Privacy Policy
Stern Pinball Privacy Policy
Last Updated: October 4, 2021
Effective Date: October 4, 2021
This Privacy Policy describes how Stern Pinball, Inc. and our affiliates ([collectively,] “Stern,” “we,” “us,” or “our”) collects, uses, shares, and safeguards personal information and your rights and choices with respect to your personal information.
This Privacy Policy covers our website, products, software, applications, content, data feeds and other services (“Services”) on which an authorized link to this Privacy Policy is posted. This Policy covers our practices regarding stern users of all ages, including a unique set of practices for those under the age of 13 (“Child Users”). This Privacy Policy is not, however, a contract and does not create any legal rights or obligations.
To the extent our data processing activities change or new laws impact our obligations, we may update this Privacy Policy. When we do, we will revise the “last updated” date at the top of the policy. If we make changes that we deem material, we will use reasonable efforts to notify (such as by placing a notice on the website or in a game, or by sending you a notice to the email address we have on file for you). Our privacy policy includes an “effective date” which refers to the date that the current version took effect.
If you have any questions, comments, or concerns regarding this Privacy Policy or our data practices, please contact us at info@sternpinball.com the following support form, telephone number, or mailing address:
TABLE OF CONTENTS
1. Types of Personal Information We Collect
2. Children’s Information
3. Cookies and Other Technical Information
4. Why We Collect Your Personal Information
5. How We Share Your Personal Information
6. How We Protect Personal Information
7. Your Choices
8. Your Rights in Relation to Your Personal Information
9. Notice to California Residents
10. Other Important Information
11. Contact Information
PRIVACY NOTICE
- Types of Personal Information We Collect
The following provides examples of the type of information that we collect from you and how we use that information if you are over the age of digital consent. If you are under the age of digital consent under the applicable laws in your jurisdiction, we consider you to be a “Child User.” For more information about how we process Child Users’ personal information, please see the Children’s Information section below.
Context |
Types of Data |
Primary Purpose for Collection |
Account Registration |
We collect your birthdate, country of residence, name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account. |
We have a legitimate interest in providing account related functionalities to our users. Accounts can be used for tracking game play, easy checkout and to save your preferences and transaction history. |
Game Play |
We collect information about the Stern games that you play online and on Stern pinball machines around the world when logged in to your account. This information may include your game play stats and performance and, when you play on a Stern pinball machine, the location of the machine. |
We use your information to perform our contract to provide you with our products or services. |
Cookies and First Party Tracking |
We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. |
We have a legitimate interest in making our website operate efficiently. |
Cookies and Third Party Tracking |
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Demographic Information |
We collect personal information, such as your age or location. |
We have a legitimate interest in understanding our users and providing tailored services. |
Distance Information |
When you use one of our Apps we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device. |
We have a legitimate interest in understanding our users and providing tailored services. In some contexts, our use is also based upon your consent to provide us with geo location information. |
Email Interconnectivity |
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Feedback/Support |
If you provide us feedback or contact us for support we collect your name and e-mail address, as well as any other content you send to us so we can reply. |
We have a legitimate interest in receiving, and acting upon, your feedback or issues. |
Mailing List |
When you sign up for one of our mailing lists we collect your email address or postal address. |
We also have a legitimate interest in sharing information about our products or services. |
Mobile Devices |
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Order Placement |
We collect your name, billing address, shipping address, e-mail address, phone number when you place an order, and use a third party provider to collect your credit card information. |
We use your information to perform our contract to provide you with products or services. |
Partner Promotion |
We collect information that you provide as part of a co-branded promotion with another company. |
We have a legitimate interest in fulfilling our promotions. |
Surveys |
When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. |
We have a legitimate interest in understanding your opinions and collecting information relevant to our organization. |
Sweepstakes or contests |
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Website interactions |
We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. |
We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. |
Web Logs |
We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. |
We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular. |
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
- Children’s Information
A “Child User” is a person under the age of digital consent under the law in their jurisdiction. We do not intentionally collect personal information from children without seeking any required parental approval in accordance with applicable legal and regulatory obligations, such as the U.S. Children’s Online Privacy Protection Act (“COPPA”).
We will ask you to provide age-related information in order to help us comply with laws like COPPA. Once you have been identified as a Child User, you may register an account with us using a registration process similar to the one adults go through; however, Child Users will first be subject to a parental notice and consent process prior to activation of their account. To initiate the registration and consent process for a Child User, we collect a parent or legal guardian’s email address.
If a user indicates they are a COPPA minor, we’ll require that user to complete a parental approval process before continuing to access our Services. This process is designed to notify parents that their child has requested access to our Services, inform them about our privacy practices, offer them the opportunity to approve our collection and use of their child’s information as described in this policy, and describe the controls that we make available to them.
