Effective Date: August 8, 2023
What Information does Monsarrat Collect?
Information You Provide to Us:
We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers on behalf of other businesses, or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. If you do not want to receive communications from us, please indicate your preference by clicking on the unsubscribe option in our messages.
Information Collected Automatically:
We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services; for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.
What Cookies and Tracking Technologies Does Company Use?
|Cookie Name||Duration (Retention Period)||Description (purpose)|
|_ga||2 years||Used to distinguish users.|
|_gid||24 hours||Used to distinguish users.|
|_ga_<container-id>||2 years||Used to persist session state.|
|_gac_gb_<container-id>||90 days||Contains campaign related information. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out. Learn more.|
|Crumb||Session||· Prevents cross-site request forgery (CSRF).
|_xsrf||Session||Prevents cross-site request forgery (CSRF)|
|dbb||One Year||Identifies the session of a logged-in user inside and outside of a game|
|dbb_play||One Year||Identifies the session of a logged-in user inside a game|
|u||One Year||Identifies the browser session of any user inside and outside of a game|
|s||Session||Identifies the browser session of any user inside and outside of a game|
|CloudFront-Policy||One Year||Mediates Access to resources on the platform|
|CloudFront-Key- Pair-Id||One Year||Mediates Access to resources on the platform|
|CloudFront- Signature||One Year||Mediates Access to resources on the platform|
Information Collected From Other Websites and Third Party Authentication Sites / “Do Not Track Policies”
Our Policies Concerning Children’s Personally Identifiable Information
We do not knowingly collect personally identifiable information from someone we know to be a child under the age of thirteen (13) without prior parental consent. IF YOU ARE THIRTEEN (13) YEARS OLD OR YOUNGER, PLEASE DO NOT USE OUR SERVICES, INCLUDING, WITHOUT LIMITATION, OUR WEBSITES, AND DO NOT SUBMIT ANY INFORMATION TO THE SERVICES OR TO MONSARRAT. Our websites and applications may contain features that may be attractive to children; therefore, children should not be granted access to any passwords or use of the parent or guardian’s account without direct monitoring and supervision by the parent or guardian. Company is not responsible for any unauthorized use of accounts, and we encourage everyone to protect their passwords and not disclose them to anyone.
Will Company Share Any of the Personal Information it Receives?
- Information that’s been de-identified. We may de-identify your Personal Information so that you are not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. However, we never disclose aggregate usage or de-identified information to a partner (or allow a partner to collect such information) in a manner that would identify you as an individual.
- Affiliated Businesses: In certain situations, businesses or third party websites with which we are affiliated may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. One such service may include the ability for you to automatically transmit Third Party Account Information to your Services profile or to automatically transmit information in your Services profile to your third party account; for example, during Facebook signup we may use your full name to automatically set the “Display Name” of your Company account (such as your monsarrat.com account).
- Our Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you; for example, we may use an email delivery and processing company to send email messages to you. Unless we tell you differently, our agents do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. Note that an “agent” may also be considered a “partner” in certain circumstances, and may be subject to the terms of the “Information that’s been de-identified” section above in that regard.
- User Profiles and Submissions: Certain user profile information, including your handle, display name and description that you have set during sign-up or use of the Services, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Your account privacy settings may allow you to limit the other users who can see the Personal Information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you add to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (in content that you create, comments that you post, in messages and in chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your handle or display name may also be displayed to other users if and when you send messages or comments or create content on the Services and other users can contact you through messages and comments. Additionally, if you sign into the Services through a third-party social networking site or service, your list of “friends” from that site or service may be automatically imported to the Services, and such “friends,” if they are also registered users of the Services, may be able to access certain non-public information you have entered in your Services user profile. Again, we do not control the policies and practices of any other third-party site or service.
- Business Transfers: We may choose to buy or sell our business, certain games or apps, or certain portions or assets related to either, and may share and/or transfer customer information in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information could be one of the assets transferred to or acquired by a third party.
The legal basis for our use and processing of Personal Information (and your personal data) for the noted purposes is based on the following:
|Purpose of the processing||Legal basis for the processing|
|To provide you access to the Services, to administrate your user account and communicate with you regarding your user account and use of the Services.||Performance of contract. (Art. 6 para. 1 lit. b GDPR).|
|To keep you informed regarding Monsarrat’s products and services and company news, as well as other marketing communications.||Consent.
