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Privacy Policy
Effective as of March 19, 2023

This Privacy Policy for Sunflower Ltd. (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s platform, the various games available on the website (“Games”), services, tools and features (collectively, the “Services”).  For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Services. 

 

Please read this Privacy Policy carefully.  By using, accessing, or downloading any of the services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy.  If you do not agree to this Privacy Policy, you may not use, access, or download any of the Services.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law.  If you do not agree to any updates to this Privacy Policy please do not access or continue to use the services.

2. COMPANY’S COLLECTION AND USE OF INFORMATION

When you access or use the Services, we may collect certain categories of information about you from a variety of sources. 

 

Some features of the Services may require you to directly enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services may include:

 

  1. Account and Registration. Users may access our Games only if they register an Account with us. The personal information we collect as part of the Account creation process includes your first and last name, email, username, password, information to confirm you are old enough to use the Services and use the Games, payment information for any purchases (for example, your name and email associated with your payment account). We may also ask you or allow you to submit certain optional information, which may include your updated usernames, preferences, and other profile information.

  2. Prizes and Payments. We collect information to process prize winnings, administer payments, comply with the law (including requiring W9 tax forms when necessary), and maintain records of prizes, which may include your email, full name, mailing address, Social Security or Taxpayer ID number, and other information necessary to complete a 1099-MISC tax reporting form, and other relevant tax documentation.

  3. Feedback. We collect and maintain records of customer service and other communications with users including survey responses, questions or comments sent to us (including the nature of the nature of the request, name and contact information), resumes provided, or other similar activities. This information may be used to enhance the Services or the Games, to market to you or others, and to allow us to make appropriate hiring decisions if submitted for that purpose.

  4. Usage Data. We automatically collect information about your use of our Services and the Games through cookies, local storage, analytics tools and other technologies, (“Tracking Technologies”) such as your device ID, location information, device name and model, operating system type, name and version, the length of time that you are using our Services and your activities within our Services (“Usage Data”). We may combine Usage Data with other information that we have collected about you. Please see the section “Analytics and Tracking” below for more information.

  5. Interactions and Activities. We collect information about your activities in the Games, such as coin activity, which games you played, time spend in the Games and other factors. We may collect your geolocation information for purposes of using the Games, and for our own due diligence and verification purposes. 

We may use the information we collect automatically to tailor features and content to you, to market to you, to provide you with offers or promotions, to run analytics and better understand user interaction with the Services.

 

We may obtain information about you from outside sources. Such information may include:

 

  • Information from third parties that you choose to share with us, for example:

    • When you choose to link any social media platforms to your account, such as Facebook or Twitter. This information is used to maintain your account and login information.

 

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. See Section 5 below for more information.

 

In addition to the foregoing, we may use any of the above information to comply with any applicable legal obligations, improve and develop the Services and our product offerings, including as we describe in our Terms of Service, to enforce any applicable terms of service, to protect or defend the Services, our rights, and the rights of our users or others, and for the purpose of combatting fraud, or to otherwise operate our business. This Privacy Policy is integrated into and is expressly a part of the Terms of Service, to be interpreted in conjunction with such Terms.

3. HOW THE COMPANY SHARES YOUR INFORMATION

In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include: 

 

  • With vendors or other service providers, such as cloud storage providers, security vendors, data analytics vendors, and payment processors

  • With our affiliates or otherwise within our corporate group

  • With third parties for marketing purposes; 

  • When you request that we share certain information with third parties, such as through your use of social media widgets, login integrations, or interactions with other users on the Platform.

  • To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries

  • In connection with an asset sale, merger, bankruptcy, or other business transaction

  • To enforce our Terms of Service

  • To ensure the safety and security of the Company and/or its users

  • When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations

  •  With professional advisors, such as auditors, law firms, or accounting firms

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

Do Not Track Signals

 

Your browser settings may allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, the Website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com

 

Cookies and Other Tracking Technologies

 

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services to work incorrectly or not function at all. 

 

5. THIRD PARTY WEBSITES AND LINKS

We may provide links to third-party websites or other online platforms operated by third parties. If you follow links to sites or interact with features (e.g., applications offered by third parties or social media widgets) not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions.  We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services. 

6. DATA SECURITY

Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Please further note that any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. 

7. European and California Users. 

A. If you are a citizen of the European Union (“EU”) or the state of California, you may have some or all of the following rights with respect to our processing of your personal data:

  1. Updating Your Information. If you would like to update personal information that you have provided to us, you can do so by accessing your Account and editing your profile.

