Top Games, Inc. Personal Information Processing Policy
Last updated February 2, 2023.
You can review changes to this policy by clicking the appropriate version below.
3. Personal Data Collected.
3.1 Data Controller
Top Games, Inc. is the data controller of your personal information. Top Games, Inc. can be reached at firstname.lastname@example.org or at 585 Glenwood Avenue, Menlo Park, CA 94025.
3.2. Personal Data You Provide To Us On Our Site.
a) Types of Personal Data. We and our service providers collect the Personal Data set forth below in order to provide the Site to you, or because we are legally required to do so. If you do not provide the Personal Data we request, we may not be able to provide you with the Site.
The Personal Data we and our service providers collect includes but is not limited to:
Communications you send to us.
b) When Personal Data is Collected.
You may be required to provide us with certain information that may constitute Personal Data in the following ways:
In addition, if you choose, you may participate in a Top Games e-mail list server by subscribing within the Site or by contacting Top Games staff directly. You may unsubscribe from these e-mail list servers by following the unsubscribe instructions found within the list email.
Member Login Information.
Information Collected through Various Forms.
We and our service providers may collect Personal Data in a variety of ways, including: (i) through use of the Site, e.g., when you sign up for a gaming service, forum community, or make a purchase; or (ii) from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.
Personal Data You Disclose Relating to Others.
3.3. Personal Data You Provide To Third Parties On Our Site.
Please note that we use certain third party service providers on our Site to enhance your experience or deliver certain services. These providers may collect Personal Data about you in performing their services and/or functions on our Site.
3.4. Information Collected Automatically
|Type of Cookies||Description||Managing Settings|
|Required cookies||Required cookies enable you to navigate our Site and use its features, such as accessing secure areas of our Site and using our services.
|Because required cookies are essential to operate our Site, there is no option to opt out of these cookies.|
|Performance cookies||These cookies collect information about how you use our Site, including which pages you go to most often and if they receive error messages from certain pages. We only use information from these cookies in an aggregated and anonymous manner. It is only used to improve how our Site functions and performs.
From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit our Site. We may also utilize Flash cookies for these purposes.
|To learn how to opt out of performance cookies using your browser settings click here.
To learn how to manage privacy and storage settings for Flash cookies click here.
|Functionality cookies||Functionality cookies allow our Site to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of our Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our Site to personalize your visit.
|To learn how to opt out of functionality cookies using your browser settings click here.
To learn how to manage privacy and storage settings for Flash cookies click here.
Third parties, with whom we partner to provide certain features on our Site or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.
|To learn more about these and other advertising networks and their opt out instructions, click here.
To learn how to manage privacy and storage settings for Flash cookies click here.
c) Other Tracking Technologies.
When you visit our Site, we may collect your IP address for tracking purposes. For example, we may use IP addresses to monitor the regions from which you navigate our Sites. We may also use web beacons alone or in conjunction with cookies to compile information about your usage of our Site and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Site. We may use web beacons to operate and improve our Site and email communications.
d) Analytics Software Tools.
We use Google Analytics on our Site to help us analyze the traffic on our Site. For more information on Google Analytics’ processing of Personal Data, please see http://www.google.com/policies/privacy/partners/. By using a browser plugin http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.
4. The Purposes For Which We Use Personal Data.
If you submit or we collect Personal Data through our Site, then such Personal Data may be used in the following ways: (i) to provide, analyze, administer, and improve our Site and services, (ii) to contact you in connection with our Site and certain services, notifications, events, programs or offerings that you may have registered for, (iii) to send you updates and promotional materials that you have registered for, (iv) to identify and authenticate your access to the parts of our Site and services that you are authorized to access, (v) to provide customer service support, including but not limited to in-app communication and tickets; (vi) for recruiting and human resources administration purposes, and (vii) to protect our rights and/or our property and to ensure the technical functionality and security of our Site.
5. How We Disclose Personal Data.
We do not sell, lease, rent or otherwise disclose the Personal Data collected from our Site to third parties unless otherwise stated below or with your consent.
5.1. Our Third Party Providers.
5.2. Social Media Services.
We engage advertising services to assist us in advertising our brand and Site. From time to time, those services target advertisements on third-party websites based on cookies or other information indicating previous interaction with our Site.
5.4. Business Partners
From time to time, we may partner with other companies to jointly offer products or services. For example, we partner with various game development and design studios to deliver you gaming services. If you purchase or specifically express interest in a jointly-offered product or service from us, we may share Personal Data collected in connection with your purchase or expression of interest with our joint promotion partner(s). We do not control our business partners’ use of Personal Data we collect, and their use of the information will be in accordance with their own privacy policies.
5.5. In the Event of Merger, Sale, or Change of Control.
5.6. Other Disclosures.
6. Retention of Personal Data.
We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (i) fulfill the purposes that are described in Section 4 (The Purposes For Which We Use Personal Data), and (ii) comply with applicable law.
7. Your Rights.
7.1 Personal Data.
If you have an account on our Site, we provide access to—and the ability to edit or delete—certain categories of Personal Data through the account. If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via our Site, you may submit a request
Via Email: email@example.com (subject heading “Privacy”)
Via Post: Top Games, Inc. Attn: Legal – Privacy 585 Glenwood Avenue, Suite 3, Menlo Park, CA 94025 USA.
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you. We encourage you to first reach out to us at firstname.lastname@example.org so we have an opportunity to address your concerns directly before you do so.
If you are a resident of California, please see Section 12 for additional information concerning your rights under California law.
