Privacy Policy

33Numbers Privacy Policy and Notice

Effective 7/22/2020

Who We Are

Welcome to 33Numbers, a service that lets users of smartphones and other mobile devices play fun games and have the chance to win prizes (the “Service“). The Service, along with our website at www.33Numbers.com (the “Site” and, together, with the Service, our “Services“) is owned and operated by 33Numbers LLC. (“33Numbers”, “we”, or “us“). This Privacy Policy (this “Policy“) describes what information we gather from you on the Services, how we use and disclose that information, and what we do to protect it. By using the Services, you expressly consent to the information handling practices described in this Policy.

This Policy is incorporated into and is subject to the 33Numbers Terms of Service, available at www.33numbers.com. The practices described in this Policy apply only to our use of information supplied by you to us through the Services. Information collected from you by others, such as third-party web sites that you may access through links on the Service, may be governed by those third parties’ privacy policies.

Information We Collect

“Personal information,” as used in this Policy, is information that specifically identifies an individual, such as an individual’s name, address, telephone number, or e-mail address. Personal information also includes information about an individual’s activities, such as information about his or her activity on our Services, and demographic information, such as date of birth, gender, geographic area, and preferences, when any of this information is linked directly to personal information that identifies that individual.

This section describes the personal information and other information we collect on the Service.

User-Provided Information: You do not have to register with us to play games on the Service, but you do need to register in order to be eligible to win and to redeem prizes that you earn on the Service. You can register in two different ways. First, you can register with us at any time by providing us with your name, an email address, password and other information. Second, if you have not yet registered when you seek to play cash and real prize games or redeem tokens on the Service, we will ask you to create an account by providing us with your name, an email address, password, and other information. Also, if you redeem a prize on the Service, we ask for your postal address and telephone number.
Also, we may offer the ability to connect to Third-Party Connected Services (as defined below in the “Third-Party Connected Services” section of this Policy). We collect personal information from those Third-Party Connected Services as described below in that section.
We may also provide you with other opportunities to voluntarily provide personal information to us on the Services, such as through feedback or customer support forms, surveys, user profile functionality, or other means.
“Automatically Collected” Information: When you visit the Site, we automatically collect information such as your IP address, cookie information, browser type, system type, the content and pages that you access on the Site, the dates and times you access the Site, and the “referring URL” (i.e., the page from which you navigated to the Site). Similarly, when you launch or use the Service, we automatically collect a variety of information about your mobile device and your use of the Service, such as your IP address, Device ID (as defined below), device type and operating system, browser type, as well as the dates and times you access or use the Service, and actions you engage in using the Service (such as, for example, the types of games you play). This information is gathered for all users.
We may collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as “Web beacons”). If we link or associate any information gathered through passive means with personal information, we treat the combined information as personal information under this Policy. Otherwise, we use and disclose information collected by passive means in aggregate form or otherwise in a non-personally identifiable form. We may also collect device information that uniquely identifies individual mobile devices (“Device ID“) on the Service. We use the Device ID to authenticate a user session and for other purposes described in the “Use of Information” section below in this Policy. This Device ID functions similarly to a persistent cookie to make it possible to authenticate a user without the need for a password. You can disassociate a Device ID from a user account at any time by emailing us at [email protected]. If you dissociate a Device ID from a user account, you may no longer be able to use certain features of the Service.
Certain features of the app will display your username, profile picture and scores i.e. leaderboards and player profiles. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
Location Information: The Service may offer features designed to target advertisements or other content to you based in whole or in part based on your location. The Service may also make suggestions to you based in whole or in part based on your location. You will be given the opportunity to opt out of location-based functionality on the Service when signing up. If you do not opt out of location-based functionality on the Service, we may collect your location based on information provided by you or your mobile device, including, if available, GPS, IP address or cell tower information. If you choose to disable location-based functionality on the Service, you may not be able to utilize certain features of the Service.
Invitation Service: We may offer functionality on the Services that allows you to tell a friend about the Services. If you choose to use our invitation service to tell a friend about the Services, we will ask you for information needed to send the invitation, such as your friend’s email address or phone number. We may also offer you the opportunity to invite your friend via third-party services such as Facebook or Twitter. We will automatically send your friend a one-time email, SMS message, or other message inviting him or her to visit or try the Services. By providing email addresses or contact information, you represent and warrant that you have the right to do so, and you acknowledge and agree and that such information may also be provided to the third-party service that you have designated to contact your friend, as applicable. We store this information to send this one-time invitation, to register a friend connection if your invitation is accepted, and to track the success of our referral program. Your friend may contact us at [email protected] to request that we remove this information from our database.

