Effective Date: April 16th, 2024
Candlestick Tech, LLC (referred to in this privacy policy as “Candlestick,” “we”, “us”, or “our”) operates a SMS marketing platform that helps drive player engagement and monetization through marketing messages and other services. The “Services” include our website, currently located at https://www.candlestick.com/, the Candlestick software development kit (the “SDK”), the Candlestick marketing messages and other services, the Candlestick data platform, the technology used to provide the Services, and any related mobile applications, integrations, interfaces, features, and content.
This Privacy Policy (this “Policy”) describes the ways we collect, store, use, and disclose the information, including personal information, and data that our users (“users” or “you”) provide or we collect in connection with our Services. Additionally, this Policy describes your rights and choices concerning your information.
Please note that the scope of this Policy is limited to information and data collected or received by us through your use of the Services. We are not responsible for the actions of individuals with no relationship to us or third-party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.
If you do not want us to collect, store, use, or share your information in the ways described in this Policy, you should not use our Services.
We may collect or receive information about you by automatically collecting it during your interactions with us and/or our Services, receiving it directly from you, or receiving it from third parties including the app publishers. For example:
We collect and store any information you knowingly provide to us. For example, we collect your phone number when you sign up to use our Services within a mobile application. We create an account for you on the back end, and use the phone number you provided to verify you, provide you with customer support, and send you marketing materials which may be of interest to you via texts / SMS.
We may also collect commercial information such as in-app purchase behavior, records of services considered, consuming histories or tendencies.
When you access our Services, we may collect (i) certain technical information about your mobile device or computer system, including IP Address), mobile advertising ID (e.g., IDFA, Google Advertising ID or other identifiers), and the version of your operating system; and (ii) usage statistics about your interactions with the Services and the mobile application in which the Services are integrated. In certain Services, we will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as e-mail address. This information may be collected through the use of Candlestick or third-party mobile device SDKs. We may use this information to serve you targeted ads on participating applications. We may send you push notifications through our Services to send you App updates and other service-related notifications that may be of interest or importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.
When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your gameplay or activity on the Services, and your user name. We will also store the correspondence and any information contained within.
Our primary goals in using your information are to create your account, provide Services to you, send you marketing materials which may be of interest to you at the phone number you provided, serve you more relevant ads, troubleshoot or provide you with customer service support, improve and optimize our and our affiliates’ Services, contact you, conduct research and create reports for internal use. We use information collected through our Services for purposes described in this Policy or disclosed to you in connection with our Service. For example, we may use your information to:
We may share information we collect or derive with third parties for the following purposes:
We do not share your personal information except as approved by you or as described herein. Where we share your information with third-party service providers and business partners, we ensure that we have appropriate agreements in place to protect your information as required by applicable data protection laws.
We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage.
However, no security system is impenetrable, and we cannot guarantee the security of your personal information. Any transmission is at your own risk.
We retain your personal data for as long as needed to provide you Services, unless we are required by law to delete or if we accept your request to delete the information. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We do not knowingly collect or solicit personal data from anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. In the event that we learn that we have collected personal data from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 16, please contact us.
On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide the Services to you. We may also process your personal data to respond to your inquiries concerning our products and services.
On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.
Additionally, we process your personal data when necessary to do so for fraud prevention, improving our network and services, and marketing our services to advertisers and publishers; where these interests are not overridden by your data protection rights.
If the processing of personal data is necessary and there is no other lawful basis for such processing, we will generally ensure that consent has been obtained from you. You have the right to withdraw your consent to processing of personal data at any time.
For questions about data processing, please contact our Data Protection Officer. Visit the “Contact Us” section below for contact information.
If you are located in the European Union, Switzerland, or the United Kingdom, the following additional provisions apply to you.
On certain occasions, we process your personal data when it is necessary for the performance of a contract to which you are a party, such as to provide services to you. We may also process your personal data to respond to your inquiries concerning our products and services.
On other occasions, we process your personal data where required by law. We may also process your personal data if necessary to protect your interests or the interests of a third party.
Additionally, we process your personal data when necessary to do so for fraud prevention, improving our and our affiliates’ network and services, and marketing our services to advertisers and publishers, where these interests are not overridden by your data protection rights.
If the processing of your personal data is necessary, we will generally ensure that consent has been obtained from you if there is no other lawful basis for such processing. You have the right to withdraw your consent to processing of personal data at any time.
For questions about data processing, please contact our Data Protection Officer. Visit the “Contact Us” section below for contact information.
We do not knowingly collect personal information from children under the age of 16 through our Services. If you believe we might have any personal information from or about a child, please contact us via email at privacy@candlestick.com.
If you are an individual in the EU or UK, you are able:
To exercise these rights, please contact us at the email address set forth in the “Contact Us” section below. Our Data Protection Officer can also be reached at this email address. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.
In certain circumstances, you may appoint an authorized agent to exercise any rights that you may have on your behalf. If you choose to exercise any rights through an authorized agent, you will need to verify your identity directly with us before we can process any requests. In addition, we will need written documentation demonstrating the authorized agent’s authority to act on your behalf.
We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and the use and disclosure of information about you, including personal data, as described in this Policy.
This section applies only to individual residents (the “Covered Individual Residents”) of the U.S. states that have enacted comprehensive consumer privacy laws, including the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act (“CCPA”), the Colorado Privacy Act, the Connecticut Data Privacy Act, the Virginia Consumer Data Protection Act, the Utah Consumer Privacy Act, and each of their associated regulations, as well as similar consumer privacy laws that may be enacted in the future (collectively, the “Applicable Laws”).
