Last Updated: June 22, 2022
PERSONAL INFORMATION WE COLLECT
Personal Information You Provide to Us. Personal information you provide to us through the Services or otherwise may include:
- Contact information, such as your first and last name, email address, mailing address, and phone number.
- Content you choose to upload to the Services, such as text, images, audio, and video, along with the metadata associated with the files you upload.
- Registration information, such as information that may be related to a service, an account, or an event you register for.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
- Your responses, answers and other input, such as the answers you submit to one of our quizzes and other responses and information that you provide when using the Services.
- Contest or giveaway information, such as your contact and other information you submit when entering a prize drawing or sweepstakes in which we participate or host.
- Demographic Information, such as your city, state, country of residence, postal code, and age.
- Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Services.
- Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications.
Some features of the Services may allow you to connect to your account on a third-party platform or social media network. If you choose to do so, we may collect information from that platform or network. For example, this information may include your social media handle, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address. You can read more about your privacy choices in the Your Choices section below.
Personal Information we Obtain from Other Third Parties. We may receive personal information about you from our affiliates and from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, sweepstakes providers, contest partners, publicly-available sources, and data providers.
Referrals. Users of the Services may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.
Cookies and Other Personal Information Collected by Automated Means. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity occurring on or through the Services. The information that may be collected automatically may include:
- Online activity data, such as the website you visited before browsing to the Services, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
- Device data, such as your computer or mobile device operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, and general location information such as city, state, or geographic area.
Our service providers and business partners may collect this type of information over time on the Services and across third-party websites and mobile applications.
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies, and our emails may also contain web beacons and similar technologies. In our mobile applications, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our Services.
See the Cookies and Similar Technologies section below for more information.
HOW WE USE YOUR PERSONAL INFORMATION
To Operate the Services. We use your personal information to:
- personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested
- respond to your customer service and other requests, questions and feedback
- provide, operate and improve the Services, such as when we administer a contest, promotion, survey or other feature of the Services
- send periodic emails or other products and services
- follow up with you and offer email support
- provide information about our products and services
- establish and maintain your user profile on the Services and keep track of any points you earn from our quizzes or trivia games
- facilitate social features of the Services, such as by identifying and suggesting connections with other users of the Services and providing chat or messaging functionality
- display leaderboards and similar features, such as by displaying your username, trivia score and rank to other users of the Services
- communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages
- communicate with you about events or contests in which you participate
- understand your needs and interests, and personalize your experience with the Services and our communications
- provide support and maintenance for the Services
To Display Advertisements. We partner with advertising partners and other third parties that collect information across various channels, including offline and online, for purposes of displaying advertisements on the Services or elsewhere online and delivering more relevant advertising to you. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere. Our partners may use your information to recognize you across different channels and platforms, including but not limited to, computers and mobile devices, over time for advertising (including addressable TV), analytics, attribution, and reporting purposes. For example, our partners may deliver an ad to you in your web browser based on a purchase you made in a physical retail store, or they may send a personalized marketing email to you based on the fact that you visited a particular website. To learn more about your choices in connection with advertisements, please see the Advertising Choices section below.
To Send You Marketing and Promotional Communications. We may send you marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt-Out of Marketing Communications section below.
For Research and Development. We analyze use of the Services to analyze and improve the Services and to develop new products and services, including by studying user demographics and use of the Services.
To Manage Our Recruiting and Process Employment Applications. We use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.
To Comply with Law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
For Compliance, Fraud Prevention, and Safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; (d) maintain the safety, security, and integrity of our Services, products and services, business, databases and other technology assets; and (e) audit our internal processes for compliance with legal and contractual requirements and internal policies.
With Your Consent. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To Create Anonymous, Aggregated or De-Identified Data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
COOKIES AND SIMILAR TECHNOLOGIES
Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites. A SDK is third-party computer code that we may incorporate into our mobile applications that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our apps, or to facilitate online advertising.
Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the Advertising Choices section below for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.
HOW WE SHARE YOUR PERSONAL INFORMATION
Affiliates. We may share your personal information with our parent companies, affiliates, subsidiaries, and other companies that control Crossword Club or are under common control with an entity that controls Crossword Club.
Sweepstakes and Joint Marketing Partners. We may also share your personal information with other partners in order to provide you with content and other features through the Services, and such partners may send you promotional materials or otherwise contact you regarding products and services that they offer. When you choose to enter a contest or sign up for a sweepstakes, we may share the personal information you provide as part of the offer with the named co-sponsors or other third parties affiliated with such offer.
Third-Party Platforms and Social Media Networks. If you have enabled features or functionality that connect the Services to a third-party platform or social media network (such as by logging in to the Services using your account with the third-party, providing your API key or similar access token for the Services to a third-party, or otherwise linking your account with the Services to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.
Other Users of the Services and the Public. We may provide functionality that enables you to disclose personal information to other users of the Services or the public. For instance, you may be able to maintain a user profile with information about yourself or your use of the Services that you can make available to other users or the public. You may also be able to submit content to the Services (such as comments, questions, stories, reviews, surveys, blogs, photos, and videos), and we will identify you by displaying information such as your name, username, social media handle, or a link to your user profile along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.