The Ways We Use Information:

Generally, we use the information that you provide or that we collect and/or aggregate, including personal information, “automatically collected” information, and other information, to: (i) administer, operate, and improve the Services and our other services and systems; (ii) personalize the content and information on the Services, (iii) monitor and analyze the effectiveness of the Service and marketing activities on the Services (including by third parties), (iv) understand and analyze the usage trends, interests, and preferences of our users, (v) track your entries, submissions, and status in any promotions or other activities that may be offered on the Services from time to time, and (vi) create new features, functionality, products, and services.
We may also use personal information for any other purposes that we may disclose to you in connection with a request for your personal information, and for any other use for which you may provide your consent.
We will use your email address and other contact information to contact you for administrative purposes and for customer service purposes. We may also use your contact information to send you advertisements and promotions regarding our products and services and those of third parties.
We may use location information that you provide or that we collect to provide content (including, without limitation, advertisements) and services to you based in whole or in part on your location.
We may use information that you provide to us or that we collect through the Services, including personal information, to tailor and provide advertising and other content to you.

When We Disclose Information:

Other than as described in this Policy, we will not disclose your personal information to third parties without your consent. We do, however, disclose your personal information and other information about you in the following circumstances: If you win a prize on the Service, we may publish your first name, last initial, location, picture, and a description of the prize (e.g., the amount of any monetary prize) that you have won on our Facebook page, our website, and in advertisements and promotional materials that we may disseminate through various media. Additionally, if you win a prize on the Service, we may disclose personal information about you to third parties in connection with tax reporting obligations.
We may work with third-party service providers to provide maintenance services, data analysis, service hosting, prize fulfillment, and other services for us. These third parties may have access to or process your personal information as part of providing their contracted services to us. We require these third-party service providers to agree to only use the personal information we provide them for the purpose for which it was provided.
We may disclose your information, including personal information, if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, including but not limited to in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity or other legal process.
We also reserve the right to disclose your information, including personal information, as we believe, in good faith, is appropriate or necessary to take precautions against liability; to protect 33Numbers and others from fraudulent, abusive, or unlawful uses or activity; to investigate and defend ourselves against any claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Services (including all hardware, software, and systems underlying the Services and otherwise used to provide the Services) and our other property; or to protect the rights, property, or safety of us, our users, or other persons or entities.
We make certain information that is not personally identifiable (e.g., information that was automatically collected, or that was otherwise aggregated or de-identified) available to third parties (i) to comply with various reporting obligations; (ii) for business, marketing, or advertising purposes; or (iii) to assist such parties in understanding our users” interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services. For example, we may inform our advertisers and other third parties that a certain proportion of the Service’s users are female or are in certain geographies.

Choices and Access:

If you have established a user account with us, you may update, correct, or delete your profile information and preferences at any time by accessing your settings through the Service. Additionally, you may request that we delete all information about you that we have received from Facebook by emailing us at [email protected]. If you wish to access or amend any other personal information we hold about you that we have collected through the Services, you may contact us at [email protected].
Please be aware that while your changes may be reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, analytics, and prevention of fraud and abuse. To protect your privacy and security, we may ask you to verify your identity before granting you account access or making corrections to your information. You are responsible for maintaining the secrecy of your unique password and account information at all times. Third-Party Connected Services
We may from time to time permit users with accounts on certain third-party services such as Facebook (“Third-Party Connected Services”) to log in to such third-party services through our Services, and may offer you the ability to connect our Services to Third-Party Connected Services. If you connect to any of our Services through a Third-Party Connected Service, you may be able to send alerts, comments, and messages on such third-party services, and may publish some of your activities on our Services to the third-party service. In any request for authorization to connect, we may ask you for additional rights or permissions with respect to Third-Party Connected Services and information, including personal information, that we obtain from them.
Any personal information you provide on or to any Third-Party Connected Service is provided directly to such Third-Party Connected Service and is subject to that third party’s policies governing privacy and security. We are not responsible for the sharing, posting, commenting, or other content and information-gathering practices on any Third-Party Connected Services. Please review their terms of service and privacy policies carefully before using any Third-Party Connected Services and connecting to our Services.
By connecting to any Third-Party Connected Services in connection with our Services, you permit us to access and use all information related to your account on the Third-Party Connected Service that may be accessible to us through the any Third-Party Connected Service pursuant to this Policy. For example, if you permit us to connect to your Facebook profile, we may collect information from your Facebook profile such as your name, email, gender, birthday, current city, profile picture URL, list of friends, and a device token that uniquely identifies your mobile device. To limit or control the information that is available to us through any such Third-Party Connected Service, or to disconnect any Third-Party Connected Service from our Services, you should check (and, if applicable, modify) the applicable settings on the Third-Party Connected Service.

