Privacy Policy
Last updated: 27 September 2023. Effective September 2022
1. Introduction
This Privacy Policy (this “Policy”) describes the ways we (InQuisiTiVe Media Limited)
collect, store, use, and disclose the information, including personal information, and
data that our users (“users” or “you”) provide or we collect in connection with the
InQuisiTiVe Media Limited website available at https://www.inquisitive.tv/ and any
InQuisiTiVe Media Limited game provided on a mobile platform (each a “Service,”
collectively, the “Services”). Additionally, this Policy describes your rights and
choices concerning your information.
Please note that the scope of this Policy is limited to information and data collected
or received by InQuisiTiVe Media Limited through your use of the
Services. InQuisiTiVe Media Limited is not responsible for the actions of individuals
with no relationship to InQuisiTiVe Media Limited or third-party companies, the
content of their sites, the use of information or data you provide to them, or any
products or services they may offer. Any link to those sites does not constitute our
sponsorship of, or affiliation with, those individuals or companies.
If you do not want InQuisiTiVe Media Limited to collect, store, use, or share your
information in the ways described in this Policy, you should not use our Services.
2. Information and Data We Collect from You and How We Collect It
When you use our Services, you may give us your contact information directly on our
website or in application, generally your name and email address.
Registration Information:
We may also offer you the option to complete a user profile that is visible to other
InQuisiTiVe Media Limited users (“Account”). If you create an Account, you may
provide us your name, a username, e-mail address, a password and other
information that helps us confirm that it is you accessing your Account. We may do
this through in-game dialog boxes, which you may choose to skip. If you sign into the
Services with Facebook Connect we will collect information that is visible via your
Facebook account such as: (1) your first and last name, (2) Facebook ID, (3) Profile
Picture/URL, and (4) list of Facebook friends. Your Account may be used to publicly
identify you as part of social features of the Services, which may include user-to-user
interaction, chat or messaging functionality, public leaderboards, head-to-head
competition, and other similar features. The InQuisiTiVe Media Limited username will
be public and will be shown to other users, but will only permit access to information
that is considered public or that you have designated as public in your user profile
settings.
We may also offer you the ability to import your contacts or manually enter e-mail
addresses so that you can locate your contacts on InQuisiTiVe Media Limited and
invite your contacts to join you in the Services. We will store those contacts for
purposes of helping you and your contacts make connections through our Services.
Payment Information:
When you order any good or service through the Services, including any virtual
currency or virtual good, our payment processing service provider will collect your
name, phone number, e-mail address, mailing address, billing address, and
complete credit card information that enables them to receive your payment. Our
payment processing service provider may also retain this information to enable you
to purchase additional items through our Services without having to re-enter it each
time. Please note that purchases from third parties may also be subject to additional
policies
Information Collected by Customer Support:
When you ask for assistance from our Customer Support team, we will collect and
store the contact information you provide (generally your name and e-mail address),
information about your gameplay or activity on the Services, and your user-name or
ID number. We will also store the correspondence and any information contained
within.
Technical and Usage Information:
When you access our Services, we may collect (i) certain technical information about
your mobile device or computer system, including IP Address, mobile device ID
(IDFA, Google Advertising ID or other identifiers), and the version of your operating
system; and (ii) usage statistics about your interactions with the Services. In certain
Services we will create and assign to your device an identifier that is similar to an
account number. We may collect the name you have associated with your device,
device type, telephone number, country, and any other information you choose to
provide, such as username, character name, or e-mail address. We may also access
your contacts to enable you to invite friends to join you in the Services. This
information is typically collected through the use of third-party mobile device software
development kits. We may occasionally send you push notifications through our
Services to send you game updates, high scores and other service-related
notifications that may be of importance to you. You may at any time opt-out from
receiving these types of communications by turning them off at the device level
through your settings.
