Privacy Policy

ISSUED BY: Win Button LLC

Last Updated: 06.01.2020.


INTRODUCTION AND GENERAL TERMS


These terms apply to the use of games and other products and services developed and/or published by Win Button LLC. (“Win Button” / “we” / “us”). This privacy policy applies and has effect in respect of all games, related Products and Services (including online network play connectivity and interactivity) and other software and products made available by us, as well as any other online features relating to our games, our websites (including, without limitation, www.insigniagame.com) All of our games, websites, communities are referred to as “Products and Services

We are a Colorado registered company with ID number 20171888832.

If you have any questions or comments about this Privacy Policy, please contact us at contact@winbuttongames.com.

This Privacy Policy explains the basis on which personal data we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Products and Services is processed, we are the “controller” for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”). We will comply with all applicable data protection laws, including the GDPR, California Consumer Privacy Act 2018 (“CCPA“).

Please read this Privacy Policy carefully as it contains important information about the following:

Win Button will occasionally update this Privacy Policy. When we do, we will also revise the "last updated" date at the top of the Privacy Policy.  You should check here from time to time to ensure you are aware of any changes.


INFORMATION WE MAY COLLECT


Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Usage Data (“Data”).

We define Usage Data as how and when you use our Products and Services.

Users are responsible for any third-party Personal Data obtained, published or shared through our Products and Services and confirm that they have the third party's consent to provide the Data to Win Button.


WHY WE COLLECT INFORMATION ABOUT YOU


Improve quality and fix problems

We may process Data so that we can analyse and improve our Products and Services. This processing will contribute to bettering user experience and the overall quality of Products and Services and fixing bugs.

Balance and adjust difficulty

We may process Data to analyse Users’ in-game choices and results to improve mechanics and balance difficulty.

Support users

We may process Data so that we are able to properly respond to your enquiries and support requests, in accordance with the terms of use agreed between us.

Prevent illegal activity

We may process Data to ensure that your use of our Products and Services is lawful, to prevent disruption to our Products and Services, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.


DATA SHARING


Group members and personnel

We keep your information confidential, but may disclose it to any member of our group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Law Enforcement

 We may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Platforms

 We may also disclose your personal data to third parties (e.g. mobile network operators, gaming platform operators, game console manufacturers or networks) in order to enforce or apply the terms of agreements, to investigate potential breaches or to protect the rights, property or safety of Win Button, our customers or others.

Analytics

On occasion we may also disclose your personal information for the purpose of improving and optimising our Products and Services to deliver a better experience for our users.


YOUR RIGHTS IN RELATION TO PERSONAL DATA


Win Button would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access - You have the right to request Win Button for copies of your personal data. We may charge you a small fee for this service.

The right to rectification - You have the right to request that Win Button correct any information you believe is inaccurate. You also have the right to request Win Button to complete information you believe is incomplete.

The right to erasure - You have the right to request that Win Button erase your personal data, under certain conditions.

The right to restrict processing - You have the right to request that Win Button restrict the processing of your personal data, under certain conditions.

The right to object to processing - You have the right to object to Win Button's processing of your personal data, under certain conditions.

The right to data portability - You have the right to request that Win Button transfer the data that we have received or collected to another organization, or directly to you, under certain conditions.

If you make a request, we have 30 days to respond to you. If you would like to exercise any of these rights, please contact us at contact@winbuttongames.com.


DATA RETENTION


We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.


CHILDREN


We do not use our Products and Services to knowingly solicit information from, or market to, children under the age of 13. In the event that we learn that we have collected personal data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age, please contact us at contact@winbuttongames.com.  


SECURITY


Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through our Products and Services; any transmission is at your own risk.


CALIFORNIA RESIDENTS & CCPA


If you are a California resident, as defined in Section 17014 of Title 18 of the California Code of Regulations, you have certain rights in respect of the personal information we hold about you.

If you have questions or concerns about our privacy policies and practices, please contact us at the details set out at the end of this Privacy Policy.

We do not knowingly sell the personal information of minors under 16 years of age, except with affirmative authorisation in the case of those aged between 13 and 16.

We do not sell personal information.

You can designate an authorised agent to make a request under the CCPA on your behalf. The authorized agent must submit proof that they have been authorized by you to act on your behalf and proof of their own identity.

You have the right to:

To make a verifiable consumer request, please contact us by email at contact@winbuttongames.com. We will attempt to verify your request within 30 days.