Professional Advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Law Enforcement, Authorities, and Others. Under certain circumstances, we may be required to disclose your personal information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). We may also disclose your personal information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled For Compliance, Fraud Prevention, and Safety.
Business Transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, joint venture, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
In this section, we describe the rights and choices available to all users.
Opt-Out of Marketing Communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at email@example.com. You may continue to receive service-related and other non-marketing emails.
Advertising Choices. Some of the business partners that collect information about users’ activities on or through the Services may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.
Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Users of our mobile applications may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based ads from other companies.
Some advertising companies we work with may also offer their own opt-out mechanisms. For example, you can learn more about opting out of the cookie-based portions of the LiveIntent Advertising Program by clicking here or from LiveRamp by clicking here, or from Google’s collection of your personal information by clicking here. In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.
Many of the opt-out preferences described in this section must be set on each device and/or browser for which you want them to apply. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Choosing Not to Share Your Personal Information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.
Third-Party Platforms or Social Media Networks. If you choose to connect the Services to a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you connect. Subsequently, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party.
OTHER SITES, MOBILE APPLICATIONS AND SERVICES
Occasionally, the Services may contain links to third-party websites, mobile applications, products or other services. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
INTERNATIONAL DATA TRANSFERS
We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.
The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.
IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
This section applies only to California residents. It describes how we collect, use and share personal information of California residents in operating our business, and their rights with respect to that personal information. For purposes of this section, “personal information” has the meaning given under California privacy laws but does not include information exempted from the scope of those laws.
Your California Privacy Rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Access. You can request the following information about how we have collected and used your personal information during the past 12 months:
- The categories of personal information that we have collected.
- The categories of sources from which we collected personal information.
- The business or commercial purpose for collecting and/or selling personal information.
- The categories of third parties with whom we share personal Information.
- Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of third party recipient.
- Whether we’ve sold your personal information, and if so, the categories of personal information received by each category of third party recipient.
- A copy of the personal information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the personal information that we have collected from you.
- Opt-out of sales. If we sell your personal information, you can opt-out. In addition, if you direct us not to sell your personal information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
- Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your personal information before we do so.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.
How to Exercise Your Rights. You may exercise your California privacy rights described above as follows:
- Right to access and deletion. You can request to exercise your access and deletion rights by:
- visiting crosswordclub.com/ccpa
- emailing firstname.lastname@example.org – Please put the statement “CCPA Consumer Request” in the subject line.
- Right to opt-out of the “sale” of your Personal Information. Like many companies, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under California law as a “sale” of your personal information to the companies that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you and for other advertising purposes. You can request to opt-out out of this “sale” of your personal information by clicking here: Do Not Sell My Personal Information. You can exercise this opt-out by toggling “off” the button next to “Sale of Personal Data” and clicking “Confirm My Choices” button at the bottom of the opt-out screen.
We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your access or deletion rights. This is a security measure to help ensure we do not disclose information to a person who is not entitled to receive it. Consistent with California law, you may designate an authorized agent to make a request on your behalf. If you do so, we may require the requester’s proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests.
Category of personal information
Personal information types that include information we collect in that category
Contact information, your content, registration information, feedback or correspondence. Contest or giveaway information, usage information, marketing information, social media platform data, referral information.
Registration information, contest or giveaway information, usage information, marketing information
Usage information, marketing information, social media platform data, device data, online activity data and other information collected by automated means
Internet or Network Information
Device data, online activity data and other information collected by automated means
May be derived from: Your responses, contest or giveaway information, demographic information, usage information, marketing information, device data, online activity data and other information collected by automated means
Professional or Employment Information
Protected Classification Characteristics
Your responses, demographic information may also be revealed in other information we collect, such as profile information or your content
Content you choose to upload to the Services
- For information about:
- The categories of sources of this personal information, see the section above Personal Information We Collect.
- The business/commercial purposes for which we collect and share this personal information, see the section above How We Use Your Personal Information.
- Commercial Information
- Online Identifiers
- Internet or Network Information
- Other information included in your responses, your demographic information, or that you provide to us.
Please see the table above and the Personal Information We Collect section for more information about what these categories of personal information include.
Notice of Financial Incentive. We may offer certain financial incentive programs that can result in different levels or quality of services to you, provided that such programs are reasonably related to the value of your personal information to us. For example, we may offer additional content to users who sign up for our mailing list, or giveaways, sweepstakes, contests, or other similar promotional campaign. We typically ask you to provide your email address or other contact information in order to participate in these programs or campaigns.
We offer these programs and campaigns because, among other things, the value of your personal information to us is related to the value of the free or discounted services, or other benefits that you obtain or that are provided as part of the applicable program or campaign. This value is based on the expense related to offering those services and benefits to participants, along with other factors such as whether and to what extent you take advantage of (or opt-out from) any offerings and whether we are able to use the data we collect from you.
When we offer any program or campaign, there is no obligation to opt-in, and you may withdraw at any time by contacting us using the designated method set forth in the applicable program rules or in the Contacting Us section below. Please review the applicable program or campaign offering or terms to view full details, including how to join.
Crossword Club LLC
3419 Via Lido, #657
Newport Beach, CA 92663