The chart below summarizes the categories of personal information we collect, the sources of the personal information collected, the business purposes for our collection, and the categories of third parties with whom we “disclose” or “share” personal information.
Category of Personal Information Collected
Source(s) of Personal Information
Business Purpose(s) for Collection
Third Parties — Disclosure for a Business Purpose
Identifiers, such as telephone number, name, email address and other contact information, IP address, and online identifiers (like advertising IDs)
Sensitive Personal Information, such as social security numbers, precise geolocation, or genetic and biometric data*
Candlestick does not collect or seek to elicit end users’ “sensitive personal information” as defined by the Applicable Laws
N/A
N/A
Commercial Information, such as records of services considered or other purchasing or consuming histories or tendencies
Internet or Network Information, such as information regarding interactions with a website, application, or advertisement, or online shopping browser history
Geolocation Data, such as city or county-level geolocation information
Inferences, such as the derivation of information, data, or assumptions from the categories of personal information included above
Category of Personal Information Collected
Source(s) of Personal Information
Identifiers, such as telephone number, name, email address and other contact information, IP address, and online identifiers (like advertising IDs)
Sensitive Personal Information, such as social security numbers, precise geolocation, or genetic and biometric data*
Candlestick does not collect or seek to elicit end users’ “sensitive personal information” as defined by the Applicable Laws
Commercial Information, such as records of services considered or other purchasing or consuming histories or tendencies
Internet or Network Information, such as information regarding interactions with a website, application, or advertisement, or online shopping browser history
Geolocation Data, such as city or county-level geolocation information
Inferences, such as the derivation of information, data, or assumptions from the categories of personal information included above
Business Purpose(s) for Collection
Third Parties — Disclosure for a Business Purpose
N/A
N/A
*Candlestick does not collect or seek to elicit end users’ “sensitive personal information” as defined by the Applicable Laws. This means that Candlestick does not collect social security numbers, drivers’ licenses, financial account or credit card numbers (except as provided by our business customers to us for payment processing purposes), precise geolocation, racial and ethnic characteristics, religious and philosophical beliefs, union membership, the contents of messages (mail, email, or text), mental or physical health condition or diagnosis, sex life or sexual orientation, genetic and biometric data, or personal data from a known child.
Candlestick may “share” personal information about you, including for purposes of serving you with personalized ads or content, otherwise known as “interest-based advertising” or “cross-context behavioral advertising.” The chart included above sets forth the categories of third parties with whom we have “shared” personal information within the last 12 months.
As a Covered Individual Resident, you may be able to exercise the following rights in relation to the personal information that we may have collected about you, subject to certain limitations and requirements, including the verification of your identity and our right to retain information to comply with our legal obligations, among other circumstances.
Privacy Right
Brief Details
Know and Access your Personal Information
You may request, up to two times in a 12-month period, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information has been collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold or shared, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
Sensitive Personal Information, such as social security numbers, precise geolocation, or genetic and biometric data*
Candlestick does not collect or seek to elicit end users’ “sensitive personal information” as defined by the Applicable Laws
Request Deletion of your Personal Information
You have the right to request that we delete certain personal information that we may have collected from you.
Opt-Out of the “Sale” or “Sharing” of your Personal Information
Candlestick may “share” personal information about you, including for purposes of serving you with personalized ads or content, otherwise known as “interest-based advertising,” “targeted advertising,” or “cross-context behavioral advertising.” You have the right to opt-out of any future “sales” or “sharing” of your personal information as defined by the Applicable Laws (and as explained below).
Non-Discrimination
You have the right to exercise the rights conferred on you by the Applicable Laws without discrimination.
Data Portability
You have the right to request that we transmit certain personal information that we may have collected from you to other entities, unless transmitting the information would not be technically feasible.
Correct Inaccurate Information
You have the right to request that we correct errors or inaccurate information in the personal information that we may have collected from you.
Opt-Out of Sharing for Cross-Contextual Behavioral Advertising
To the extent Candlestick shares your personal information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising,” you have the right to opt-out of such “sharing.”
Limit the Use or Disclosure of Sensitive Personal Information
In certain circumstances, you have the right to limit the use of any sensitive categories of personal information. As noted above, Candlestick does not collect or seek to elicit sensitive categories of personal information.
Opt-Out of the Use of Automated Decision Making
In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your personal information.
To exercise your right to know, right to access, right to correct, right to delete, right to opt out of information sales or sharing, or any other right you may have under applicable law, please submit a request by emailing privacy@candlestick.com or by writing to us at the physical address in the “Contacts” section below, with the subject line “Data Privacy Rights Request” and specifying which right(s) you would like to exercise (for example, your right to delete). We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
We aim to respond to a consumer request within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
As explained in “Our Policy Regarding Children” section above, children under the age of 16 may not use the Services and we do not knowingly collect information from children under the age of 16.
Appointment of an Authorized Agent
In certain circumstances, you may appoint an authorized agent to exercise any rights that you may have on your behalf. If you choose to exercise any rights through an authorized agent, you will need to verify your identity directly with us before we can process any requests. In addition, we will need written documentation demonstrating the authorized agent’s authority to act on your behalf.
We are constantly changing and improving our Services. And we may update this Policy to reflect any changes to our data and information privacy practices. If we make any material changes we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices. Please note that if we need to adapt the policy to legal requirements, the new policy will become effective immediately or as required.
You may contact our Data Protection Officer at privacy@candlestick.com or at the address below for further information.
Data Protection Officer
Candlestick Tech, LLC
1100 Page Mill Road
Palo Alto, CA 94304
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