The personal information we collect from or about Child Users is used to give them access to certain features of the Services and communicate with a parent or legal guardian about the Child User’s registration, including for the purpose of verifying their information in connection with the registration. We do not share or otherwise disclose Children’s personal information, except (1) as may be necessary to protect the safety of a Child, including by disclosing their personal information, where appropriate, to law enforcement agencies or for an investigation related to public safety; (2) to enable us to take precautions against liability; (3) to protect the safety and security of the Services; or (4) where required to do so by law or legal process.
We use third-party service providers such as SuperAwesome Trading Limited which is described below to collect or maintain Child Users’ personal information through the Services.
At any time, a parent or legal guardian may review their Child’s Personal Information maintained by us, require us to correct or delete such personal information, request that we delete their Child’s account, and/or refuse to permit us from further collecting or using their Child’s Personal Information by contacting us using the email address provided in the Contact section below. To protect parents and legal guardians’ privacy and security and the privacy and security of Children, we may require a parent or legal guardian to take certain steps or provide additional information, which we will keep strictly confidential, to verify their identity before we provide any information about the Child or make any corrections.
SuperAwesome. We use Kids Web Services (“KWS”), a product of SuperAwesome Trading Limited of 2-4 Packhorse Road, Gerrards Cross, Buckinghamshire, SL9 7QE, England, United Kingdom for obtaining verified parental consent (if applicable) and informing parents of their Child’s online activities. You may contact SuperAwesome directly at privacy@superawesome.com for any questions related to their use of Personal Information. SuperAwesome’s privacy policy for KWS can be found at https://www.superawesome.com/kids-web-services-privacy-policy/.
SuperAwesome’s KWS is designed specifically to power kid-friendly registrations and digital experiences, as well as parental management tools, across the web and mobile ecosystem in compliance with the COPPA and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation) (“GDPR”). KWS is certified as COPPA-compliant by the kidSAFE Seal Program, an FTC-Approved COPPA Safe Harbor Program. The kidSAFE Seal Program is an independent safety certification service and seal-of-approval program designed exclusively for children-friendly websites and technologies, including child-targeted game sites, educational services, virtual worlds, social networks, mobile apps, connected products, and other similar interactive services and technologies. Click on the seal or go to www.kidsafeseal.com for more information. To learn more about COPPA, you may also consult this simple one-page informational guide from the kidSAFE Seal Program: www.kidsafeseal.com/knowaboutcoppa.html.
SuperAwesome is also a valid licensee, and participating member, of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, SuperAwesome has voluntarily undertaken this privacy initiative, and its services have been reviewed by ESRB Privacy Certified to meet established online information collection, use and disclosure practices. As a licensee of this privacy program, SuperAwesome’s services are subject to audits and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.
- Cookies and Other Technical Information
We, and our vendors, and business partners may send “cookies” to your computer or use similar technologies to understand and enhance your online experience on our websites and through our advertising and media across the Internet and mobile apps.
Cookies are small text files placed in your browser. We may use cookies and other technologies to help recognize your browser or device, maintain your preferences, provide certain website or app features, and collect Information about interactions with our websites, our content, and our communications. We may also use cookies and other technologies (i) to provide, develop, maintain, personalize, protect, and improve our Services and to operate our business, (ii) to perform analytics, including to analyze and report on usage and performance of our Services and marketing materials, (iii) to protect against, identify, and prevent fraud and other unlawful activity, (iv) to create aggregate data about groups or categories of our users, (v) to synchronize users across devices, affiliates, business partners, and select third parties, and (vi) for us and our affiliates, business partners, and select third parties to target, offer, market, or advertise products, programs, or services. Cookies and other technologies also facilitate, manage, and measure the performance of advertisements displayed on or delivered by or through us and/or other networks or sites.
Managing cookies and other technologies. Cookies can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). Check your browser settings to learn how to delete cookies.
You may adjust your browser to reject cookies from us or from any other website. Controlling cookies via browser controls may not limit our use of other technologies. Please consult your browser’s settings for more information. However, blocking cookies or similar technology might prevent you from accessing some of our content or Services’ features.
Some of our Services may use Google Analytics to analyze traffic. You can find out more information about Google Analytics cookies by visiting the follow location provided: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. To opt out of Google Analytics relating to your use of our Sites, you can download and install the Browser Plugin available by visiting the following location: https://tools.google.com/dlpage/gaoptout?hl=en.
- Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions. We continue to review new technologies and may adopt a standard once one is created.
- Why We Collect Your Personal Information
- In addition to the purposes and uses described above, we use information in the following ways:
- To identify you when you visit our websites or play a Stern pinball machine or game.