  2. Marketing Communications. You can opt-out of receiving marketing communications from us by clicking “unsubscribe” in any marketing email communications we send you, or by sending an email to support@sunfltd.com If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.

  3. Additional Rights for the EEA and Certain Other Territories. If you reside in certain territories (such as the European Economic Area), you may have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with the GDPR. We may need to retain certain information for record-keeping purposes, legal purposes, and/or to complete transactions that you began prior to requesting any deletion. You can contact our Data Privacy and Protection office by sending an email to support@sunfltd.com

  4. Right Not to Provide Consent or to Withdraw Consent. We may seek to rely on your consent in order to process certain personal information and to render the Services. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect any actions based on consent before its withdrawal.

  5. Right of Access. You may have the right to access the personal information that we hold about you.

  6. Right of Erasure. In certain circumstances, you may have the right to the erasure of personal information that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).

  7. Right to Object to Processing. You may have the right to request that westop processing your personal information and/or to stop sending you marketing communications.

  8. Right to Correct. You may have the right to require us to correct any inaccurate or incomplete personal information.

  9. Right to Restrict Processing. You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is not accurate or lawfully held).

  10. Exercise of Rights. If you would like to exercise any of the above rights, please contact support@sunfltd.com so that we may consider your request under applicable law. To protect your privacy and security, we may take steps to verify your identity before complying with the request. You also have the right to lodge a complaint to your local data protection authority at: https://edpb.europa.eu/about-edpb/board/members_en

8. YOUR CHOICES

We may send periodic informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about any Services you have requested or received from us.

9. CALIFORNIA PRIVACY RIGHTS ADDENDUM

A. This CALIFORNIA PRIVACY NOTICE (“Notice”) IS FOR CALIFORNIA RESIDENTS and supplements our Privacy Policy. We have adopted this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). 

B. Information We Collect. We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we collect: 

 

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C. We obtain the categories of personal information listed above from the following categories of sources: 

1. Directly from our Users. For example, from when Users register for our services.

2. Directly and indirectly from activity on our websites and applications. This includes:

  • Usage and log information. For example, service-related, diagnostic and performance information. This includes information about your activity on our websites and applications, log files and reports.

  • Device and connection information. We collect device-specific information such as hardware model, operating system information, browser information, IP address etc. 

3. From third parties that interact with us in connection with the services we perform. We may work with third parties, for example, in order to understand, customize, support and market the services we provide and/or to comply with laws.

4. Use of Personal Information. We may use or disclose the personal information we  collect for one or more of the following business purposes as disclosed in our  Privacy  Policy: 

  • To provide and manage the services you request;

  • To improve customer service and our services;

  • To process payments; 

  • To personalize user experience;

  • To contact you about our services; 

  • To send important notices to you; 

  • To comply with our legal and regulatory obligations;

  • To offer alternative dispute resolution services .

 

5. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

6. Sharing Personal Information. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the contract. We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates;

  • Service providers;

  • Third parties that interact with us in connection with the services we perform. 

We do not sell your personal information, and never will. 

7. Your Rights and Choices. The CCPA provides players who are California residents with specific rights regarding their personal information. You have the right to access the personal information we’ve collected about you during the past 12 months and information about our data practice. You also have the right to request that we delete the personal information we have collected from you. Exercising Access and Deletion Rights To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us as set forth below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you decide to use an authorized agent, please also include written permission that you have designated that agent to make this request, or proof of the agent’s power of attorney. We may follow up with you to verify your identity before processing your authorized agent’s request. You may also make a verifiable consumer request on behalf of your minor child. In order for your consumer request to be verifiable, you must: • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. You will need to provide: (1) full name (2) date of birth (3) address (4) email address (5) whether you are a California consumer pursuant to CCPA (6) if you would like to know the specific pieces of personal information that we have collected about you, or to delete your personal information; (7)  identification that clearly shows your name, date of birth and address (for example, passport or other photo identification); (8) describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. 

8. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

9. Response Timing and Format We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

10. We will not discriminate against you for exercising any of your CCPA rights.

11. This Notice may be updated from time to time to reflect changes in the way we work or the way our work is regulated. We will notify you of changes by posting changes here, or by other appropriate means. 

10. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at support@sunfltd.com or contact us at [PHYSICAL MAILING ADDRESS and/or TELEPHONE NUMBER]. Contacts will be routed to our designated Data Privacy Protection Officer, as may be appropriate. 

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