California Privacy Notice

SuperPlay California Privacy Notice

Last updated: April 11th 2023 

This California Privacy Notice (“Notice”) supplements our Privacy Policy. It includes information required under California law, including Title 1.81.5 of the California Civil Code (the “California Consumer Privacy Act” or “CCPA”), and describes the rights available to you if you are a resident of the State of California.

We may update this Notice at any time and such changes will apply from the time we publish or otherwise notify you of the updated Notice.

As used in this Notice, the term “Personal Information” does not, unless stated otherwise, include information made publicly available from federal, state or local government records, or consumer information that is de-identified or aggregate consumer information. Any undefined but capitalized term in this Notice has the meaning given to it in the Privacy Policy. 

Table of Contents

Personal Data we collect and how we use it

1. Categories of Information we Collect and With Whom it is Shared
2. Sources of Personal Information
3. Purpose of Collection of Information
4. Recipients of Personal Information
5. Sale of Personal Information

Your California Privacy Rights

1. Your Rights under the CCPA
2. Disclosure of Sharing for Others’ Direct Marketing Purposes (“Shine the Light”)
3. Limitations on Rights
4. California Do Not Track Notice

A. Our Data Practices:

1. Categories of Information we Collect and With Whom it is Shared: 

In the last 12 months we have collected and shared the following categories of personal information for our business purposes: 

In addition to the foregoing, we have collected and shared information in a manner which may be deemed a “sale” under the CCPA to data analytics providers and communication service providers, which may use information as targeted cookies and other information they collect and analyze on our behalf for their own purposes.

2. Sources of Personal Information

The categories of sources from which we collect the personal information described above are:

• Third-Party communication solution providers and resellers of our services. 
• From our users when they access and use our website and/or services, submit information or permit us to access their networks or devices;
• Data analytics providers we or you engage and provide us information, such as cookies.

3. Purpose of Collection of Information

Our business or commercial purposes for collecting personal information are:

• To provide our products and service to you or perform our agreement with you.
• For the reason you provided the information. For example, if you contact us with an inquiry and share your name and contact information, we will use that personal information to respond to your inquiry.
• To provide, support, personalize, develop and improve our website, products and services.
• To communicate with you about our products, services and related issues.
• To allow you to register for the services and to administer and process the registration, to trouble shoot, provide support and contact you in connection with your account.
• To prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the services and any security breaches or other potentially prohibited or illegal activities.
• To evaluate the quality of our products and services, and to enhance your experience on our site/application.
•  

4. Your GDPR Rights. 

Subject to certain exceptions and exclusions, the following rights apply to individuals who are located in an EU member states or otherwise protected by the EU General Data Protection Regulation (“GDPR”), as further described below. If you are such a person, then:

• Legal counsel and professional advisors, courts, tribunals, and other entities for the purpose of resolving a dispute, defending against a claim or enforcing our rights; 
• To an acquirer of our business or the relevant portion of our business, or in case of a merger, to the surviving company. 
• With law enforcement or government agencies when required to do so by applicable law or in order to prevent harm to you or any third party or the public;
• When person to whom the data relates has consented or requested that we do so.

5. Sale of Personal Information

We do not sell personal information for money. However, in some cases, sharing personal information may be deemed a “sale” under the California Consumer Privacy Act. The categories of personal information we share which may be deemed a “sale” under the CCPA are listed in the table above as categories A (Identifiers), D (Commercial information), F (Internet or other similar network activity), and G (Geolocation data) . When we share this personal information, we do so in the context of receiving services from third parties for the purposes listed in Section 3 above. For example: 

• We use data analytics providers to collect information about our users and visitors so we can monitor and improve our website, application and Services. They may use this information they receive for their own purposes. 
• When you share information with our business partners, they may use such information for the purpose of your communication with them, or for any other reason our business partners collect and keep information for. We recommend you review our business partners' privacy policies to learn of their usage and record of Privat Information.
• When you make a purchase on our application, our payment processors business partners may use the information you provide to identify fraud or for transactional purposes. 

You can direct us not to “sell” your personal information as such term is defined in the CCPA by clicking here. Please be aware that if you make such a request, we may not be able to provide certain or all of our products and services.

