Privacy
Privacy Policy
Last Updated: 09/2022
Your privacy is important to us. Our privacy policy is designed to help you understand the types of information that we collect, how we use and share the information, and how the information is protected. This policy covers our use of information that can or could be used to identify you, but it does not cover information which cannot be used to identify you. This policy applies to all Syclus services that directly reference or link to it, but does not apply to Syclus services that link to separate privacy policies.
Categories of information we collect
Information that you give to us
When you register for, and use our services, we collect the information that you give to us. This may include information like your name, email address, postal address, phone number, date of birth, grade in school (if applicable), city, state, and country of residence, language, information related to racial or ethnic origin, and gender. We ask that you not send us, and you not disclose, any sensitive information (e.g., social security numbers, financial information, health information, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, or sexual orientation) on or through the website or otherwise to us.
Information about your device
When you use our services, we may collect specific information about your device, and across your devices, such as the model, serial number, operating system, device settings, device performance, device and advertising identifiers, Internet service provider, IP address and other unique personal or online identifiers. If you or your device experiences an error, we collect information about the error, the time the error occurred, the application or features being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.
Information about your use of our services
We collect information about your use of and interaction with our services. This could include information about the account you use to access our services, your gameplay, your online status, your service use history, your connections and interactions with other users, the content you share, the date and time of your use or visit, information about the links you click, pages you view, and advertising you interact with within our services, inferences used to create a profile about your preferences and characteristics, standard server log information, and other information about how you use our services.
Your content
Our services may allow you to create, upload or share content such as text, images, audio, video, your nickname and user icon, or other content that you create or is licensed to you. When you use any of our services that include these or other similar capabilities we may collect your content in accordance with our terms of use and this policy.
Location information
With your consent, we may collect and process information about your precise location. When we have your location information, we use it to tailor our services for you and others, like allowing you to play location-based games or helping you establish friend relationships with other users.
Information from other sources
We may also receive information about you from other sources, including from other users of our services, and third-party services and organizations. For example, if you access any social media or similar services through our services to login or to share information about your experience on our services with others, we may collect information from these third-party services. We may also combine the information received from these other sources with information we’ve collected from you.
Aggregated and deidentified information
We may aggregate or de-identify the information described above. Because aggregated and de-identified information cannot be used to identify you, it is not subject to this policy.
How we use your information
We use your information to deliver, maintain and improve our services, including for the performance of troubleshooting, data analytics, testing, research, statistical analysis and surveys. We also use your information to provide you with services that you request, develop new services, suggest personally relevant features, offer you customized content, allow you to participate in interactive features, manage your account, provide you with tailored advertising, send you promotional materials from us or our affiliates and trusted business partners, keep our services, business and users safe and secure, comply with applicable laws and regulations, prevent fraud, and to protect or exercise our legal rights or defend against legal claims.
Whenever you contact us, we use the information that you provide to us to help resolve issues you might be having when you use our services. We also use information, such as your email address or phone number, to respond to you when you contact us, to let you know about changes to our policies and terms, to let you know about changes or improvements to our services and to inform you about other services that we offer.
We partner with third parties to engage in analytics, auditing, research, and reporting on our website. These third parties collect information regarding your usage of the website, and they may use server logs, cookies, web beacons, tags, pixels, and similar technologies. We may use cookies, or other similar technologies, on some of the features of our services. Cookies are small files that are typically downloaded to the browser application on your device. We also may permit our third-party service providers to set cookies and use web beacons, Software Development Kits, and similar technologies within our services to perform various analytics functions and to provide you with more relevant or interest-based advertisements. Please note that you can only disable cookies used for performance and interest-based advertising purposes; cookies that are strictly necessary for the proper functioning of our websites and services cannot be disabled.
Please note that these preferences may not apply across all of our digital properties. Please follow the instructions below to ensure that your cookie preferences are set accordingly for these other digital properties.
To opt-out of the Google Analytics cookies we use on our website, please follow the opt-out instructions found here.
Finally, if you would like to opt-out from the collection and use of cookies and other data in our mobile apps, please follow the opt-out instructions in each mobile app’s settings. We do not, and will not sell your information to third parties. However, we permit third-party service providers to collect personal information through some of our services and we share personal information with third party service providers for business or research purposes as described in this policy, including providing advertising on our services and elsewhere based on users’ online activities over time and across different sites, services, and devices.
