1. Introduction
1.1 Welcome to the J REYNOLDS SYSTEMS Services operated by J REYNOLDS SYSTEMS SOFTWARE LLC and its affiliates and related companies (individually and collectively, "J REYNOLDS SYSTEMS", "we", "us" or "our"). J REYNOLDS SYSTEMS takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all users of our J REYNOLDS SYSTEMS games ("Games"), websites and mobile applications ("Websites") (we refer to the Games, Websites and other services mentioned in our Terms of Service as the "Services"). User means anyone who registers for an account or otherwise uses or accesses the Services (individually and collectively, "User", "you" or "your"). We recognize the importance of the personal data you entrust to us and believe it is our responsibility to properly manage, protect and process your personal data. This policy (the “Privacy Policy”) is designed to help you understand how we collect, use, disclose, transfer or process personal data that you provide to us or that we have about you, now or in the future, and to assist you in making an informed decision before providing us with any of your personal data. Capitalized terms used in this Privacy Policy that are not otherwise defined have the meanings ascribed to them in the J REYNOLDS SYSTEMS Terms of Service.
1.2 “Personal Data” or “Personal Data” means data about an individual, whether true or not, from which that individual can be identified, or from that data and other information to which an organization has or may have access. Common examples of Personal Data may include name, identification number and contact information.
1.3 By using the Services, registering for our account or visiting our Website, you acknowledge and agree that you are accepting the practices, requirements or policies outlined in this Privacy Policy, and you hereby consent to our collection, use, disclosure or processing of your personal data as described herein. If you do not consent to the processing of your personal data as set out in this Privacy Policy, please do not use our Services or visit our games or websites. If we change our Privacy Policy, we will notify you by posting those changes or the revised Privacy Policy on the Website. We reserve the right to modify this Privacy Policy at any time. To the maximum extent permitted by applicable law, your continued use of the Services or Website, including making any purchases or orders, will constitute your acknowledgement and acceptance of the changes to this Privacy Policy.
1.4 This Policy applies in conjunction with other notices, contractual terms, consent terms that apply to our collection, storage, use, disclosure or processing of your personal data, and this Policy is not intended to override those notices or terms unless we expressly state otherwise.
2. When does J REYNOLDS SYSTEMS collect personal data?
2.1 We will/may collect personal data about you:
• When you register for or use our services, games or websites;
• When you submit any form, including but not limited to application forms or other forms related to any of our products and services, whether online or via physical forms;
• When you enter into any agreement or provide other documents or information related to your interaction with us, or when you use our products and services;
• When you interact with us, for example by telephone (which may be recorded), letter, fax, face-to-face meetings, social media platforms and email, including when you interact with our customer service agents;
• When you use our electronic services, or interact with us through our games or websites or use our services. This includes, but is not limited to, cookies we may deploy when you interact with our games or websites;
• When you grant permission on your device to share information with our mobile applications or websites;
• When you conduct transactions through our games or websites (as applicable) or with our authorized third-party payment service providers;
• When you provide us with feedback or complaints;
• When you register for a tournament, game or game-specific event;
• During the course of a game;
• When you submit personal data to us for any reason.
The above is not exhaustive and sets out some common circumstances when personal data about you may be collected.
3. What personal data does J REYNOLDS SYSTEMS collect?
3.1 Personal data J REYNOLDS SYSTEMS may collect Information you provide, information collected automatically, and information from other sources. This information may include, but is not limited to:
• Name, username, and user ID;
• Contact information (including email address, phone number, or address);
• Transaction information, including bank account and payment information (where applicable and subject to applicable law);
• Chat data (including voice, text, or other communications) and other information about the people and accounts you interact with;
• Gender, age, or date of birth;
• Information sent by or associated with the device you use to access our Services;
• Images, audio, video, or other content you submit through the Services
• Location-related information, including IP address;
• Government-issued identification or other identification you share with us, where applicable;
• Marketing and communications data, such as your preferences for receiving marketing materials, your communications preferences, and communications history with us and our service providers;
• Survey responses. information you provide to us in connection with a contest, competition or competition, or other information;
• Any other information about you that you provide when registering for or using the Services, including information shared through any linked social media accounts (“Social Media Accounts”); and
• Usage and transaction data, including data about your activities, orders, use of the Services, and advertisements and other content you engage with.
3.2 You agree not to submit any inaccurate or misleading information to us, and you agree to notify us of any inaccuracies or changes to such information. We reserve the right, at our sole discretion, to request additional documentation to verify the information you provide, subject to applicable law.
