PRIVACY POLICY

Type of website: Game
Effective date: 19th day of November, 2021

wordigins.com (the “Site”) is owned and operated by Igins, LLC. David M. Rheingold is the data controller and Privacy Officer, and he can be contacted at:
data@wordigins.com or:
Wordigins Data
Igins LLC, 1905 15th St. #2020, Boulder, CO 80306

Purpose
The purpose of this privacy policy (this “Privacy Policy”) is to inform users of our Site of the following:

  1. The personal data we will collect;
  2. Use of collected data;
  3. Who has access to the data collected;
  4. The rights of Site users; and
  5. The Site’s cookie policy.

This Privacy Policy applies in addition to the Terms and Conditions of our Site. The European Union’s General Data Protection Regulation (“GDRP”) and California’s California Consumer Privacy Act (“CCPA”) provide protections for consumers in their respective jurisdictions. If you are not a resident or user of the site in the European Union or a California resident then you may not have rights under the GDRP or CCPA. Even though the GDRP or CCPA may not apply to you, we do respect and protect users’ privacy.

Even if you are not a California resident or a resident of the European Union we take steps to protect your private information. However, nothing herein should be taken as an agreement that the CCPA’s protections/remedies shall apply as to use by non-California residents or that the GDRP’s protections/remedies shall apply to non-European Union residents.

General Terms on Privacy
Except as otherwise mandated by law in the applicable jurisdiction, the following General Terms on Privacy shall apply.

Third Party Vendors
We may use third party vendors to perform certain functions, e.g. e-mail services, cloud/data storage providers. Such vendors shall only have access to personal information needed to perform their functions and shall not have authority to use any personal information for any other purpose.

Business Transfers
In the event we sell or transfer some or all of our business or assets, the consumer information and user submissions we obtain may be part of such sale or transfer.

Legal Compliance
We may disclose personal or consumer information on a good faith belief that the disclosure is appropriate to comply with the law or protect the user, us, the site or the public.

Children
We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our Privacy Officer.

How to Access, Modify, Delete, or Challenge the Data Collected
If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to who we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our Privacy Officer, David M. Rheingold at privacy@wordigins.com or:
Wordigins Privacy
Igins LLC, 1905 15th St. #2020, Boulder, CO 80306

Do Not Track Notice
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We do not track the users of our Site over time and across third party websites and therefore do not respond to browser-initiated DNT signals. We are not responsible for and cannot guarantee how any third parties who interact with our Site and your data will respond to DNT signals.

Cookie Policy
A cookie is a small file, stored on a user’s hard drive by a website. Its purpose is to collect data relating to the user’s browsing habits. You can choose to be notified each time a cookie is transmitted. You can also choose to disable cookies entirely in your internet browser, but this may decrease the quality of your user experience.

We use the following types of cookies on our Site:

  1. Functional cookies
    Functional cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits;
  2. Analytical cookies
    Analytical cookies allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc; and
  3. Third-Party Cookies
    Third-party cookies are created by a website other than ours. We may use third-party cookies to achieve the following purposes:

    1. Monitor user preferences to tailor game settings around their interests.

Modifications
This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates. If necessary, we may notify users by email of changes to this Privacy Policy.

Contact Information
If you have any questions, concerns or complaints, you can contact our Privacy Officer at privacy@wordigins.com or:
Wordigins Privacy
Igins LLC, 1905 15th St. #2020, Boulder, CO 80306

General Data Protection Regulation (European Union)
The above General Terms on Privacy shall apply as to users in the European Union except to the extent they conflict with the terms of the GDPR. For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation. For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

Your Rights as a User Under the GDPR
Under the GDPR, you have the following rights:

  1. Right to be informed;
  2. Right of access;
  3. Right to rectification;
  4. Right to erasure;
  5. Right to restrict processing;
  6. Right to data portability; and
  7. Right to object.

We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

Consent
By using our Site users agree that they consent to:

  1. The conditions set out in this Privacy Policy.

When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by contacting data@wordigins.com.

Legal Basis for Processing
We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal bases to collect and process the personal data of users in the EU:

  1. Users have provided their consent to the processing of their data for one or more specific purposes; and
  2. Processing of user personal data is necessary to a task carried out in the public interest or in the exercise of our official authority.

Information We Collect and How We Use It

Personal Data We Collect
We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected Automatically
When you visit and use our Site, we may automatically collect and store the following information:

  1. Your name or initials that you provide to us;
  2. Location;
  3. Hardware and software details;
  4. Clicked links; and
  5. Content viewed

How We Use Personal Data
Data collected on our Site will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Site. We will not use your data beyond what we disclose in this Privacy Policy.

