Chumba Solitaire Lite Privacy Policy
Version: 1.0
Date updated: March 25th , 2024
At VGW, we are committed to maintaining transparency and protecting the privacy of our players.
VGW operates the Chumba Solitaire Lite app that is available through the Apple App Store, Google Play on
mobile devices, and any subdomains, subpages, successor sites or any application accessible via our
website or app (the “App”).
At VGW, we are committed to protecting and respecting your privacy and maintaining the confidence and
trust of our players. This privacy policy (“Privacy Policy”) explains how VGW collects, uses, maintains and
shares information collected from the App.
We are committed to complying with obligations under all applicable North American data privacy laws,
including, but not limited to, the California Consumer Privacy Act (including the California Privacy Rights
Act), the Colorado Privacy Act, the Florida Digital Bill of Rights, the Oregon Consumer Privacy Act, the
Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, the Virginia Consumer Data
Protection Act, and the Canadian Personal Information Protection and Electronic Documents Act (and any
provincial substantially similar law as applicable).
1. DEFINITIONS
Aggregate Information means information about groups or categories of players, which does not identify and
cannot reasonably be used to identify an individual player.
Anonymous Information means information that does not directly or indirectly identify, and cannot reasonably
be used to identify, an individual. When anonymous information is directly or indirectly associated with personal
information, the resulting information is also treated as Personal Information.
Personal Information means any information about you, whether it is true or not, that can reasonably be used
to identify you, or otherwise make you identifiable.
VGW (including “VGW Holdings Limited”, “VGW Malta Limited”, “VGW Group”, “We”, “Us” or “Our”) means
VGW Holdings Limited and any applicable subsidiaries, including VGW Malta Limited, VGW GP Limited, VGW
Games Limited, VGW Administration Malta Limited, VGW US, Inc., VGW Luckyland Inc., VGW Holdings US Inc.,
and VGW Canada Inc., that forms the VGW Group and may collect, use, maintain and disclose information
collected from the App as applies to this Privacy Policy.
2. DATA CONTROLLER
The data controller responsible for processing data collected through your use of the App (including any data you
may provide through the App) is VGW Malta Limited having its registered address at Trident Park, Notabile
Gardens, No6 – Level 3, Central Business District, Mdina Road, Zone 2 Birkirkara CBD2010 Malta (the “Data
Controller”).
3. TYPE OF INFORMATION WE COLLECT
3.1. We collect three types of information (as defined in section 1, Definitions):
● Personal Information
● Anonymous Information
● Aggregated Information
Any other information that we receive and identify as your Personal Information will be treated as Personal
Information by VGW.
3.2. The types of Information we may process depends on the business context and the purposes for which it
was collected. It may include:
Personal Information, such as your first name and surname, email address, and mobile phone number.
Geolocation Information, including approximate location information provided by a mobile or other device
interacting with the App, or associated with your IP address, where we are permitted by law to process this
information.
Usage Data, which may include activity, technical and device information about your use of the App, such
as the content you view, the time and duration of your visit on the App, how often you use our services,
how you first heard about our App, your preferences and information about your interaction with the
content offered through the App, your hardware model, device type, other unique device identifiers,
operating system version, browser type and IP address, as well as information sent bilaterally or within a
small group using text message, live chat, post or other similar methods of communication.
Information we obtain from a third-party, such as a site or platform provider (including Apple, APK and
Google), about your use of or interest in our services.
4. HOW WE COLLECT YOUR INFORMATION
4.1. INFORMATION YOU PROVIDE TO US DIRECTLY
This includes information collected when you visit our mobile app, website, register, respond to a survey,
fill out a form, and in connection with other activities, services, features, or resources we make available
on our App.
We collect information from you by telephone, video or in correspondence (including email, live chat, mail,
text message or social media). All telephone or video calls between you and VGW Group representatives
may be recorded for training, quality control and compliance purposes and by continuing with any such call
you consent to it being recorded.
