponsors or vendors for the promotion. VPG s use of any such information will be governed by this Policy. The names of third parties such as co-sponsors (other than vendors hired by VPG to conduct, administer, and execute a promotion on behalf of VPG) will be disclosed to you when you are asked to sign up for the promotion. You should review such third parties privacy policies to see how they may use any information that they collect.
Online Purchases and Technical Support
Issues related to customer service, billing questions, or technical and computer support, etc. may also require you to provide us with some personal information (such as such as your real name, email address, street address, etc.) so that we may resolve the issue properly.
Online Games
When you play any of the games offered and/or served by VPG or use any of the communication features on the Sites, your IP address (the Internet protocol address from which you access any of the above) may be stored in our records. When any game is updated or patched, our patch routine may check your device to see that you have the most recent version of game-specific files; when you communicate within any game, even privately to another person, you do so with the understanding that those communications go through our servers and could potentially be monitored by us. Consequently, you should have no expectation of privacy in any of those communications and, accordingly, you expressly consent to our monitoring of any / all communications (including technical support and customer service communications) that you send and receive through our services. When you log into one of our online games, your device specifications (such as its CPU type, RAM, video resolution, etc.) may be reviewed/recorded by us for the purposes of analyzing and optimizing your game experience and in order to provide you with customer service.
Resume Submissions and Business Capacity
VPG allows for the online submission of resumes. Please be advised that information (including personal information) contained in a job applicant s resume or otherwise submitted to VPG in a business capacity is not subject to the terms of this Privacy Policy. The information obtained from your resume will only be used for the purpose of evaluating your submission for potential employment and contacting you in connection with that purpose.
What non-personal information we collect from you
General, aggregated, demographic, and non-personal information may be collected by VPG. It will not be linked to any of your personal information, through cookies or other means, without your consent. This type of anonymous, aggregated profiling and session data may include information that you have provided to us through surveys, polls, etc., but will not be tied to any personal information without your consent. It may also include aggregated anonymous information about site usage and the customer base.
As part of the registration process for some services, you may be asked to provide information that does not personally identify you. For example, you may be asked to provide information concerning your entertainment preferences, purchasing habits, and the like. This information is generally optional but may be included in your account profile and tied to personal information. VPG requests this information to understand you better and to also bring to your attention new services, programs, or offers that may be of interest to you.
In many cases, VPG will automatically collect certain non-personal information about your use of its sites and services. VPG might collect, among other things, information concerning the type of Internet browser or computer operating system you are using, the domain name of your Internet service provider, your click path through the VPG site, and the web site or advertisement that was linked to or from the VPG site when you visited. To do this, VPG may use cookies and other technology (see below). Your visits to our web sites, and information provided through these technologies, will be anonymous unless you provide us with personal information or have provided such information in the past. This information is anonymized and used on a statistical basis for further improving VPG's services and offerings.
Information on cookies and related technology
VPG web sites, and some services and advertisements on such sites, may contain cookies. A cookie is a small data packet that is sent from VPG's servers over the Internet connection to your device, which will temporarily store the cookie if it is set to accept such cookies. Upon request by VPG s servers, your device is subsequently able to present that cookie back to securely prove its trusted identity, which is at times necessary when switching between different portions of the sites as well as different VPG servers. Clear GIFs (also known as web beacons ) assist in the delivery of cookies.
VPG uses cookies, clear GIFs, frames, server log analysis and other technology to optimize and customize your experience with our various sites and services. Any personal information that is incidentally collected through the use of these technologies will be handled according to this Policy.
Cookies are passive things. They are not programs. They are akin to an ID card that is issued to your device and can then be subsequently presented by your device to prove its identity (for example, to prevent repeatedly having to enter your username and password when switching between pages). Cookies were invented in 1994, and today are one of the most common web technologies on the Internet.
Most devices and even internet browsers allow you the full power to erase cookies from your device, block the acceptance of new cookies, or receive a warning and choice-to-approve before any given cookie is stored. You should refer to your device and/or browser instructions or Help screen to learn more about how to manage cookies. Please note, however, that if you choose to block cookies, the portions of the VPG web sites and services that rely on cookies may no longer function properly.
How we use and share the information that we collect from
you
Personal information which we collect for a particular purpose will only be saved and used for that purpose, unless you have agreed to allow us to use it for some other purpose, as described in this Policy.
When you have provided personal information to us for a particular purpose, we may disclose your information to other companies that we have engaged to assist us in fulfilling your request. We may also disclose any of your personal information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, or other suspected illegal activities, or as otherwise may be required by applicable law, or, as we deem necessary in our sole discretion, in order to protect the legitimate legal and business interests of VPG.
We may use the information we collect from you for the purpose of providing you with technical support, customer service, and account maintenance. We use the information we collect to learn what you like, tailor your experience accordingly, and to improve web sites and our other products. We send e-mail to our members who want to receive e-mail from us. However, if you don t want to receive e-mail from us, you can opt out of receiving it at the time you register as a member on our web sites, within our services or each time we request information from you. If you change your mind and wish to stop receiving e-mails from us, you may also choose to opt out by following the steps described in each such e-mail.