3.3 If you do not wish us to collect the above information/personal data, you may opt-out at any time by notifying our Data Protection Officer in writing. For more information on opting out, please see the section below titled “How can you withdraw consent, delete, request access to, or modify information you have provided to us?” Please note, however, that opting out or withdrawing your consent for us to collect, use, or process your personal data may affect your use of the Services.
4. Collection of Other Data
4.1 Like most websites and mobile applications, the information sent by your device may include data about you that is logged by web servers when you use our Services. This typically includes, but is not limited to, your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, mobile device type, characteristics of your mobile device, your mobile device’s unique device identifier (UDID) or mobile device identifier (MEID), the address of the referring website (if any), the pages you visited on our websites and mobile applications and the time of your visit, and sometimes “cookies” (which can be disabled using your browser preferences) to help websites remember your last visit. If you are logged in, this information will be associated with your personal account. This information is also included in anonymous statistics so that we can understand how visitors use our games and websites.
4.2 Our mobile applications may use GPS, Wi-Fi, We collect precise information about the location of your mobile device using technologies such as WhatsApp and Facebook. We collect, use, disclose or process this information for one or more purposes, including but not limited to location-based services you request, or to provide you with relevant content based on your location, or to allow you to share your location with other users as part of the services under our mobile applications. For most mobile devices, you can revoke your permission for us to obtain this information about your location through your device settings. If you have questions about how to disable location services for your mobile device, please contact your mobile device service provider or device manufacturer.
4.3 When you view pages or content on our websites or mobile applications, most of the same information is sent to us (including but not limited to IP addresses, information about your operating system, etc.); however, instead of page views, your device sends us information about the content, ads viewed or software installed, and when.
5. Cookies
5.1 We or our authorized service providers and advertising partners may from time to time implement "cookies" or other features that allow us or third parties to collect or share information related to your use of the Services. These features help us improve our Sites, Games and the Services we offer, help us offer new Services and features, or enable us and our advertising partners to provide you with more relevant content, including through remarketing, subject to applicable law. "Cookies" are identifiers that we transfer to your computer or mobile device to record data about your computer or device, how and when you use or visit the Services or Sites, how many people use them, and other activities on our Sites and Games. We may associate cookie information with Personal Data. Cookies may also be linked to information about items you choose to purchase, pages you view, or games you play. Depending on the relevant Service, this information may be used to keep track of your shopping cart, deliver content specific to your interests, enable us or our third-party advertising partners to serve advertising through the Services or sites on the Internet, and monitor usage of the Services.
5.2 You may refuse the use of cookies or web beacons by selecting the appropriate settings on your browser or device or adjusting your preferences. However, please note that if you do this, you may not be able to use the full functionality of our Sites, Games or Services.
5.3 You can also opt out of personalized advertising on certain mobile applications by following the instructions for Android and iOS.
6. How do we use the information you provide to us?
6.1 We may collect, use, disclose or process your personal data for one or more of the following purposes:
(a) Consider or process your application/transaction with us, or your transactions or communications with third parties through the Services;
(b) Manage, operate, provide or administer your use of or access to our Services, Websites and Games (including, without limitation, your preferences), and your relationship with us and user account;
(c) Respond to, process, handle or complete transactions or fulfill your requests for certain products and services, and notify you of service issues and unusual account activity;
(d) Enforce our Terms of Service or any applicable end user license agreement;
(e) Protect the personal safety and rights, property or security of others;
(f) For identification or verification;
(g) Maintain, manage and improve any software updates or other updates, support the Services, including troubleshooting, reporting or resolving any issues that may be required (e.g., responding to bug or crash reports) to ensure the smooth operation of the Games or Services;
(h) Process or facilitate customer service, carry out your instructions, process or respond to any inquiries made by you or on your behalf (or purportedly made by you);
(i) To contact or communicate with you by voice call, text message or fax, email or postal mail or other means in order to administer or manage your relationship with us or your use of our Services, such as, but not limited to, communicating to you administrative information related to our Services. You acknowledge and agree that we may make such communications by posting letters, documents or notices to you, which may involve the disclosure of certain personal data about you to effectuate the delivery of the same, and on the outer cover of the envelope/mailing package;
