SUPPLEMENTAL PRIVACY DISCLOSURE FOR CALIFORNIA RESIDENTS
Last updated: July 25, 2023
The California Consumer Privacy Act of 2018, as amended (“CCPA”) establishes specific rights for California residents to control their personal information and requires businesses to provide specific information to California residents regarding how their personal information is collected, used, and disclosed.
Rovio Entertainment Corporation (referred to as “we” in this disclosure) provides this disclosure to California residents who play our Games (referred to as “you” in this disclosure) to provide you the information required by the CCPA and to inform you of your rights under the CCPA. This disclosure supplements our Privacy Notice, which provides more comprehensive information on how and why we may process data relating to you. We recommend that you read our Privacy Notice in conjunction with this disclosure.
In this disclosure, the term “Games” has the same definition as in our Privacy Notice.
1 Your rights
Under the CCPA, California residents have certain rights to their personal information. If you are a California resident, you may exercise these rights as explained below. To help us provide you with better service, please submit requests using the automatic tools we provide in our Games, where available. Where those tools are not available, you may contact our player support instead. For more information, please refer to section 10 of our Privacy Notice.
When you submit a request to exercise your rights, we are required to verify that you are the consumer to whose personal information the request relates or a person authorized to act on that consumer’s behalf. If you submit your request using the automated tools provided in our Games, we will usually not need additional information to verify your request. For requests submitted by other means (for example, by email), we may ask you to provide additional information about the account to which the request relates to enable us to confirm that you are the account holder or acting on their behalf.
Right to Know. You have the right to know what personal information about you we collect, from which sources, for which purposes, and to whom we disclose it. You also have the right to request the specific pieces of personal information we have collected about you. Moreover, you have the right to know which categories of personal information we have sold, shared, or disclosed for a business purpose.
For information on the personal information we collect, the sources we collect it from, the purposes we collect and use it for, the parties we share it with, and the business purposes we may disclose it for, please refer to section 2 of this disclosure. In addition, section 3 of this disclosure describes the extent to which we may sell or share your personal information in the meaning of the CCPA.
Right to Correct. In certain circumstances, you have the right to request that we correct any inaccurate personal information that we may hold about you.
Right to Delete. You have the right to request that we delete any personal information about you that we have collected from you, subject to certain exceptions provided in the CCPA (including, for example, where we need to keep your personal information to complete a transaction, to provide a service requested by you, to help ensure security and integrity, to enable certain solely internal uses, or to comply with a legal obligation). Following your deletion request, we may either erase or de-identify your personal information.
Right to Opt Out. You have the right to direct us to not sell or share your personal information. In practice, doing so means that we will no longer share your identifiers and other information with our advertising partners to make the ads you see more relevant to you. To exercise your right to opt out, please use the automated tool we provide for this purpose in our Games. The tool can be found by navigating to the settings menu of a Game and tapping “Terms and Privacy” or a similarly named option. This opens a page with an option called “Do not sell or share my personal information,” which can be used to opt out. If you have trouble using the tool, please contact our player support.
Right to Limit the Use of Sensitive Personal Information. You have the right to limit the use of your sensitive personal information, where that information is used to infer characteristics about you. We do not currently use sensitive personal information about you for that purpose. For that reason, we also do not offer an option to limit such use.
Right to No Retaliation. We will not discriminate against you if you choose to exercise any of your rights under the CCPA.
2. How we collect, use, and disclose your personal information
What follows is a summary of how we may collect, use, and disclose your personal information. The summary is provided in the format we believe to be required by the CCPA. Please review our Privacy Notice for additional information.
We regularly collect the following categories of personal information specified in the CCPA:
|Category of personal information||Examples||Sources|
|Identifiers||In-game alias, IP address, hardware or operating system based identifiers, email address, or identifiers we assign to your account.||Directly from you (including automatically when you interact with our Games), our advertising partners (to the extent you interact with our ads outside of our Games), third-party account providers (if you link a third-party account to our Games), or third-party payment service providers (if you make purchases in our Games).|
|Protected classifications||Your age or information about when you were born.||Directly from you when you provide the information to us when prompted in our Games.|
|Commercial information||Information regarding your virtual items or currency in our Games, including records of purchases you may have made.||Directly from you (including automatically when you interact with our Games) and third-party payment service providers (if you make purchases in our Games).|
|Internet or other electronic network activity information||Information on your activity in our Games (for example, your game progress or your interactions with ads in our Games).||Directly from you (including automatically when you interact with our Games), our advertising partners (to the extent you interact with our ads outside of our Games).|
|Geolocation data||Your coarse location (for example, country, state, or city), determined based on your IP address.||Directly from you (including automatically when you interact with our Games).|
|Inferences drawn from this information to create a profile about you||Your geolocation or preferences used to personalize our Games for you.||We make these inferences based on the other categories of information.|
|Content of communications||The messages you may choose to send using chat features provided in our Games.||Directly from you when you use the chat features provided in our Games.|
We may use this information for the following business purposes specified in the CCPA:
- auditing related to counting ad impressions, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards,
- helping to ensure security and integrity,
- debugging to identify and repair errors in our services,
- short-term, transient uses, including non-personalized or contextual advertising,
- performing our services,
- providing advertising and marketing services (other than cross-context behavioral advertising),
- internal research for technological development and demonstration, or
- activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
To achieve the business purposes listed above, we may disclose personal information to recipients such as our service providers and other recipients described in section 6 of our Privacy Notice. This means that we may disclose the categories of personal information listed above for a business purpose.
We retain personal information for a length of time determined based on the purpose for which the information is collected and used, our internal operational needs, any specific requirements deriving from applicable laws or regulations, and other incidental factors as may be relevant to the type of information in question.
3 How we may sell or share your personal information
We do not sell your personal information, as we understand the definition of “sale” under the CCPA. However, when we request our advertising partners to show you an ad in our Games, we may share a limited amount of your personal information to those advertising partners to enable them to deliver an ad that is relevant to you.
We may share the following categories of your personal information with advertising partners:
- identifiers (generally including an advertising ID and your IP address) and
- internet or other electronic network activity information (including technical information required to select and deliver the appropriate ad type and format).
You may direct us not to share your personal information to our advertising partners. To learn how to exercise your right to opt out, please see section 1 of this disclosure.
If we have actual knowledge that you are under 16 years old, we will not sell or share your personal information without affirmative authorization.