4.2. INFORMATION WE COLLECT AS YOU USE OUR SERVICES
We also collect information about your use of our products and services through a variety of technologies
that are present when you visit the App or use our applications on third-party sites or platforms (whether or
not you are logged in or registered) including tags and application program interfaces (“API”) (further
information is set out in section 5, Personal Information Collected via Technology). Analytics tools are
also used by us to collect information, including when you visit the App or use our applications or services
on third-party sites or platforms.
5. PERSONAL INFORMATION COLLECTED VIA TECHNOLOGY
5.1 We and our service providers and data processors use industry standard identifiers to provide an
enhanced experience.
5.2 These technologies allow us to record certain pieces of information whenever you visit or interact with the
App. Information may include, in part, browser type, operating system, device type, an estimate of your
geographic location associated with your IP address, the location of your mobile device, the page served,
the time, referring URLs and other information normally transmitted in HTTP requests.
5.3 This statistical data provides us with information about your use of the services, such as general
engagement with a page, the type of content on that page and how long you stay on that page. Usage
Data is generally non-identifying but if VGW associates it with you as a specific and identifiable person,
VGW will treat it as Personal Information (including in relation to any unique identifiers).
5.4 The following are examples of these types of technologies:
a) APIs. APIs work by allowing different types of software to communicate with each other. They make
life a lot easier for programmers and provide a better experience for end users.
b) Mobile device identifiers. When you download or access our products via a mobile device, we and
our service providers and data processors may receive information about your geolocation (based
on your IP address) and your mobile device including advertising identifiers, hardware type, your
operating system and your in-game activity. We may share the advertising identifier associated with
your mobile device or tablet (such as the Apple IDFA and Google Advertising ID) with advertisers.
We and our service providers and data processors may use this information to provide you with
tailored advertising and other content. When you download or access our games through your
mobile device, we may ask permission to track your activity. If you initially consent to tracking, you
may later disable that permission in your device settings or withdraw your consent. In addition, if
you do not want to receive third-party tailored advertisements, you may opt-out by adjusting the ad
tracking settings on your device (such as turning on “Limit Ad Tracking”) and reset the advertising
identifier on your device. Further, depending on your platform provider (such as Apple or Google),
you may be able to download apps such as the Digital Advertising Alliance’s “AppChoices” app to
provide you with control regarding the collection and use of your cross-app data for tailored
advertising. For more information on the advertising choice mechanisms, visit the NAI’s Mobile
Choices page here.
c) Event tagging. Event tagging allows us to track actions that occur in the App such as application
installs. By tracking these events we can view analytics, measure ad performance, and build
audiences for ad targeting.
6. HOW WE USE COLLECTED INFORMATION
6.1. The Data Controller is responsible for and may use your information for the purposes described in
this Privacy Policy. Other members of the VGW Group may access your information where they act
on behalf of the Data Controller as a data processor for the purposes described in the Privacy Policy.
6.2. We use the information collected to operate the App and to provide our products and services, to
respond to your questions and to fulfil all applicable regulatory requirements.
6.3. There may be occasions where we collect and use your information for the following specific
purposes:
To improve our
services
Information you provide helps us respond to your service requests more
efficiently; we may use feedback you provide to improve our products
and services.
To personalize user
experience
We may use information which has been aggregated to understand how
our users as a group use the services and resources provided on the
App.
To contact you about
our services including
marketing
We may contact you by email, live chat, telephone, text message, mail
or social media for communications related to your use of our services
and products, including in connection with your accounts, offers and
information about our products and services, promotions and
competitions you choose to enter, online surveys, new features that you
are entitled to access, and other important information. Please see
section 8, Your Privacy Rights, for your opt out rights.
To send important
notices to you
From time to time, we may send important notices to you, such as legal
notices regarding the changes to our terms and conditions or other
policies. This information is important to your interactions with us, and
you acknowledge that you may not opt-out of receiving these
communications.
To comply with our
legal and regulatory
obligations
We may use information we collect about you to assess your social
gameplay activity for responsible social gaming purposes, or to comply
with any other legal or regulatory obligations (including the detection,
investigation and prevention of activity that violates our Terms and
Conditions or that may be illegal).
To offer alternative
dispute resolution
services
We may provide information we collect about you to our service
provider for the specific purpose of resolving any disputes that have not
been satisfactorily resolved through our internal processes.
