Peak California Privacy Notice Effective Date: 4 July 2022
Scope of Supplemental Notice
This Notice provides additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 ("CCPA").
Collection and Use of Personal Information
When we use the term "personal information" in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
In the last 12 months, we have collected the following categories of personal information about consumers for the following purposes.
|Category of Personal Information||Categories of Sources||Commercial or Business Purpose|
|Identifiers, such as name, address, email address, user ID and password, or other similar identifiers||
|Commercial Information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||
|Internet/Network Information, such as website, application or advertisement browsing history.||
|Geolocation Data, such as IP address, device shared location, and Wi-Fi connection location.||
|Inferences drawn from the above categories of personal information about consumer preferences, characteristics, behavior, attitude and aptitudes.||
Disclosure of Personal Information
In the last 12 months, we have disclosed the following categories of personal information to a variety of third parties for business purposes:
- Commercial Information
- Internet/Network Information
- Geolocation Data
“Sales” and Online Advertising
Peak does not "sell" personal information about our players as most people would typically understand that term. However, we do allow certain third-party advertising partners to collect personal information about consumers through our games and our website for purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for ad fraud detection and reporting, which could constitute "sales" of personal information under the CCPA.
In the last 12 months, we have shared identifiers, commercial information internet and network information and inferences about our players with our advertising partners for the purposes of cross-context behavioral advertising. We have not sold geolocation data about our players.
Advertisements that are tailored for your interests may include banner ads on game boards or in Services, full-screen ads between moves or games or ads made available through an “offer wall” (in which advertisers offer virtual currency or other in-game items to players in exchange for watching an advertisement, signing up for an account, completing a survey or performing some other activity). Offer walls are hosted by third-party offer wall providers, and the offers are made by third-party advertisers, not by Peak.
In addition to serving you with relevant ads, the information collected may be used to:
- measure how effective advertising campaigns are
- offer you targeted advertising in third party services for products and services that are more likely to appeal to you
- undertake web analytics to analyze traffic and other player activity
- improve our Services
These third parties may use this personal information for their own commercial purposes in accordance with their own privacy policies, which may include providing this information to additional third parties, including other advertising networks.
Please note, after clicking on a third-party advertisement or offer, you may no longer be on a site or app controlled by Peak or the social network through which you are playing Peak’s games.
If you do not want to receive tailored in-application advertisements, please see the How to Exercise Your California Privacy Rights section below or view our Cookies Notice.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):
The Right to Know
You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:
The Right to Request Deletion
You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt-Out of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of the rights described above.
However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
"Shine the Light"
California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s "Shine the Light" law (Civ. Code § 1798.83).
How to Exercise Your California Privacy Rights
To Exercise Your Right to Know or Right to Deletion
To exercise your right to know and right to deletion, please submit a request by emailing [email protected] with the subject line "California Rights Request".
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and the right to deletion, certain requests may require us to obtain additional personal information from you. We will only use personal information provided in with a consumer rights request to review and comply with the request. In certain circumstances, we may decline a request to exercise the right to know and right to deletion, particularly where we are unable to verify your identity.
To Exercise Your Right to Opt-Out of Personal Information "Sales"
Unless you have exercised your right to opt-out of personal information "sales", we may "sell" personal information to third parties, as that term is defined under California law. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include re"sell"ing this information to additional third parties.
To exercise your right to opt-out, please submit a request by sending an email to [email protected].
Do Not Sell My Info
You do not need to create an account with us to exercise your right to opt-out. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and track compliance with your opt-out request. We will only use personal information provided in an opt-out request to review and comply with the request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems and authenticate you as authorized to receive the information.
Once you make an opt out request, you may change your mind and opt back in to personal information sales at any time by contacting us at [email protected].
"Shine the Light"
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the "Right to Opt In") from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at [email protected] to inform us if you, or your minor child, would like to opt in to “sales”.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
In-Game Rewards & Currency: We offer nominal in-game currency and rewards to users when they choose to watch in-game video advertisements or connect their Facebook account. When a user chooses to receive the in-game currency and rewards, Peak and its advertising partners use the information collected to serve the user with more relevant ads. Video and other relevant advertisements help support the game’s operation. A user can choose not to receive the in-game rewards and currency by electing not to watch in-game advertisements or by disconnecting their Facebook account through Facebook’s user settings.
We may update this California Notice from time to time. When we make changes to this California Notice, we will change the "Effective Date" at the top of this page. If we make material changes to this California Notice, we will notify you by email to your registered email address, by prominent posting on our online services, or through other relevant communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.