- To allow you to play games and track your performance through our website.
- To provide products and services or to process returns.
- To improve our services and product offerings.
- To streamline the checkout process.
- To conduct analytics.
- To respond to inquiries related to support, employment opportunities, or other requests.
- To send marketing and promotional materials including information relating to our products, services, sales, or promotions, or those of our business partners.
- For internal administrative purposes, as well as to manage our relationships.
- Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you complete an online purchase we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
- How We Share Your Personal Information
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
- Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
- Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
- Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
- Public. Our website may provide the opportunity to post comments, or reviews, in a public forum. If you decide to submit information on these pages, that information may be publicly available.
- Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
- Service Providers. We may share your information with service providers. Among other things, service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.
- In addition to the sharing described above, we may share your information with other third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy if we have your consent to do so
- Your Choices
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
- Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed.
- Your Rights in Relation to Your Personal Information
- Depending on applicable law where you are located, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, Stern has absolute discretion in providing you with those rights. The rights you may have include:
- Access To Your Personal Information. You may request access to your personal information held by us. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
- Changes To Your Personal Information. We rely on you to update and correct your personal information. Most of our website allow you to modify your account profile. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.
- Deletion Of Your Personal Information. You may request that we erase your personal information, subject to applicable law. Please note that we may be required by law to retain your information.
- Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.
- Objection to Certain Processing. Depending on the applicable law, you may be able to object to our use or disclosure of your personal information by contacting us at the address described below.
- Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
- Withdraw consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of Stern’s processing based on consent before your withdrawal.
- Automated decision making. In some jurisdictions, you may have the right not to be subject to a decision which significantly impacts your rights that is based solely on automated processing ((where a decision is taken about you using an electronic system without human involvement). No decision will be made by Stern about you solely on the basis of automated decision making which has a significant impact on you.
- We will not discriminate against you for exercising your rights. Please address written requests and questions about your rights to info@sternpinball.com.
If you are located in a jurisdiction that grants you some or all of the rights above, you should note that your rights with regard to your personal information are not absolute. Depending upon the applicable law, requests may be denied: (a) when denial of the request is required or authorized by law; (b) when granting the request would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.
Note that, as required by law, in order to exercise your rights, we will require you to prove your identity. We may verify your identity by a phone call or an email. Depending on your request, we will ask for information such as your name, the last location you played a Stern pinball machine using your account, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us. If you are an authorized agent submitting a request on behalf of an individual, you must attach a copy of the following information to the request:
- Documentation indicating that you have authorization to act on the consumer’s behalf (e.g., a signed and notarized consent form); and
- If you are a business, proof that you are registered with the Secretary of State to conduct business in California.
If we do not receive both pieces of information, the request will be denied.
- How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
Our website permits you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.
- Notice to California Residents
California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether the following categories of personal information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” (as those terms are defined under California law). We do not “sell” your personal information. The table below indicates the categories of personal information we collect and transfer in a variety of contexts. Please note that because this list is comprehensive, it may refer to types of information that we collect and share about people other than yourself. For example, while we transfer credit card or debit card numbers for our business purpose in order to process payments for orders placed with us, we do not collect or transfer credit card or debit card numbers of individuals that submit questions through our website’s “contact us” page.
Categories of Personal Information We Collect |
To Whom We May Disclose Personal Information for a Business Purpose |
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number or other similar identifiers. |
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Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, state identification card number, insurance policy number, education, bank account number, credit card number, debit card number, and other financial information, medical information, and health insurance information. |
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Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc. |
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Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement. |
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Geolocation data |
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- Other Important Information
The following additional information relates to our privacy practices:
- Transmission of Information to Other Countries. We operate internationally. As a result, your information may be processed in a foreign country where privacy laws may be less stringent than the laws in your country. Nonetheless, where possible we take steps to treat personal information using the same privacy principles that apply pursuant to the law of the country in which we first received your information. By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.
- Personal Information Transferred Out of the EU. We rely on Standard Contractual Clauses approved by the European Commission to facilitate the business to business international of personal information collected in the EEA, the United Kingdom and Switzerland (“European personal information”), and any onward transfer of such information, to the extent the business receiving the European personal information is located in a country that the EU considers to not provide an adequate level of data protection. We may also rely on an adequacy decision of the European Commission confirming an adequate level of data protection in the jurisdiction of the party receiving the information.
- Third Party Applications/Websites. Our Service may link to third party websites. We have no control over the privacy practices of websites or applications that we do not own. For more information about the third party’s data processing activities, please refer to the third party’s privacy notice.
- Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
- Contact Information. If you have any questions, comments, or complaints concerning our privacy practices please contact us at info@sternpinball.com. If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.