To conduct market
research and analysis
We may use information we collect about you to analyze how you
interact with our products and services, to monitor and analyze usage
and activity trends (including Usage Data), and for other research,
analytical and statistical purposes.
6.4. BEHAVIORAL ADVERTISING
We may partner with a third-party service provider to: (a) display advertising on the App or any application
or website accessible via the App; and (b) manage our advertising on other websites to help us provide
more relevant advertisements.
Under some US state privacy laws, consumers have the right to opt out of the sharing or sale of their
Personal Information with third parties for targeted advertising (also known as behavioral advertising).
“Behavioral advertising” in this context means advertisements that may be sent to you based on your data
through the use of technologies to gather information about your activities on the App and other
applications and websites.
Certain types of your Personal Information may be collected when you use our Website and services, such
as your email, your IP address of your device, any unique identifier attributed to you or your device, or
cookies stored on your device, which may be combined with other information we or our third-party service
providers have to provide interest based or targeted advertising and content. This information may also be
used by our advertising partners and social media platforms to combine it with other information they have
about you obtained through other sources or through your relationship with them.
If you wish to opt-out of interest-based advertising click here (or if located in Canada click here). Please
note you will continue to receive generic advertisements.
7. HOW WE SHARE INFORMATION
7.1. The following categories of data may be shared for behavioral advertising purposes:
a) Name, mobile device identifier and contact data; and
b) Interactions.
7.2. The above data may be shared with third parties that perform online advertising services for VGW
for the purposes of delivering tailored advertising based on your interests.
7.3. If you do not want to receive third-party tailored ads, you may opt-out by adjusting the ad tracking
settings on your device (such as turning on “Limit Ad Tracking”). You can also reset the advertising
identifier (like an IDFA) from your device’s settings, which will prevent continued use of existing
behavioral data tied to the previous advertising identifier. Depending on your platform provider (such
as Apple or Google), you may be able to download apps such as the Digital Advertising Alliance’s
“AppChoices” app, that offers to provide you with control regarding the collection and use of
cross-app data for tailored advertising. These opt-out tools are provided by third parties, not VGW.
VGW does not control or operate these tools or the choices that advertisers and others provide
through these tools.
8. YOUR PRIVACY RIGHTS
8.1. We appreciate that by law and subject to certain conditions, you have a number of rights concerning
the Personal Information we hold about you. Further information and advice about your rights can be
obtained from the data protection regulator in your country or state.
8.2. Your rights may include, but are not limited to, the following:
The right to access
You have the right to access your Personal Information we
process, and certain other information (similar to that provided in
this Privacy Policy).
The right to rectification or
correction
You are entitled to your Personal Information corrected if it is
inaccurate or incomplete. You can request that we rectify any
errors in information that we hold about you.
The right to be informed
You have the right to know how we collect and use your
information and your rights regarding your Personal Information.
The right to object to
processing
You have the right to object to certain types of processing,
including processing for direct marketing and advertising.
The right to delete
You have the right to request the deletion or removal of your
Personal Information subject to certain exceptions. Please refer to
section 8.5, How to access or delete your information, for more
details.
The right to data portability
With certain exceptions, you have the right to obtain and reuse
your information in an easily understandable format. Please refer
to section 8.5, How to access or delete your information, for
more details.
The right to opt-out of
sharing
You have the right to opt out of the sharing of your Personal
Information to a third party for cross-context behavioral advertising.
The right to complain to a
supervisory authority
You also have the right to complain to the relevant data protection
supervisory authority about VGW’s processing of your Personal
Information. Please complete the Chumba Privacy Request Form
here or alternatively, email dataprivacy@vgw.co.
8.3. ADDITIONAL RIGHTS TO US RESIDENTS
Residents of California have the right to: (1) request to know more about the categories and specific
pieces of Personal Information we collect, use and disclose; (2) request deletion of your Personal
Information; (3) opt out of sale of your Personal Information (if any); (4) not be discriminated against for
exercising these rights; and (5) limit use of your sensitive Personal Information if we use such Personal
Information to infer characteristics about you. We do not currently use sensitive Personal Information for
such purposes. In some states, we may be required to obtain your consent before collecting your
sensitive Personal Information.