Links:

The Services may contain links to other Web sites, products, or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this Policy will not apply to your activities or any information you disclose while using third-party products or services or otherwise interacting with third parties. We are not responsible for the privacy practices of these third-party websites and services. We encourage you to carefully review the privacy policies applicable to any Web site or service you visit other than the Service before providing any personal information on them.

Survey Serving Technology:

This app uses an on-line survey platform, through which, anyone may conduct surveys. This platform collaborates with Developers of applications for smartphones in order to have access to users of such applications and address survey questionnaires to them. When a user connects to this app, it detects whether the user has enabled his Device’s interest-based-ads settings (Advertising ID for Android/Advertising Identifier for iOS). If not, it does not proceed to any action and cannot offer any survey to the user or collect any of his/her Data. If the user has enabled such settings, a specific set of user’s device data and response meta-data is automatically sent to Pollfish servers. These data will be associated with your answers to the questionnaires. By downloading the application you accept this privacy policy document and you hereby give your consent for the processing by Pollfish of the aforementioned data. Furthermore, you are informed that you may disable Pollfish operation at any time by (a) enabling the “opt out of interest-based advertising” in your device Settings area or by (b) using the Pollfish “opt out section” available on Pollfish website . We invite you to check the respondent’s terms of use, if you wish to have more detailed view of the way Pollfish works.”

Our Commitment to Children’s Privacy:

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or maintain personal information from persons under 13 years of age on the Services, and no part of the Services is directed to persons under 13. If we learn that personal information of children under the age of 13 has been collected on the Service without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has obtained an account on the Service or otherwise provided personal information to us, then you may alert us at [email protected] and request that we delete that child’s personal information from our systems.

Data Security:

We use commercially reasonable physical, managerial, and technical safeguards in an effort to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Once we receive your transmission of personal information, we make commercially reasonable efforts to ensure the security of our systems. Please be aware, however, that this is not a guarantee that such personal information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at [email protected].

International Visitors:

The Services are hosted in the United States and are intended solely for visitors located within the United States. If you nonetheless choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, please be aware that you are transferring your personal information outside of those regions to the United States and, by providing your personal information on the Services, you consent to that transfer.

Business Transfers:

In the event that all or a portion of 33Numbers or its assets is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer and/or assign the information that we have collected from users, including personal information, in connection with such merger, reorganization, recapitalization, acquisition, sale, or other change of control.

Notice to California Residents:

California law permits residents of California to request certain details about what personal information a company shares with other companies for such other companies’ direct (and independent) marketing purposes. 33Numbers does not share your information with other companies for such other companies’ direct (and independent) marketing purposes. If you have any questions about our practices with respect to your personal information or your rights under California law, please write to 33Numbers at its address below.

Consent

By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Consent is required for 33Numbers to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by contacting [email protected].

Your Rights as a Data Subject

Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organization.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review: in the event that 33Numbers refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the Complaints clause below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.

Complaints

Changes and Updates to this Policy:

We may occasionally update this Policy. When we do, we will also revise the “last updated” date at the bottom of the Policy. Your continued use of the Services after a revised Policy has become effective indicates that you have read, understood and agreed to the then-current version of the Policy. If we change this Policy in a manner that is materially less restrictive of our use or disclosure of your personal information, we will use reasonable efforts to notify you of the change and to obtain your consent prior to applying the change to any personal information that we collected from you prior to the date the change becomes effective. For example, we may send a message to your email address, if we have one on file, message you through the Services, or generate a pop-up or similar notification when you access the Services for the first time after such material changes are made. Material changes to this Policy will be effective upon the earlier of (i) your first use of any of the Services with actual knowledge of such change, or (ii) 30 days from providing you notice of such change as described in this section. We encourage you to periodically review this Policy to stay informed about how we collect, use, and disclose information.

Contact Information:

Please contact us with any questions or comments about this Policy, your personal information collected on the Services, our third party disclosure practices, or your consent choices by email: [email protected].