(j) allow other users to interact, communicate or contact you, including notifying you when other users send you private messages or post comments for you through the Game or the Website;
(k) conduct research, analysis and development activities (including but not limited to data analysis, surveys, product and service development or analytics) to analyse how you use our Services, improve our Services or products or enhance your customer experience;
(l) allow advertising and other audits and surveys (through offline and online surveys, including on third-party platforms such as Google Forms) to verify the size and composition of our target audience and understand their experience of J REYNOLDS SYSTEMS Services;
(m) marketing and advertising for any marketing campaigns, and for that matter, recommend products or services relevant to your interests, send you product or service related communications, marketing and promotional information and materials through various media and methods (including email or SMS) (including but not limited to: J REYNOLDS SYSTEMS (or its subsidiaries or affiliates) may sell, market or promote the products or services of third parties with whom J REYNOLDS SYSTEMS may work or collaborate, whether such products or services exist now or are created in the future. You may unsubscribe from marketing messages at any time by using the unsubscribe function in electronic marketing materials. We may use your contact information to send newsletters or marketing materials from us and our affiliates;
(n) respond to legal process or comply with or as required by any applicable law, governmental or regulatory request in any relevant jurisdiction, including without limitation making disclosures pursuant to any legal requirement binding on J REYNOLDS SYSTEMS or its related companies or affiliates;
(o) produce statistics and research for internal and statutory reporting or record keeping requirements;
(p) conduct due diligence or other screening activities (including without limitation background checks) in accordance with legal or regulatory obligations or as may be required by law or as part of our risk management procedures that we may have implemented;
(q) audit our services or J REYNOLDS SYSTEMS’s business;
(r) To prevent or investigate any actual or suspected breach of our Terms of Service, fraud, illegal activity, omissions or misconduct, whether in connection with your use of our Services or any other matter arising out of your relationship with us;
(s) To store, host, back up (whether for disaster recovery or other purposes) your personal data, whether in or outside your jurisdiction;
(t) To process or facilitate business asset transactions or potential business asset transactions, if such transactions involve J REYNOLDS SYSTEMS as a participant, or involve only J REYNOLDS SYSTEMS’s affiliates or subsidiaries as participants, or involve J REYNOLDS SYSTEMS or any one or more of J REYNOLDS SYSTEMS’s affiliates as participants, and there may be other third-party organizations that are participants in such transactions. "Business Asset Transaction" means the purchase, sale, lease, merger, consolidation or any other acquisition, disposal, transfer or financing of an organization or a portion of an organization, its business activities or assets; or
(u) verifying your eligibility or submitting your application/request when you register for a Game-specific contest, event or tournament and providing you with rewards, if applicable; and
(v) other purposes permitted by applicable law and as notified to you by us at the time we obtain your consent.
(collectively, the "Purposes").
6.2 You acknowledge, consent and agree that J REYNOLDS SYSTEMS may access, preserve and disclose your account information and content if required to do so by law or pursuant to an order of a court or any governmental or regulatory authority with jurisdiction over J REYNOLDS SYSTEMS or in the good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority with jurisdiction over J REYNOLDS SYSTEMS, (c) enforce the J REYNOLDS SYSTEMS Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claim against J REYNOLDS SYSTEMS or other claim that any content infringes the rights of a third party; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of J REYNOLDS SYSTEMS, its users or the public.
6.3 As the purposes for which we will likely collect, use, disclose or process your personal data will depend on the circumstances at hand, such purposes may not appear above. However, we will inform you of such other purposes when we obtain your consent, unless the Privacy Laws permit the processing of applicable data without your consent.
7. How does J REYNOLDS SYSTEMS protect and retain customer information?
7.1 We implement various security measures and operational controls and strive to ensure the security of your personal data on our systems. User personal data is contained behind secure networks that are only accessible to a limited number of employees who have special access rights to such systems. However, it is inevitable that absolute security cannot be guaranteed.
7.2 We will retain personal data in accordance with the Privacy Law or other applicable laws. That is, when we reasonably determine that (i) retaining such personal data no longer serves the purpose for which the personal data was collected; (ii) retention is no longer necessary for any legal or business purpose; and (iii) there is no other legitimate interest justifying further retention of such personal data. If you stop using our services, or your license to use the Site, Games or Services is terminated or revoked, we may continue to store, use or disclose your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. We may process your personal data securely and without prior notice to you, in accordance with applicable laws.