Monsarrat’s legitimate interest.
|To prevent, detect, investigate and take measures against criminal activity, fraud and misuse of or damage to our Services or network, and to take measures against other threats against Monsarrat’s or a third party’s rights.||Balancing of interests (Art. 6 para. 1 lit. f GDPR) where Monsarrat has pursued the following legitimate interests:
● Monsarrat’s interest of investigating suspicion of and taking measures against misuse of or damage to our services or network;
● Monsarrat’s and/or third party’s interest of investigating and producing evidence regarding criminal activity, fraud and other threats against its interest;
● Monsarrat’s interest of establishing and exercising its legal rights;
● Monsarrat’s and/or third party’s right to protect its safety or property; and
● Competent authority’s interest of conducting law enforcement activities and collecting evidence for such purposes.
|To comply with (i) applicable laws, regulations, court orders, government requests, and law enforcement agencies’ requests, or (ii) the extent otherwise required by applicable law.||Compliance with a legal obligation to which Monsarrat is subject. (Art. 6 para. 1 lit. c GDPR).|
|To establish or exercise our legal rights or defend against legal claims, or protect the safety or property of our employees, contractors, customers, users or others.|| Balancing of interests (Art. 6 para. 1 lit. f GDPR) where Monsarrat has pursued the following legitimate interests:
● Monsarrat’s interest of pursuing its legal rights; and
● Monsarrat’s interest of safeguarding its business relationships.
|Marketing or email campaigns||Consent. (Art 6 para 1 lit. a GDPR)|
Is Personal Information about me secure?
Your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via that third party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
Company is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries.
What Personal Information can I access?
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
- email address and password;
- user profile information (including any handle or description of yourself, along with some of the content you have created, your avatar, etc.)
The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at firstname.lastname@example.org.
- The right of access.This is your right to see what data is held about you by us and to receive certain additional information and copies of your personal data.
- The right to rectification.The right to have your data corrected or amended if what is held is incorrect in some way.
- The right to erasure.Under certain circumstances, including where your personal data is no longer required for the purposes it was collected, or your consent has been withdrawn, you can ask for your personal data to be deleted. This is also called “the right to be forgotten”.
- The right to restrict processing.This gives you the right to ask for a restriction to processing of personal data, such as in the case where the accuracy of the data is disputed.
- The right to withdraw consent. If processing is based on your consent, you have the right to refuse to provide your consent and – without impact to data processing activities that have taken place before such withdrawal – withdraw your consent to processing of your personal data at any time.
- The right to object. You have the right to object on grounds relating to your particular situation, that your personal data is processed. In this case, please provide us with information about your particular situation. After the assessment of the facts presented by you we will either stop processing your personal data or present you our compelling legitimate grounds for continuing to do so.
- The right to data portability. This right entitles you to receive a copy of your personal data that you have provided to us in a structured, commonly used and machine-readable format, or request us to transmit your personal data to another data controller.
- The right to complain. This means you may lodge a complaint before the competent data protection regulators.
You may exercise the rights referred to above or pose any questions or make any complaints regarding our data processing by contacting us, by sending an email to us at email@example.com or write to us at the address below. We will process such requests in accordance with applicable law.
Please note that if you object, restrict or otherwise refuse the processing of certain or all of your personal data and/or ask that we delete your personal data you might not be able to use some or all of the Services or certain aspects or elements thereof.
State Privacy Rights (and Similar Laws in Other Jurisdictions)
Your Privacy Rights Under California Law:
California law permits California residents to request from companies conducting business in California a list of third parties to which the company has disclosed personally identifiable information during the preceding year for direct marketing purposes as well as other details regarding types of information collected and how it is used. Company has not and will not share your personally identifiable information with third parties for their direct marketing purposes; accordingly, it will not maintain such a list of third parties. If you are a resident of California and want additional information confirming how the company does not share your personally identifiable information with third parties for their direct marketing purposes, or additional details regarding information that is collected, you may contact us at firstname.lastname@example.org with the words “California Privacy” in the subject line of your email.
California Business and Professions Code Section 22581 permits California residents under the age of eighteen (18) who are registered users of our website or other aspects of the Services to request and obtain the removal of content or information that they have posted to public forums, such as chat rooms and bulletin boards. To make such a request, please contact us at email@example.com with the words “California Privacy” in the subject line of your email, or write to us at the address above and include a heading reference with the words “California Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).