3. How We Use Your Information
InQuisiTiVe Media Limited's primary goals in using your information are to create
your account, provide Services to you, troubleshoot, improve and optimize our
Services, contact you, conduct research and create reports for internal use. We use
information collected through our Service for purposes described in this Policy or
disclosed to you in connection with our Service. For example, we may use your
information to:
Create accounts and allow users to use our Services;
Identify and suggest connections with other InQuisiTiVe Media Limited users;
Operate and improve our Services;
Understand you and your preferences to enhance your experience and
enjoyment using our Services;
Respond to your comments and questions and provide customer service;
Provide and deliver products and services you request;
Deliver advertising and marketing and promotional information to you;
Send you related information, including confirmations, invoices, technical
notices, updates, security alerts, and support and administrative messages;
Communicate with you about promotions, contests, rewards, upcoming
events, and other news about products and services offered by InQuisiTiVe
Media Limited and our selected partners;
Conduct and administer contests promoted by InQuisiTiVe Media Limited;
Enable you to communicate with other users; and
Link or combine it with other information we get from third parties, to help
understand your preferences and provide you with better services.
Use of Your Information by Others:
Third Party Services. We may provide your information to third party companies to
perform certain services, including but not limited to hosting services, payment
processing, analytics, customer service and to assist us in our marketing efforts.
Where we share your information with third-party service providers and business
partners, we ensure that we have appropriate agreements in place to protect your
information as required by applicable data protection laws.
Advertising. To the extent we display advertising in our Services, we may allow
advertising networks of our affiliates and partner networks to collect information
about your mobile device to enable them to serve targeted ads to you. Such mobile
device data includes the following:
Device make, model and operating system;
Device properties related to screen size & orientation, audio volume and
battery;
Carrier;
Operating system;
Name and properties of mobile application through which a consumer
interacts with the Services;
Country, time zone and locale settings (country and preferred language);
Network connection type and speed;
IP Address;
Internet browser user-agent used to access the Services; and
Advertising ID (IDFA on iOS devices and GAID on Android devices).
You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for
individuals in the EU) to learn more about interest-based advertising and how to opt-
out of this form of advertising on your web browser by companies participating in the
Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to opt-out of
interest based advertising in mobile apps on your device by companies that
participate in the DAA’s AppChoices app, you may download that app onto your
device and exercise your choice. AppChoices is available at the links below:
https://apps.apple.com/us/app/appchoices/id894822870
https://play.google.com/store/apps/details?id=com.DAA.appchoices&hl=en_GB&gl=
US
You may also limit data collection by third parties by using your mobile device
settings. Please note that electing to opt-out will not stop advertising from appearing
in your browser or applications. It may make the ads you see less relevant to your
interests. Additionally, please not that if you use a different browser or erase cookies
from your browser, or use a different mobile device, you may need to renew your
opt-out choices.
4. How We May Disclose Your Information to Third Parties
InQuisiTiVe Media Limited does not share your personal information except as
approved by you or as described in this Policy.
We may share information we collect or derive with third parties for the following
purposes:
With service providers that perform services on our behalf, including the ones
referenced above under “Third Party Services”;
With our affiliates;
For analytics and research purposes;
When we have a good faith belief that we have to disclose the information in
response to lawful requests by public authorities, including law enforcement or
legal process purposes;
To satisfy any applicable laws or regulations;
When we believe in our sole discretion that our Services are being used in
committing a crime, including to report such criminal activity or to share
information with other companies and organizations for the purposes of fraud
protection, credit risk reduction, and other security precautions;
To protect our or a third party’s legal rights, investigate fraud, or to defend
against a legal claim;
As part of a business transfer such as a merger, acquisition, or at bankruptcy;
We may share aggregate or anonymous information about you with
advertisers, publishers, business partners, sponsors, and other third parties;
and
We may use analytics services provided by third parties, including Google
Analytics. These service providers may use cookies to collect information
about your online activities across this and other sites over time for non-
advertising purposes. To learn more about how Google analytics collects and
processes data and the choices Google may offer to control these activities,
you may visit http://www.google.com/intl/en/policies/privacy/partners/.
5. Specific Provisions for EU Individuals
Accessing and Correcting Your Personal Information. At any time, you may contact
InQuisiTiVe Media Limited at the address provided in the “Support InQuisiTiVe
Media Limited” section herein and request to access the personal data that
InQuisiTiVe Media Limited holds about you. InQuisiTiVe Media Limited may need to
ask you to provide certain information to make sure you are who you claim to be. If
you find the information on your account is not accurate, complete or updated, then
please provide InQuisiTiVe Media Limited with the necessary information to correct
it.