8. DOES J REYNOLDS SYSTEMS DISCLOSE INFORMATION IT COLLECTS FROM VISITORS TO EXTERNAL PARTIES?
8.1 In conducting our business, we will/may need to disclose your personal data to our third-party service providers, agents or our subsidiaries or affiliates or other third parties, whether located in or outside the United States, for one or more of the purposes listed above. Such third-party service providers, agents or affiliates or related companies or other third parties will process your personal data on our behalf or otherwise for one or more of the purposes listed above. Such third parties include, but are not limited to:
• Our subsidiaries, affiliates and related companies;
• Other users of our Services in connection with your use of the Services and one or more of the purposes listed above;
• Contractors, agents, service providers and other third parties that we use to support our business. These include, but are not limited to, organizations that provide administrative or other services to us, such as post offices, our game development partners, payment or financial services providers, advertising and marketing partners, telecommunications companies, game development partners, information technology companies and data centers;
• Governmental or regulatory authorities with jurisdiction over J REYNOLDS SYSTEMS, or such other authorities as permitted under Section 6.2;
• In the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of J REYNOLDS SYSTEMS’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, or a transition of any of our Services, in which personal data held by J REYNOLDS SYSTEMS about our users is among the assets transferred; or a counterparty in a business asset transaction in which J REYNOLDS SYSTEMS or any of its subsidiaries or affiliates is involved, including any entity that succeeds or to which we transfer the operations of any of our Services; and
• Third parties to whom we disclose your information for one or more of the Purposes, and such third parties will in turn collect and process your personal data for one or more of the Purposes.
8.2 We may disclose, among other things, your game history or disclose records showing which IP addresses have viewed or accessed which games. We may also share statistical and demographic information about our users and their use of the Services with advertising partners and third-party vendors of advertising, remarketing and other programming, subject to applicable law.
8.3 In addition, you may choose to export your user activity feeds as RSS feeds to which other users may subscribe, which may include information about your games, game installations, contacts with other users, and other information about your account activity that is posted as a feed on the Site or in the Game.
8.4 For the avoidance of doubt, to the extent that privacy laws or other applicable laws permit an organization like us to collect, use or disclose your personal data without your consent, such permission granted by law will continue to apply.
8.5 Personal data transmitted to or contained on the Site may be unlawfully intercepted or accessed by third parties, technology may malfunction or fail to work as intended, or someone may access, abuse or misuse information through no fault of ours. Nonetheless, we will deploy reasonable security arrangements to protect your personal data as required by privacy laws; however, it is inevitable that absolute security cannot be guaranteed, such as, but not limited to, unauthorized disclosure caused by malicious and sophisticated hacker attacks without our fault.
9. Children's Information
The Services are not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally identifiable information from anyone under the age of 13, and no part of our website, games or other services is directed to them. As a parent or legal guardian, please do not allow such children under your care to submit personal data to J REYNOLDS SYSTEMS, and please consult J REYNOLDS SYSTEMS's Terms of Service for more information. If the personal data of a child under the age of 13 under your care is disclosed to J REYNOLDS SYSTEMS, you hereby consent to the processing of the child's personal data and accept and agree to be bound by the terms of this Privacy Policy on behalf of the child. If you do not actually consent to the processing of the personal data of a child under the age of 13 under your care, please contact our Data Protection Officer. We will close any accounts dedicated to such children and delete or remove any personal data submitted without parental consent from such children or as otherwise required by applicable law.
10. Information collected by third parties
10.1 Our websites and games use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies (text files placed on your device) to help the website analyze how users use our services. The information generated by the cookie about your use of the services or your device (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information to evaluate your use of our services, to compile reports on website activity for website operators and to provide other services related to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
10.2 From time to time, we and third parties may make software applications available for download for use on or through the Services. These applications may separately access and allow third parties to view your identifying information, such as your name, your user ID, your device's IP address, or other information, such as the game you are playing during any given session, and any cookies you may have previously installed or that were installed for you by a third-party software application or website. In addition, these applications may ask you to provide additional information directly to the third party. The third-party products or services offered through these applications are not owned or controlled by J REYNOLDS SYSTEMS. We encourage you to read the terms and other policies posted by such third parties on their websites or other websites.
11. Disclaimer Regarding Security and Third-Party Websites
11.1 We do not guarantee the security of your Personal Data or other information you provide on third-party websites. We do implement a variety of security measures to maintain the safety of your Personal Data in our possession or control. Your Personal Data is contained behind secure networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the Personal Data confidential. When you place an order or access your Personal Data, we provide secure servers. All Personal Data or sensitive information you provide is encrypted into our databases and can only be accessed as described above.