The California Consumer Privacy Act of 2018 (“CCPA”) permits California residents to request that we (1) disclose what Personal Information we collect, use, disclose and sell, and (2) delete your Personal Information. As indicated above, other states and jurisdictions have or may have similar laws. To make such a request (whether further to CCPA or a similar law in another state or jurisdiction), please contact us at firstname.lastname@example.org with the words “Delete My Information” (or include the name of your state or jurisdiction) in the subject line of your email, or write to us at the address above and include a heading reference with the words “Delete My Information”, and include in your email or letter the request that we delete all of your Personal Information. We will process such requests in accordance with applicable law. CCPA also offers an opt-out right with respect to the sale of personal data. However, because we do not sell your personal data we do not offer such an opt-out mechanism. We will not discriminate against you if you exercise your CCPA rights.
Your Rights under the Colorado Privacy Act: Residents of Colorado are granted certain rights under the Colorado Privacy Act (CPA). These rights include the right to access personal data, to request correction of inaccurate personal data, and to delete personal data under certain circumstances. Moreover, such residents also have the right to receive a copy of their personal data in a portable and readily usable format. Additionally, residents of Colorado possess the right to opt-out of the processing of their personal data for targeted advertising purposes, the sale of personal data, or profiling that produces legal or similarly significant effects concerning you. Colorado citizens will not be discriminated against for exercising any of their CPA rights. To make such a request, please contact us at email@example.com with the words “Colorado Privacy” in the subject line of your email, or write to us and include a heading reference with the words “Colorado Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed and/or any other information you may wish to review or requests you would like to make. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).
Your Rights Under the Virginia Consumer Data Protection Act: Virginia Law gives Virginia residents the right to access the personal data we have collected about them during the past twelve (12) months, including the categories of personal data, sources, business or commercial purpose, categories of third parties with whom we share personal data, and specific pieces of personal data we have collected about such residents. Virginia residents have the right to request the company to delete personal data we have collected, subject to certain exceptions in the VCDPA. They also have the right to opt out of our sale or sharing of their personal data and not be discriminated against for exercising any of their rights under the VCDPA. To make such a request, please contact us at firstname.lastname@example.org with the words “Virginia Privacy” in the subject line of your email, or write to us and include a heading reference with the words “Virginia Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed and/or any other information you may wish to review or requests you would like to make. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).
Your Rights Under the Connecticut Data Privacy Act: Residents of Connecticut have the right to request the specific pieces of personal data we have collected about such person in the past twelve (12) months, including the categories of personal data, sources from which the personal data was collected, purposes for collecting or selling the personal data, and third parties with whom we share personal data. Residents have the right to request the deletion of their personal data and opt out of the sale or sharing of their personal data. You will not be discriminated against for exercising your privacy rights under the CTDPA. To make such a request, please contact us at email@example.com with the words “Connecticut Privacy” in the subject line of your email, or write to us and include a heading reference with the words “Connecticut Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed and/or any other information you may wish to review or requests you would like to make. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).
Your Rights Under the Utah Consumer Privacy Act: Residents of Utah have the right to request access to their personal data, which includes information about the categories of personal data collected, sources of personal data, business or commercial purposes for collecting the personal data, categories of third parties with whom the data is shared, and specific pieces of personal data collected about them in the past twelve (12) months. Additionally, they have the right to request the deletion of their personal data and opt-out of the sale or sharing of their personal data. Exercising their privacy rights under the UCPA will not result in any discrimination against them. To make such a request, please contact us at firstname.lastname@example.org with the words “Utah Privacy” in the subject line of your email, or write to us and include a heading reference with the words “Utah Privacy”, and include in your email or letter a detailed description of the posted content or information that you would like removed and/or any other information you may wish to review or requests you would like to make. Please note that we are not required to remove content or information you have posted where it has been made anonymous, or if applicable law requires that we maintain such content or information, or if such content or information was posted by a third party registered user of the Service (including content or information that you posted that was stored, republished, or reposted by the third party).
To exercise any of these rights, or any similar rights based upon any other jurisdiction applicable to you, please contact us at email@example.com. We may ask you to verify your identity before responding to your requests.
What choices do I have?
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.
You may be able to add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
What if I have questions about this policy?
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to firstname.lastname@example.org, and we will try to resolve your concerns.
Date of Last Update: August 8, 2023