Withdrawing Your Consent. Contact us if you would like to withdraw your consent to
the processing of your personal data. Exercising this right will not affect the
lawfulness of processing based on consent before withdrawal.
Erasing or Restricting Access to Your Information. You may request to delete or
restrict access to your personal data. We may postpone or deny your request if your
personal data is in current use for providing Services or for other legitimate
purposes, in which case we will let you know if we are unable to do so and why.
Transferring your Personal Data (Otherwise known as Your Right to Data
Portability). You have the right to receive your personal data that you have provided
us in a structured, commonly used and machine-readable format and the right to
transmit that data to another party of your choice, where technically feasible.
However, this right shall not apply where it would adversely affect the rights and
freedoms of others.
Right to Make Complaint: if you consider that our processing of your personal data
infringes data protection laws, you have a legal right to lodge a complaint with a
supervisory authority responsible for data protection. You may do so in the EU
member state of your habitual residence, your place of work or the place of the
alleged infringement.
If you have any concerns about the way we process your personal data, you are
welcome to contact our Data Protection Officer at support@connectthewords.net We
will look into your request and make good faith efforts to resolve any concern you
may have.
6. Security Safeguards.
InQuisiTiVe Media Limited takes reasonable measures to protect your information
from unauthorized access or against loss, misuse or alteration by third
parties. Although we make good faith efforts to store the information collected on the
Services in a secure operating environment that is not available to the public, we
cannot guarantee the absolute security of that information during its transmission or
its storage on our systems. Further, while we attempt to ensure the integrity and
security of our network and systems, we cannot guarantee that our security
measures will prevent third-party “hackers” from illegally obtaining access to this
information. We do not warrant or represent that your information will be protected
against, loss, misuse, or alteration by third parties. No method of transmission over
the Internet, or method of electronic storage, is 100% secure, however. Therefore,
we cannot guarantee its absolute security.
7. Data Retention.
InQuisiTiVe Media Limited retains your personal data for as long as needed to
provide you Services, unless we are required by law to delete or if InQuisiTiVe Media
Limited accepts your request to delete the information. We will also retain and use
your personal data as necessary to comply with our legal obligations, resolve
disputes, and enforce our agreements.
8. Our Policy Regarding Children.
We do not knowingly collect or solicit personal data from anyone under the age of 16
or knowingly allow such persons to use our Services. If you are under 16, please do
not send any information about yourself to us, including your name, address,
telephone number, or email address. No one under the age of 16 may provide any
personal data. In the event that we learn that we have collected personal data from
a child under age 16, we will delete that information as quickly as possible. If you
believe that we might have any information from or about a child under the age of 16,
please contact us.
9. Transfer of Personal Data Outside Your Country.
We may transfer information that we collect about you to affiliated entities, or to other
third parties across borders and from your country or jurisdiction to other countries or
jurisdictions around the world. Please note that these countries and jurisdictions may
not have the same data protection laws as your own jurisdiction, and we take steps
to ensure adequate safeguards are in place to enable transfer of information to the
U.S. and the use and disclosure of information about you, including personal data,
as described in this Policy.
10. Lawful Basis for Processing.
On certain occasions, we process your personal data when it is necessary for the
performance of a contract to which you are a party, such as to provide the Services
to you. We may also process your personal data to respond to your inquiries
concerning our products and services.
On other occasions, we process your personal data where required by law. We may
also process your personal data if necessary to protect your interests or the interests
of a third party.
Additionally, we process your personal data when necessary to do so for fraud
prevention, improving our network and services, and marketing our services to
advertisers and publishers; where these interests are not overridden by your data
protection rights.
If the processing of personal data is necessary and there is no other lawful basis for
such processing, we will generally ensure that consent has been obtained from
you. You have the right to withdraw your consent to processing of personal data at
any time.
For questions about data processing, please contact our Data Protection Officer
at support@connectthewords.net
11. Privacy Shield Framework
InQuisiTiVe Media Limited transfers certain personal data to the U.S. and
participates in and has certified its compliance with the EU-U.S. Privacy Shield
Framework and the Swiss-U.S. Privacy Shield Framework. InQuisiTiVe Media
Limited is committed to subjecting all personal data received from European Union
(EU) member countries and Switzerland, respectively, in reliance on each Privacy
Shield Framework, to the Framework’s applicable Principles. To learn more about
the Privacy Shield Framework visit the U.S. Department of Commerce’s Privacy
Shield List, available at: https://www.privacyshield.gov/list.