11.2 In an effort to provide you with increased value, we may select various third-party websites to link to and build upon the Site or Games. We may also engage in co-branding and other relationships to provide e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies and security arrangements. We have no control over these linked sites, even if the third party is affiliated with us, and each has separate and independent privacy and data collection practices that are independent of us. We may not receive data collected by our co-branding partners or third-party websites (even if offered on or through our Site or Games).
11.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are for your convenience only and therefore you access them at your own risk. Nonetheless, we seek to protect the integrity of our website and games and the links on each game and therefore welcome any feedback on these linked sites (including but not limited to if a particular link does not work).
12. DOES J REYNOLDS SYSTEMS TRANSFER YOUR INFORMATION OVERSEAS?
12.1 Your personal data or information may be transferred to, stored or processed outside of your country. J REYNOLDS SYSTEMS will only transfer your information overseas in accordance with privacy laws and this policy. By accepting this policy, you consent to the cross-border transfer of your information to any country where our affiliates, developers, servers or databases are located. In most cases, your personal data will be processed in Singapore, where our central databases and servers are operated. As different jurisdictions may have different data protection requirements, we take steps to implement appropriate safeguards to protect your data.
12.2 If you are a user in India, your personal data will be processed and stored on our servers in India or Singapore. J REYNOLDS SYSTEMS will only transfer your information overseas in accordance with privacy laws and you hereby consent to such transfer and processing.
12.3 For more information on the transfer of personal data or information relating to EU users out of the EU, please see the section entitled “Additional Terms Applicable Only to EU Users”.
13. How can you withdraw consent, request access to, or correct information you have provided to us?
13.1 Withdrawal of Consent
13.1.1 You may withdraw your consent to the collection, use or disclosure of, or request deletion of, your personal data in our possession or control by emailing our Data Protection Officer at [email protected]. We will process such requests in accordance with this Privacy Policy and our obligations under applicable privacy and other applicable laws.
13.1.2 However, your withdrawal of consent or request to delete personal data in our possession or control may mean that we will not be able to continue to provide you with services and we may need to terminate your existing relationship or contract with us.
13.2 Requesting access to or correction of personal data
13.2.1 If you have an account with us, you may personally access or correct your personal data currently in our possession or control through the Site or Tab. If you do not have an account with us, you may request access to or correction of your personal data currently in our possession or control by submitting a written request to us. We require sufficient information from you to determine your identity and the nature of your request so that we can process your request. Please submit your written request by sending an email to our Data Protection Officer. In addition, where required by law, we will take steps to notify any third party that has received or used your personal data of such correction.
13.2.2 Where permitted by applicable law, we reserve the right to deny certain requests or may charge you a reasonable fee to process your request to access your personal data. In this case, we will notify you and provide you with a written estimate of any applicable fees. Subject to applicable law, the requested personal data will be provided to you within a reasonable time after you pay the relevant fees.
13.2.3 Please submit your written request by sending an email to our Data Protection Officer. Subject to applicable law, we reserve the right to respond only to data subject requests submitted in accordance with this policy.
14. Other User Rights
14.1 Additional Terms for EU Users Only
14.1.1 The provisions in this section apply only to users located in the EU. These terms prevail over any inconsistent terms in the rest of this Privacy Policy.
14.1.2 Portability
You have the right to obtain from us the personal data you have previously provided to us, and which we process on the basis of your consent, in a structured, commonly used and machine-readable format, and to request that we transfer such personal data to another party. If you would like us to transfer personal data to another party, please make sure you specify that party and note that we can only do so where it is technically feasible. We are not responsible for the security of personal data or for what third parties do with it after it has been received. We may also not provide you with certain personal data if providing that data would interfere with the rights of others (for example, providing personal data we hold about you would reveal information about others).
14.1.3 Erasure
You have the right to ask us to delete the personal data we hold about you in the following circumstances:
(a) you believe that it is no longer necessary for us to hold the personal data we hold about you;
(b) we are processing the personal data we hold about you based on your consent and you wish to withdraw your consent and there is no other reason for us to process the personal data;
(c) we are processing the personal data we hold about you based on our legitimate interests and you object to such processing. Please provide us with details of your grounds so that we can assess whether there is an overriding interest in processing and retaining such personal data;
(d) you no longer want us to use the personal data we hold about you to send you promotions, special offers, marketing and lucky draws; or
(e) you believe that the personal data we hold about you is being unlawfully processed by us.