Under some US state privacy laws, consumers have the right to opt out of the sharing or sale of their
Personal Information with third parties for targeted advertising (behavioral advertising). Please refer to
section 6.4 above for more details.
If you want to stop receiving promotional communications from us, you can click on the “unsubscribe” link
in any promotional email received from us.
8.4. HOW TO EXERCISE YOUR RIGHTS
You can exercise any of these rights by completing the Chumba Privacy Request Form here or
alternatively, email dataprivacy@vgw.co. We will not discriminate against you (e.g., through denying
products and services or providing a different level of quality of goods or services) for exercising any of the
rights afforded to you.
You may opt-out of receiving commercial messages from us by following the instructions contained in
those messages or by contacting Customer Support. In the event of your objection to processing for the
purpose of direct advertising, we will no longer process your Personal Information for these purposes.
If you would like to use an agent authorized in accordance with applicable law to exercise your rights, we
may request evidence that you have provided such agent with power of attorney or that the agent
otherwise has valid written authority to exercise those rights on your behalf.
8.5. HOW TO ACCESS OR DELETE YOUR INFORMATION
You have the right to view, manage, download and delete your information under the applicable privacy
laws, as set out in further detail in the table below. To exercise your rights, please submit the Chumba
Privacy Request Form here or contact dataprivacy@vgw.co.
Access your
information
You can access the following information from your use of our App and/or
interactions with VGW:
(a) Your activity within our App, including any games you’ve played.
(b) Personal Information that you’ve provided when you set up your
account in the App.
(c) Logged information that is logged from your activity in the App,
including things such as your location and game play history.
(d) Security and login information related to your account.
(e) Apps and websites from service providers and data processors
through your use of the App.
(f) Information related to your activity with advertisements that interact
with our App.
Download your
information
You are able to download your information from your use of our App,
including your activity and things that we collect. You will first need to
choose the information that you want to download and when the files are
ready, you can download them to your device. If you require your data
logs, a request will need to be made to the Chumba Privacy Request
Form either here or by email to dataprivacy@vgw.co, and this request
may take up to 30 days’ to process. Data logs are additional details we
collect and store that can be associated with you. This data can be
unique but it can also be additional details about information provided in
your account, such as the things you’ve viewed or clicked on.
Delete your
information
You can permanently delete your information, including your activity,
unless we need to keep it as described in section 10, How Long Will We
Retain Your Information For by making a request to the Chumba
Privacy Request Form either here or by email to dataprivacy@vgw.co. If
you request that we delete your information, it may take up to 30 days to
delete your information. We may retain Personal Information that has
been de-identified or aggregated. We may retain information necessary
for us or our service providers and data processors to comply with certain
legal and regulatory obligations.
Once we receive your request, we may verify it by requesting information sufficient to confirm your identity.
In some jurisdictions you are able to use an authorized agent to exercise your rights; we may request
evidence that you have provided such agent with a power of attorney or that the agent has valid written
authority to exercise your rights on your behalf.
9. HOW WE PROTECT YOUR INFORMATION
9.1. We use physical, electronic, and operational procedures to protect the information we gather. We
follow appropriate practices for collecting, storing and handling data, along with security measures to
prevent unauthorized access, changes, exposure or loss of your Personal Information. We regularly
review and update our security measures to stay current with technological advances.
9.2. If we believe that a notifiable data breach has occurred, we will comply with the legislative
requirements to notify you of the data breach and any steps taken by VGW to contain and
investigate the data breach.
10. HOW LONG WILL WE RETAIN YOUR INFORMATION
10.1. We will retain the categories of Personal Information listed in section 3 above for various periods of
time to reasonably fulfil the purposes specified in this Privacy Policy which will be determined based
on (1) the length of time we need to retain the information to achieve the business or commercial
purpose for which it was obtained; (2) any legal, accounting, reporting or regulatory requirements
applicable to such information; (3) internal operational needs; and (4) any need for the information
based on any actual or anticipated investigation, dispute or litigation.