InQuisiTiVe Media Limited is responsible for the processing of personal data it
receives under the Privacy Shield Framework and subsequently transfers to a third
party acting as an agent on its behalf. InQuisiTiVe Media Limited complies with the
Privacy Shield Principles for all onward transfers of personal data from the EU and
Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield
Framework, InQuisiTiVe Media Limited is subject to the regulatory enforcement
powers of the U.S. Federal Trade Commission. In certain situations, InQuisiTiVe
Media Limited may be required to disclose personal data in response to lawful
requests by public authorities, including to meet national security or law enforcement
requirements.
In compliance with the Privacy Shield Principles, InQuisiTiVe Media Limited commits
to resolve complaints about our collection or use of your personal information. EU
and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy
should first contact us at: support@connectthewords.net. We will attempt to answer
your questions and satisfy your concerns in a timely and complete manner. If you do
not receive timely acknowledgment of your complaint from us, or if we have not
addressed your complaint to your satisfaction, please contact or
visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a
complaint. The services of JAMS are provided at no cost to you.
If your complaint is still not resolved through these channels, under certain
conditions, more fully described on the Privacy Shield website
here: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may
invoke binding arbitration when other dispute resolution procedures have been
exhausted.
12. Specific Provisions for California Consumers
These additional provisions for California consumers apply only to individuals who
reside in California. The California Consumer Privacy Act of 2018 (“CCPA”) provides
additional rights to know, delete and opt out, and requires “businesses” collecting or
disclosing personal information to provide notice and a means to exercise those
rights.
Categories of personal information collected in the preceding 12 months
Business purpose for collection
Third parties with whom we may share your information
Right to Know and Right to Delete
For any of the personal information described above, you can request to know what
personal information we collected, disclosed, used and sold, and request that we
delete your personal information at any time.
To exercise your right to know and right to deletion, please submit a request by
emailing support@connectthewords.net with the subject line “California Rights
Request.” We will need to verify your identity before processing your request. In
order to verify your identity, we will generally require the matching of sufficient
information you provide us to the information we maintain about you in our systems.
In certain circumstances, we may decline a request to exercise the right to know and
right to deletion, particularly where we are unable to verify your identity.
Upon verification of your request, we will delete (and direct our service providers to
delete) your personal information from our records, unless retaining the information
is necessary for us or our service providers to complete the transaction with you,
detect security incidents or fraud, fixing errors, exercise free speech or another right
provided by law, comply with legal obligations, or other internal and lawful uses.
Right to Opt Out of Sale
CCPA gives you a right to direct a business that sells your personal information to
stop selling your personal information and to refrain from doing so in the future. We
do not sell any of your personal information and will require our service providers not
to sell your personal information.
You also have the right not to be discriminated against for exercising any of the
rights listed above.
If you are a California resident seeking to exercise your rights under the CCPA or
have any questions or concerns, please email us at support@connectthewords.net. In
certain circumstances, you are permitted to use an authorized agent to submit
requests on your behalf where (i) you provide sufficient evidence to show that the
requestor is an authorized agent with written permission to act on your behalf and (ii)
you successfully verify your own identity with us.
We aim to respond to a consumer request for access or deletion within 45 days of
receiving that request. If we require more time, we will inform you of the reason and
extension period in writing.
13. Changes to This Policy.
We may update this Policy to reflect changes to our data and information privacy
practices. If we make any material changes we will notify you by means of a notice
on the Services prior to the change becoming effective. We encourage you to
periodically review this Policy for the latest information on our privacy
practices. Please note that if InQuisiTiVe Media Limited needs to adapt the policy to
legal requirements, the new policy will become effective immediately or as required
15. Contact Us
You may contact InQuisiTiVe Media Limited’s Data Protection Officer
at support@connectthewords.net or the address below for further information.
Attention: Legal
InQuisiTiVe Media Limited
28 Bramshill Gardens
London
NW5 1JH