The data we collect automatically is used for the following purposes:

  1. Statistics

Who We Share Personal Data With

  • Employees

We may disclose user data to any member of our organization who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

  • Third Parties

We may share user data with the following third parties:

  1. Google Analytics.

We may share the following user data with third parties:

  1. Links clicked while using site.

We may share user data with third parties for the following purposes:

  1. Statistics.

Third parties will not be able to access user data beyond what is reasonably necessary to achieve the given purpose.

Other Disclosures
We will not sell or share your data with other third parties, except in the following cases:

  1. If the law requires it;
  2. If it is required for any legal proceeding;
  3. To prove or protect our legal rights; and
  4. To buyers or potential buyers of this company in the event that we seek to sell the company.

If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policies and practices.

How Long We Store Personal Data
User data will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.

How We Protect Your Personal Data
In order to protect your security, we use the strongest available browser encryption and store all of our data on servers in secure facilities. All data is only accessible to our employees.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

International Data Transfers
We transfer user personal data to the following countries:

  1. United States.

When we transfer user personal data we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring personal data internationally.

If you are located in the United Kingdom or the European Union, we will only transfer your personal data if:

  1. The country your personal data is being transferred to has been deemed to have adequate data protection by the European Commission or, if you are in the United Kingdom, by the United Kingdom adequacy regulations; or
  2. We have implemented appropriate safeguards in respect of the transfer. For example, the recipient is a party to binding corporate rules, or we have entered into standard EU or United Kingdom data protection contractual clauses with the recipient.

Complaints
If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern in a satisfactory manner you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority. You can lodge a complaint with a supervisory authority by contacting the European Data Protection Supervisor; details can be found at https://edps.europa.eu/data-protection/our-role-supervisor/complaints_en.

CALIFORNIA CONSUMER PROTECTION ACT
The above General Terms on Privacy shall apply as to users who are California residents except to the extent they conflict with the California Consumer Privacy Act of 2018. The CCPA protects California residents. CCPA has similar requirements and protections to the GDRP. The CCPA applies to:

  • Companies that serve California residents that have at least $25 million in annual revenue;
  • Companies of any size that have personal data of at least 50,000 California residents or that collect more than half their revenue from the sale of personal data of California residents.

For your information, we do not have $25 million in annual revenue (hopefully one day we will!), and we do not sell our users’ personal data for monetary consideration.  As of September 2022 we do not have the personal data of 50,000 people to trigger the CCPA.  The CCPA does not currently apply to us; however, we will look to the CCPA for guidance for ways to protect your privacy.

Rights of California Residents Under the CCPA:

  1. Right to Know. You may make 2 requests in a 12-month period for the (1) categories of personal information we have collected, disclosed or sold about you in the last 12 months, (2) categories of sources that we collected personal information, (3) the business purposes that we used the information, and (4) categories of third parties with whom we share or have shared your personal information in the last 12 months;
  2. Right to Access. You may make 2 requests in a 12-month period for the specific pieces of personal information we have collected about you in the last 12 months.
  3. Right to Delete. You have the right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions.
  4. Right to Opt-Out. If we ever did start selling our users’ personal information, then you would have the right to opt-out of the sale of your personal information to third parties.
  5. You have the right to designate an authorized agent to submit the above requests on your behalf.
  6. You have the right to not be discriminated against in receiving different or less favorable pricing, services, or financial incentives for exercising an of the above rights.

You may exercise your right to make any of these requests by contacting the Privacy Officer (identified above).

CCPA Consumer Requests
If the CCPA applies and you submit a consumer request we will endeavor to respond to your request within 45 days. Our response shall only cover the prior 12 month period preceding our receipt of your request. We will notify you if we require more time to respond or if we are unable to comply with a request.

Information that We Collect and How We Use It
Please see the sections describing the Information We Collect and How We Use It that are provided, above, in relation to the GDRP.

Authorized Agent
You may authorize someone to act as your authorized agent regarding consumer requests sent on your behalf. We will require a validly executed and notarized power of attorney or other written authorization that we can verify. We may ask for proof of authorization.

Opt-Out of Sale of Your Information
Again, we do not sell your personal information for monetary consideration. However, as described above, we may share your information, such as with Google Analytics. This may result in a benefit to us about informing us what visitors to our websites view or interact with for marketing purposes. This may lead to targeted advertising. You have the right to tell us NOT to sell your personal information (again, we do not sell your information for money). You may opt-out of our disclosure of your personal information to third parties where the disclosure constitutes a “sale” as defined by the CCPA without fear of discrimination for doing so. You may do this by contacting our Privacy Officer, including but not limited to, contact through regular mail or email (see above). You may prevent your data from being used by Google Analytics, see: https://tools.google.com/dlpage/gaoptout.

Changes
We may change and update this privacy policy at any time. Please check back on a regular basis for any changes that may have been made.