10.2. We will take reasonable steps to destroy or permanently de-identify any Personal Information where:
a) we no longer need the Personal Information for any purpose for which the Personal
Information was collected; and
b) we are not required by law, a regulator or a court/tribunal order, to retain the Personal
Information.
11. SHARING YOUR INFORMATION
11.1. We share your Personal Information with the following categories of third parties:
a) Affiliates – other companies in the VGW Group;
b) Service providers and data processors – other companies who provide services to you on our
behalf or process your data on our behalf; and
c) Third parties that interact with us in connection with the services we perform.
11.2. If we share your Personal Information with a third party, we will take reasonable steps to ensure your
information is protected to the same standards as we protect our own and prohibit them from using
your Personal Information for purposes other than those requested by us or required by law.
11.3. WITH THIRD PARTIES
We only share information with third parties in limited circumstances including the following:
a) when you allow us to share your information with third parties;
b) when providing you with products and services and notifying you about important changes or
developments to the features and operation of those products and services;
c) with our service providers to enable us to offer our services, such as companies that help us
with things like technology, storing and combining data, processing payments, or providing
relevant marketing and advertising for our products and services. Where service providers use
Personal Information for their own purposes, where permitted by law, such service providers
will act as the data controller of that data;
d) in response to lawful requests by public authorities, including to meet national security or law
enforcement requirements, when ordered to do so by any regulatory body and/or under any
legal provision contained in the governing law of a particular jurisdiction;
e) to enforce our terms and conditions set out in our App, to protect our rights and property and
the rights and property of our players and third parties; and
f) when performing web analytics to analyze traffic and player activity.
OTHER THIRD PARTIES
11.4. We may also share generic aggregated demographic information not linked to any personal
identification information regarding visitors and users of our App with our service providers, affiliates
and advertisers for the purposes outlined above.
11.5. TRANSFERS OF DATA
The VGW Group operates in several international jurisdictions and Personal Information we collect may be
transferred to, and stored and processed by, affiliates within the VGW Group or service providers in the
European Union, the United States, Canada, Australia, the Philippines or any other country in which we or
our service providers maintain facilities. We will ensure that transfers of Personal Information to any
country or organization are subject to appropriate safeguards. Additionally, without limitation and where
applicable, when transferring Personal Information from the European Union, we may use standard
contractual clauses approved by the European Commission or otherwise in accordance with European
protection laws for ensuring adequate safeguards.
12. MINORS
12.1. Protecting the privacy of children is especially important to VGW. For that reason, we never
knowingly collect or maintain information from individuals under the age of 18, and no part of the
App is structured to attract anyone under the age of 18. VGW does not offer or direct any of its
services or products, including the App, to individuals under the age of 18.
13. Do-Not-Track Signals and Similar Mechanisms
13.1. Some browsers may transmit “do-not-track” signals to the websites and/or apps with which the user
communicates. Due to the different ways that browsers incorporate and activate this feature, it is not
always clear whether users intend for these signals to be transmitted, or whether they are even
aware of them. As there is currently no industry standard concerning what, if anything, websites
and/or apps should do when they receive such signals, the Chumba Solitaire App currently does not
take action in response to these signals. If and when a final standard is established and accepted,
we will reassess how to respond to these signals.
14. CHANGES TO THIS PRIVACY POLICY
14.1. This Privacy Policy 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 material changes and, where required by law, will
obtain your consent. Notice may consist of posting such changes on the App or by other means in
accordance with applicable laws.
14.2. Any changes to the Privacy Policy will become effective when the updated policy is posted on the
App and/or Website.
14.3. We encourage you to frequently check for any changes to stay informed about how we are helping
to protect the Personal Information we collect.
14.4. This Privacy Policy, in effect as of the last modified date stated at the top of the document,
supersedes and replaces any and all Privacy Policies previously in effect.
15. CONTACTING US
If you have specific questions regarding your Personal Information, how we process or use it, or to
exercise your rights, please contact our Privacy Team directly by email at dataprivacy@vgw.co or
alternatively please complete the Privacy Request Form here.