B. YOUR CALIFORNIA PRIVACY RIGHTS

1. Your Rights under the CCPA

Under the California Consumer Privacy Act, you have the right to:

• Request information about the categories and specific pieces of personal information that we have collected in the last 12 months
• Request that we delete personal information that we have collected from you. However, certain exceptions specified in law may apply and, in such cases, we are not required and may not comply with your request. This includes when we need the information in order to: 

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall in accordance with federal law, provide a good or service requested by you or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code;
• 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 business’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
• Enable solely internal uses that are reasonably aligned with expectations based on our relationship with you;
• Comply with a legal obligation; or
• Otherwise use the information, internally, in a lawful manner that is compatible with the context in which you provided the information.

• Request disclosure of the categories and specific pieces of personal information we collect about you, the categories of sources from which it is collected, the business or commercial purposes for which we collect personal information, and the categories of third parties with whom we share personal information, all in the last 12 months.
• Request disclosure of the categories of personal information we have sold or shared about you and the categories of third parties to whom we have we sold or with whom we have shared such personal information in the last 12 months.
• Direct a business that sells personal information about you to third parties not to sell your personal information. 
• Not be discriminated against for making these requests, such as by being denied goods or services, receiving worst rates or prices, receiving worse quality of goods or services, and we will not engage in any such discrimination.

You may make any of the requests by submitting a request in one of the following ways:

• E-mail us at privacy@superplay.co
• Contact us by mail at: Menachem Begin St 23, Bnei Brak, Israel;
• Submit your request through our California Privacy Rights Request Form available here.

You will need to provide sufficient information for us to locate Personal Data which relates to you and to verify your identity. This includes: your phone number, e-mail address and your postal code. We may request additional information to verify your identity.

If you do not provide all the requested information or information sufficient for us to verify your identity, we will not be able to fulfill your request. 

You may also make such requests through an agent you authorize for such purpose, but such agent must include a written document of your authorization. We may contact you directly to verify this authorization. 

2. Disclosure of Sharing for Others’ Direct Marketing Purposes (“Shine the Light”) 

In addition to the above, if we have an established relationship with you now or in the past 18 months, and you have shared with us certain personal information which at the time it was disclosed could be used to identify, describe or be associated with you, then once per year you may request a list of certain categories of personal information disclosed by us to third parties for their direct marketing during the preceding calendar year, the names of such third parties, and if the nature of the parties’ businesses is not reasonably clear from their names, examples of the products or services marketed by such third parties. 

The types of categories which must be disclosed according to such a request are listed in California Civil Code Section 1798.83 and include name, address, age, email address, race, religion, certain physical or health information, certain financial information, and other information listed in the statute. 

You may request this information by e-mailing us at privacy@superplay.co

This right only applies if our relationship is primarily for your personal, family or household purposes and related to the purchase of our products and services.

3. Limitations on Rights

With respect to all requests made as described above, we will fulfill and disclose information to the extent required by applicable law. In addition to the limitations on your right to request the deletion of data as described above, other exceptions and limitations in California and federal law may apply.

Furthermore, if you do not provide 

C. CALIFORNIA DO NOT TRACK NOTICE

We do not track individuals’ online activities over time and across third-party websites or online services (though we do receive information about the webpage you visited prior to accessing our websites, online services products and advertisement landing pages). We do not permit third-parties to track individuals’ online activities on our website and online services, unless it is part of a service provided to us. For example, we use data analytics providers to provide analytics services and collect data about the use and access of our website. We do not respond to Web browser “do not track” signals or similar mechanisms. You can find out more information about do not track signals at: http://www.allaboutdnt.com

D. CHILDREN UNDER AGE 16

We do not knowingly collect information from children under the age of 16.

E. HOW LONG WE RETAIN PERSONAL INFORMATION

In general, we retain the Personal Information we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable. We may store Personal Information for longer periods of time: (i) where we believes we are required to do so to comply with laws or in connection with legal proceedings; (ii) to resolve disputes; (iii) to enforce agreements between us and others; (iv) when the information is related to a potential or actual legal dispute.