Except as described in this policy, we will not give any of your personal information to any third-party without your express approval, and the only personal information we will ask you if you want us to share with third parties is your name, your mailing address and e-mail address. We sometimes share general, demographic, or aggregated (not personal) information with third parties about our user base, but that information does not include any personal information.
You will be deemed to have consented to the disclosure to, and use by, a subsequent owner or operator of the Sites, of any personal information contained in the VPG database for such site, if VPG or one of its companies assigns all of its rights and obligations regarding the use of your personal information at the time of a bankruptcy, merger, acquisition, sale of all or substantially all of VPG s or such VPG company s assets to a subsequent owner or operator, or similar event.
Information about links and third parties related to our
sites and services
This Policy applies only to information collected online by VPG through web sites maintained by VPG and affiliated companies that VPG may own or control. From time to time, we may provide links to third-party web sites. This Policy does not apply to third-party web sites, whether we provide a link to such sites or not, so we encourage you to review the policies of all such sites carefully, as your rights will be governed by those third-party policies and not by VPG s. Additionally, there may be unauthorized third-party web sites that may be providing links from their sites to our web sites without our knowledge or control. We are not responsible for the content of any third-party web sites, expressly disclaim any statements or assertions made on such web sites, and deny all liability associated with your use of, and the content on, such other sites or advertisements contained therein.
How you may access, change, or delete the information you
have provided to us
If you change your mind and do not want to receive e-mails from us and/or to have us share your name and e-mail address (or other personal information) with third parties, you may send an e-mail to us at info@virtualplaygames.com. Subject to security and privacy concerns (e.g., regarding your password, etc.), we will give you the ability to review, correct, delete, and/or update your information. To do so, you may send us an e-mail at info@virtualplaygames.com. You may also contact us via physical mail at the following address:
Attention: Privacy Officer
Virtual Play Games, Inc.
171 Pier Ave # 169
Santa Monica, CA 90405
If you choose to have your personal information removed from our active databases, we will take prompt action to do so within a reasonable time after your request and we will take all reasonable steps to ensure that your personal data is not used (except as may be required by law, or in an anonymized fashion) by VPG after we have received your notification.
Other important agreements that govern your use of our
sites and services
In addition to this Policy, your rights and obligations concerning our web sites, services, and online games are governed by the applicable web site terms of service, the applicable game s end user license agreement and/or terms of use, and other applicable policies, guidelines, and requirements. When you sign up to use our services, please review each such agreement carefully, as you must agree to be bound by each such agreement before you may use the service.
Information for persons outside the United States
By consenting to this Policy, you confirm that your command and knowledge of English (or in some cases, French, Russian, German, or Spanish) is sufficient to understand the terms and conditions set forth herein.
For persons in European Union countries, as used herein, terms such as personal information refer to personal data as defined by the Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ( Directive ). We will not collect any personal data from you unless you provide it voluntarily by providing us with your freely given specific and informed consent. By using VPG websites or services, you agree that we may transfer your personal information outside the European Union in connection with the purposes stated in this Policy. Your personal data may be transferred to our servers in the United States (and/or other non-EU jurisdictions, as applicable).
In certain countries other than the United States, some of our online games and the services related thereto, may be provided to you by third-party distribution partners. To the extent that a third-party distributor is providing services related to your account, you understand and agree that each such distributor will collect and use your personal information in accordance with its own privacy policies (which you will have access to when you register to play). To the extent that VPG collects or retains any of your personal information, its use will continue to be governed by the terms of this Policy.
In compliance with the EU GPDR, VPG provides eight subject data rights to its users:
All individual users of VPG services are free to exercise their rights and can contact us via e-mail or physical mail at the above-provided addresses in order to do so.
Please note that the "right to be forgotten" does not fully encompass historical financial transactions, which may be required by law to be tracked for purposes of taxation.
Our commitment to secure the personal information we have
collected
While VPG takes best-practice precautions against possible breaches in its web sites and customer databases, utilizing current SSL Encryption, IP Address restriction, Firewalls with Stateful Packet Inspection, Port Restriction and much more, no web site or Internet transmission is completely secure. Zero-day exploits continue to be found that allow for unexpected breaches to occur even when all known, current threats have been countered. Consequently, neither VPG nor any other online service provider can fully guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Consequently, you expressly acknowledge that your use of all VPG sites and services is wholly at your own risk, and agree to hold VPG harmless from any liability that could potentially descend from any such unauthorized access, hacking, data loss, or other breaches. VPG urges you to take steps to keep your personal information safe by choosing a unique password for their services, memorizing that password or (if written down) keeping it in a safe place separate from your account information, logging out of your user account whenever you are finished using VPG services, and fully closing our games, then locking your devices so that a passcode is required before entry.
Whenever you give VPG sensitive or confidential information, VPG will take commercially reasonable steps to protect the information by establishing a secure connection with your device. VPG also utilizes third parties to handle extremely confidential information such as credit card data, and as per best practices, does not store or retain such highly confidential data at all.
Notice of changes to the Policy
VPG reserves the right to update this Policy at any time by notifying registered users via e-mail of the existence of a new Policy and/or posting the new Policy on the VPG sites. All changes to the Policy will be effective when posted, and your continued use of any VPG site or service after the posting will constitute your acceptance of, and agreement to be bound by, those changes.