The information that we collect through or in connection with our website is controlled by us, and we are headquartered in the United States. Your information may be transferred to and processed in the United States for the purposes described above. We also may subcontract the processing of your data to, or otherwise share your data with, third parties in the United States or countries other than your country of residence. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence. By agreeing to this policy when registering for an account on the website and/or using the website or by providing any information to us, you expressly consent to such transfer and processing.
How your information is shared
Authorized third-party service providers
We may share some or all of the categories of your personal information, as identified above, with third-party service providers that provide services to us for a variety of business purposes, such as payment processing, customer service, email deployment, research, advertising and marketing (including counting ad impressions, analyzing website clicks, verifying positioning and quality of ad impressions, ensuring compliance with industry standards, ad delivery, reporting, personalization, audience segmentation, and analytics), security enhancement, fraud prevention, performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, information hosting, auditing, and information processing.
Corporate affiliates
We sometimes share your information within our family and affiliates of Syclus companies, including popfy Media LLC.
Legal purposes
We may share your information to comply with legal process, respond to claims or inquiries, enforce our terms, or protect and defend the rights, property or personal safety of our operations, our users, or the public.
Business transfers
We may share your information as part of a substantial corporate transaction, such as a sale or transfer of company assets or equity, a merger, consolidation, or as otherwise legally permitted.
Other users and the public
Some of our services allow you to share your information and content with other users or engage in public activities. When you choose to use these services, the information or content that you share, your nickname, your user icon, online status, country of residence, reported age range, then educational grade level, and gameplay information may be visible to Syclus and its trusted business partners, such as popfy Media LLC, other Syclus users, and in some cases, the public. Please keep in mind, when you use these services, that the information and content that you choose to share may be read, collected, or used by others or the public. You are fully responsible for the information and content that you choose to share in these instances.
When you access third-party services
If you access third-party services -- such as third-party online gaming services and social media services -- through our services, these third-party services may be able to collect information directly from you or about you, including information about your activity on our services, and they may notify your connections on the third-party services about your use of our services, in accordance with their own privacy policies.
With your consent
We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
5. Information retention and information security
Your information will only be retained as long as reasonably necessary for the purposes set out in this privacy policy, and in accordance with applicable law.
We have implemented administrative, physical and technical security measures that are designed to protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. You should understand though that, despite our efforts, no security can be guaranteed as impenetrable. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.
6. Information about children
The Site is not intended for use by children under the age of 13 and under. We do not knowingly collect, use or share information from children the age of 13 and under without verifiable parental consent or as permitted by law. If you are 13 and under, please do not submit any personal information on this website.
7. Changes
Syclus may update this privacy policy from time to time. When we update it, we will revise the "Last Updated" date above. If we make material changes in the way we collect, use, retain or share your personal information, we will notify you by sending you an email at the last email address that you provided us, or by posting notice of the changes on the services covered by this privacy policy.
9. Contact information
If you have any questions, concerns or comments regarding this privacy policy, or any of our privacy practices, please contact us via email at info@syclus.org with “Attn: Privacy” in the subject line.
Privacy Notice for California Residents
Last Updated: 9/2022
This Privacy Notice for California Residents (this “Notice”) supplements the information contained in our Privacy Policy (the “Policy” and applies solely to all visitors, users, and others who reside in the State of California (“Users” or “You”) who visit this site (the “Site”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.
INFORMATION WE COLLECT
You have the right to request certain information about our collection and use of consumers’ personal information over the past 12 months. The categories of information that we have collected from consumers in the past twelve months, and may collect from you, are listed below along with the general sources of that information, the purposes for which we collect it, and types of third parties to whom we have disclosed it. We update this information at least once every 12 months.
Our Site collects personal information, which, for the purposes of this Notice, includes information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. Personal information does not include:
● Publicly available information from government records;
● Deidentified or aggregated consumer information; and
● Information excluded from the CCPA’s scope, like:
o health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
o personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, our Site has collected the following categories of personal information from its Users within the last twelve (12) months.
Identifiers, such as a name, postal or email address, IP address, account name, Social Security number, driver's license number, or passport number: We collect names, email addresses, and IP addresses.
Personal information categories are listed in Cal. Civ. Code § 1798.80(e). We collect personal information, such as name and education.
Protected classification characteristics under California or federal law, such as age, race, ancestry, citizenship, religion, marital status, medical condition, gender identity or expression, pregnancy or childbirth, sexual orientation, veteran or military status, or genetic information: We collect age, race, ancestry, and gender identity or expression.
Commercial information, such as records of personal property, products or services purchased or considered, or other purchasing or consuming histories or tendencies: We generally do not collect this type of information.