Please provide as much detail as possible about the reason for your request to help us determine whether you have a valid basis for erasure. However, we may retain personal data if there is a legitimate reason under applicable law (e.g. we have a legal obligation or right to retain certain information in order to exercise or defend legal claims, freedom of expression, etc.), but we will inform you if this is the case. Please note that after deleting personal data, we may not be able to provide you with the same level of service as we are not aware of your preferences and in some cases, you may no longer be able to use our services.
14.1.4 Retention of personal data
We may retain your personal data for as long as necessary to provide you with services or products, or as required or permitted by applicable law (such as tax and accounting laws), or to exercise or defend legal claims. If you make a request to delete personal data and we determine that your request is justified, we will endeavor to delete the personal data within 30 days of your request, or inform you if longer is required.
14.1.5 Objection to profiling and targeted marketing
You have the right to object at any time to our processing of personal data about you for the purpose of sending you promotions, special offers and marketing information, including where we have built a profile for this purpose, and we will cease to process the personal data for this purpose. Please provide as much detail as possible about the reason for your request to help us determine whether you have a valid objection. However, we may retain personal data if there is a legitimate reason to do so by law.
14.1.6 Processing for storage only
You have the right to ask us to limit the processing of personal data we hold about you to storage purposes only in the following circumstances:
(a) you believe the personal data is inaccurate while we verify its accuracy;
(b) we want the personal data to be erased but you want us to only store it;
(c) we want the personal data to be erased because it is no longer necessary for our purposes but you need to store it to establish, exercise or defend legal claims; or
(d) you object to us processing the personal data we hold about you based on our legitimate interests and you want us to stop processing the personal data while we determine whether there is an overriding interest for us to process and retain such personal data.
14.1.7 Transfer of personal data outside the EU
Your personal data may be transferred outside the EU. We take appropriate measures to ensure that recipients of your personal data are subject to confidentiality obligations and implement measures such as appropriate contractual clauses to ensure that recipients of such transfers protect and process your personal data in accordance with all applicable personal data protection laws.
14.1.8 Children’s Information
The Services are not intended for children under the age of 16 located in the EU. We do not knowingly collect or maintain any Personal Data or non-personally identifiable information from anyone under the age of 16 located in the EU, and no part of our Sites, Games, or other Services is directed to children under the age of 16 located in the EU. We will close any accounts dedicated to such children and will remove or delete any Personal Data we believe to have been submitted by any child under the age of 16 located in the EU.
14.2 Additional Notice for Users whose Data is Subject to California Law
14.2.1. Pursuant to the California Consumer Privacy Act (“CCPA”), we do not “sell” Personal Information, and have not sold any Personal Information of our users, as defined in the CCPA, in the past 12 months prior to the effective date of this Policy. California’s “Shine the Light” law also provides California residents the right to opt-out of having certain categories of Personal Information (as defined in the “Shine the Light” law) shared with third parties for their direct marketing purposes in certain circumstances. We do not share your Personal Information with third parties for their own direct marketing purposes.
14.2.2 The personal information about users that J REYNOLDS SYSTEMS collects, uses or discloses and has collected, used or disclosed in the twelve months prior to the effective date of this Policy may include personal information as defined by the CCPA, depending on how you visit the Site and interact with us.
14.2.3 Under the CCPA or other applicable law, you may have the right to: (i) request confirmation that we are processing your personal information; (ii) access or copy your personal information; (iii) receive an electronic copy of your personal information or request that we send that information to another company; (iv) restrict our use of your personal information, including the right to opt-in or opt-out of the sale of your personal information to third parties, in accordance with applicable law; (v) seek correction or amendment of personal information that is inaccurate, untrue, incomplete or misprocessed; and (vi) request deletion of personal information that J REYNOLDS SYSTEMS holds about you, subject to certain exceptions provided by law.
14.2.4 If you would like to exercise any of these rights, please contact us as set forth below by sending an email to our Personal Data Protection Officer. We will process such requests in accordance with applicable law. To protect your privacy, we may need to take steps to verify your identity before fulfilling your request. If you are a California resident, you have the right not to receive discriminatory treatment from us for exercising your rights under the CCPA.
15. Questions, concerns, or complaints? Contact Us
15.1 If you have any questions, concerns, or complaints about our privacy practices, please feel free to contact our Data Protection Officer at [email protected].
15.2 If you are an Indian user, you may contact our Grievance Officer at [email protected] for any questions regarding the collection and processing of your personal data. The Grievance Officer will respond to your concerns and queries as soon as possible and in compliance with applicable law.
Last modified: February 19, 2025