7.2. Opting-Out of Promotional Emails.
You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us, or by responding to the emails directly and requesting removal if such a link is not available. Additionally, you may send a request specifying your communications preferences to email@example.com. Customers cannot opt out of receiving transactional emails related to their account with us or our services. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).
7.3 Deletion of Data and Accounts.
We provide various methods for users to delete accounts and data. Each of these is permanent and can not be reversed; also, all games, assets and history will be permanently deleted.
Requests for data deletion will also mean the account will be closed and deleted as we require personal data for the purposes described in Section 4 to keep accounts active and open.
To delete data and your account:
a) In App: Go to settings, Account and then select “Delete Account”.
b) Mail: Top Games, Inc. (Attn: Privacy), 585 Glenwood Avenue, Menlo Park, CA 94025 USA
7.4 Assistance for People With Disabilities.
8. Personal Data Transferred Internationally.
If you use the Site from outside the United States, please be aware that personal information may be collected, stored, and processed in the United States and Canada. If we transfer personal information internationally, we take steps to provide adequate safeguards, such as entering into standard contractual clauses with our service providers. Please be aware that the data protection laws of the United States might not be as comprehensive as those in your country.
9. Data Security.
The security of Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.
10. Children’s Privacy.
10.1. Children Under 13.
Children under the age of 13 should not use our websites or games at any time. In the event that we confirm that we have inadvertently gathered personal information from children under the age of 13, we will take reasonable measures to promptly remove such information from our records. We do not knowingly collect or store any Personal Data from children under 13. If parents believe that we have unintentionally collected their children’s’ Personal Data, they may request the deletion of the information by contacting us at:
Top Games, Inc. Attn: Legal – Privacy 585 Glenwood Avenue, Suite 3, Menlo Park, CA 94025 USA
They may also e-mail us at firstname.lastname@example.org.
10.2. Note to Parents.
11. How We Respond to Do Not Track Signals.
Top Games does not track Site users over time and across third-party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about an individual consumer’s online activities over time and across third-party web sites or online services.
12. Your California Privacy Rights.
This section applies to our collection and use of “Personal Information”, as defined under California law if you are a resident of California.
Categories of Personal Information Collected, Used and Disclosed
“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. In accordance with California law, we collected the following categories of Personal Information within the preceding 12 months:
Identifiers such as your name, alias, email address, mailing address, IP address, and online identifiers;
Certain categories of Personal Information are described in subdivision (e) of California Civil Code Section 1798.80;
Internet or other electronic network activity information, including information on your usage of our Website (“Usage Information”);
Information used to create a profile about a consumer reflecting the consumer’s preferences or behavior; and
Commercial information, including records of products or services purchased or other purchasing histories.
We disclose each of these categories of Personal Information to our service providers to the extent necessary for them to facilitate our business purposes (including any purpose specified in Section 4, above). Additionally, within the past 12 months, some of our online advertisers may have used and disclosed Usage Information collected automatically from the Service. This may be a “sale” as broadly defined under the CCPA. Therefore, we provide you the right to opt out of this “sale” of Personal Information as described, below.
Your California Privacy Rights
If you are a resident of the state of California, you have the following rights:
Right to Know. You may have the right to request information on the categories of personal information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such personal information is collected and shared. You also have the right to request information on the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your personal information.
Right to Delete. You may have a right to request us to delete Personal Information that we collected from you.
Right to Opt-Out. You have a right to opt-out of certain disclosures of Personal Information to third parties, if such disclosures constitute a “sale” under California law. As noted above, in the past twelve (12) months we enabled advertisers to collect certain information from the Site, which the advertisers may use to improve their interest-based advertising networks. Regardless of whether this is a “sale,” you may opt-out of interest-based advertising as described in Section 3.3, above.
If you would like to exercise your rights listed above, please contact (or have your authorized agent contact) us using the contact information listed below. When doing so, please tell us which right you are exercising and provide us with contact information to direct our response. We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification. You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights.
Additionally, if you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Data about you by Top Games to third parties for the third parties’ direct marketing purposes. To make such a request under this Section, please send an email to email@example.com or write to us: Top Games, Inc. Attn: Legal – Privacy 585 Glenwood Avenue, Suite 3, Menlo Park, CA 94025
13. Contacting Us.
14. Your South Korea Rights.
14.1. Procedure and Method of Destruction of Personal Information
Top Games destroys personal information without delay when the information becomes unnecessary, such as the lapse of the personal information retention period as outlined in section 6 or achievement of the purpose of processing as outlined in section 4 above.
If the personal information retention period agreed by the user has lapsed or the personal information needs to be kept in accordance with other laws despite the achievement of the purpose of processing, the personal information may be moved to a separate database (DB) or stored to be preserved differently. Separately stored personal information will not be used for any purpose other than the purpose of preservation unless it is required by law.
1) Destruction Procedure
The company selects the personal information for which the reason for destruction has occurred and destroys the personal information with the approval of the company’s personal information protection officer.
2) Destruction Method
The company destroys personal information recorded and stored in the form of electronic files using methods such as low-level format so that the record cannot be reproduced, and personal information recorded and stored in paper documents is destroyed by shredding or incineration with a shredder.”
14.2 Personal Information Protection Officer
Name: Legal Department (Privacy)
Email: firstname.lastname@example.org (subject heading Privacy)
Address: 585 Glenwood Avenue, Menlo Park, CA 94025
14.3 Notice on Overseas Transfer
|Company Name||Country||Purpose of Use||Data||Transfer occurrence||Retention period|
|Top Games, Inc.||Canada and United States||Account Service||As per section 3.||As per section 3.||As per section 6.|
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