Biometric information, such as fingerprints, faceprints, voiceprints, or other physical patterns, and sleep, health, or exercise data: We generally do not collect this information.
Internet or other similar network activity, such as browsing history or a consumer’s interaction with a website, application, or advertisement: We may collect this information directly from you through your internet use.
Geolocation data, such as a person’s physical location or movements: As is true of most web sites, the Site server automatically recognizes the Internet URL from which you access the Site. An IP address may indicate the location of your computer on the Internet. We may collect this information from you through your internet use.
Sensory data, such as any audio, electronic, visual, thermal, or similar information: We generally do not collect this type of information.
Professional or employment-related information, such as a job history or performance evaluations: We generally do not collect this type of information.
Non-public education information, such as grades, transcripts, student financial information, or disciplinary records: We generally do not collect this type of information.
Inferences drawn from other personal information, such as a profile reflecting a person’s preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes: We generally do not collect such information.
We obtain the personal information listed above from the following categories of sources:
● DIRECTLY FROM YOU. For example, from forms you complete, including online, products and services you use on the site, signing up for the BodegaBudget™ gaming platform or newsletters, or otherwise submit to us.
● INDIRECTLY FROM YOU. For example, from observing your actions on our Site through cookies or other tracking mechanisms.
USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for business or research purposes set forth in the Policy. We use the personal information collected for a variety of business purposes, including research, tracking the Users’ use of and progress in the game, improving our gaming platform or Site, informing the Users of services and products, and conducting research and presenting opportunities to potential investors to invest in improving our gaming platform.
SHARING PERSONAL INFORMATION
Any personal information collected may have been disclosed to our IT service providers within the last twelve (12) months. Also, we may disclose your personal information to a third party for business purposes as set forth in the Policy. When we disclose personal information to a third party for a business purpose, we enter into a contract that describes the purpose for which the disclosure is being made and requires the recipient to both keep that personal information confidential and not use it for any purpose except for the purposes specified in the contract. The CCPA prohibits third parties who purchase the personal information that we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
YOUR RIGHTS AND CHOICES
The CCPA provides California residents with specific rights regarding their Personal information. This section describes your CCPA rights and explains how to exercise those rights.
ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, to the extent it is possible to associate your request with any personal information that we possess, we will disclose to you:
● The categories of personal information we collected about you;
● The categories of sources for the personal information we collected about you;
● Our business or commercial purpose for collecting or selling that personal information;
● The categories of third parties with whom we share that personal information. The specific pieces of personal information we collected about you (also called a data portability request);
● The specific pieces of Personal information we collected about you (also called a data portability request); and
● If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the Personal information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal information categories that each category of recipient obtained.
DELETION REQUEST RIGHTS
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, to the extent it is possible to associate your request with any personal information that we possess, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
● Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;
● Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
● Debug products to identify and repair errors that impair existing intended functionality;
● Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
● Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
● Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
● Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
● Comply with a legal obligation; or
● Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
● Emailing us at info@syclus.org with “Attn: Privacy” in the subject line; or
● Sending us a message on the Site.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
● Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal information or an authorized representative; and
● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity and/or authority to make the request.
RESPONSE TIMING AND FORMAT
We try to respond to verifiable consumer requests within forty-five (45) days of receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the twelve (12) month period preceding receipt of the verifiable consumer request’. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to a verifiable consumer request unless such a request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
OPT-OUT AND OPT-IN RIGHTS
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of Users we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Users who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may email us at info@syclus.org with “Attn: Privacy” in the subject line.
We will only use personal information provided in an opt-out request to review and comply with the request.
NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
● Deny you goods or services;
● Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
● Provide you a different level or quality of goods or services; or
● Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
3. OTHER CALIFORNIA PRIVACY RIGHTS “SHINE THE LIGHT” LAW
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a calendar year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please send an email to info@syclus.org with “Attn: Privacy” in the subject line.
If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided and include the email address associated with your account and a statement that you reside in California. We will make sure that the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.
To request any other changes or information about our collection, use or disclosure of your information, please email us at info@syclus.org with “Attn: Privacy” in the subject line.
DO NOT TRACK DISCLOSURE
Third parties may keep track of your browsing activities across third party websites. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know we respond to “Do Not Track” browser signals. “Do Not Track” is a preference you can set in your web browser to let the sites you visit know that you do not want them collecting information about you. Our Site does not currently respond to “Do Not Track” settings. For further details regarding “Do Not Track,” visit donottrack.us.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this Notice at our discretion and at any time. When we amend this Notice, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of any such amendments.