Last Updated: February [1], 2023
This Privacy Policy and Notice for California Residents (“Notice”) applies to all visitors and users of CyberFUN (“App”) who reside in the State of California (“consumers” or “you”). TRYFUN, PTE. LTD. (“we” or “us”) adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and California Privacy Right Act of 2020 (“CPRA”).
Personal Information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include:
(a) Publicly available information from government records.
(b) Deidentified or aggregated consumer information.
Information excluded from the CCPA’s and CPRA’s scope, such as:
(a) Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
(b) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
In particular, we may have collected the following categories of Personal Information from consumers:
Category | Examples |
Identifiers | A name, nickname, username, social media handle, profile picture, instant messaging account, account ID, device ID, device type, operating system, CPU, RAM, IP address, MAC address, email address, IP address, physical address. |
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, mailing address, and telephone number. Some Personal Information included in this category may overlap with other categories. |
Protected classification characteristics under California or federal law | Age (date of birth), gender (gender expression or gender identity), sexual orientation. |
Commercial information | Goods or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
Internet or other similar network activity | Browsing history, search history, or any information on a consumer's interaction with the App, or advertisement or service. |
Geolocation data | Physical location, IP address, device shared location. |
Electronic information | Information you provide directly or through your interactions with our Services (device type, network data, operating system, date and time stamp of actions) and interactions with other users. |
Inferences drawn from other Personal Information | Profile reflecting a person’s preferences. |
We will not collect information associated with your telephone number or government-issued ID without first obtaining your consent.
We may collect the categories of Personal Information listed above from the following categories of sources:
Directly from you.
Indirectly from you – for example, from your actions on our App.
From service providers and/or third parties, including telecommunication service providers, payment and auditing processors, and social media service providers.
From government agencies and public authorities.
From our affiliate entities.
We may use or disclose the Personal Information we collect for one or more of the following business purposes:
To set up user accounts and provide services to the users.
To promote our goods and services.
To create, maintain, customize, and secure your account with us.
To personalize your experience with our goods and services, and to deliver contents or offerings relevant to your interests.
To help maintain the safety, security, and integrity of our App, goods and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our App, goods and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To enforce our terms and conditions, policies, rules and standards.
To work with third parties and service providers to evaluate their marketing services.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users is among the assets transferred.
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.
We may disclose the following categories of Personal Information to the following categories of persons or entities:
Category of Information | Categories of Persons or Entities to Whom the Information Was Disclosed |
Identifiers |
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
|
Protected classification characteristics under California or federal law |
|
Internet or other similar network activity |
|
Geolocation data |
|
Electronic information |
|
Inferences drawn from other Personal Information |
|
We do not sell any of your Personal Information.
We may offer nominal in-App points and rewards to users when they choose to provide certain information or generate certain information. We may use the information collected to serve the user with more relevant promotional materials, and the value of a user's aforesaid information to us is reasonably related to the value of the corresponding in-App points and rewards. Users can withdraw from this incentive at any time by requesting deletion of the collected information, as provided below.
The CCPA and CPRA provide you with certain rights regarding your Personal Information in certain circumstances and subject to certain exceptions. This section describes your CCPA and CPRA rights and explains how to exercise those rights.
You may have the right to request that we disclose to you certain information about our collection and use of your Personal Information over the preceding twelve months. Once we receive and confirm a verifiable consumer request, we will disclose to you the following information responsive to your request:
The categories of Personal Information we collected about you.
The categories of sources from which the Personal Information was collected.
The categories of third parties to whom the Personal Information was disclosed for a business purpose.
The specific pieces of Personal Information we have collected about you.
Our business or commercial purposes for collecting that Personal Information.
If we disclosed your Personal Information for a business purpose, we will list such disclosures, identifying the Personal Information categories that each category of recipient obtained.
You may have the right to request that we delete any of your Personal Information that we collected from you and retained. Once we receive and confirm a verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny a deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which the Personal Information was collected; provide a good or service requested by the California Consumer or reasonably anticipated within the context of a business's ongoing business relationship with the California Consumer or otherwise perform a contract between the business and the California Consumer.
Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
Debug to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses' deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
To enable solely-internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the business.
Comply with a legal obligation.
Otherwise use the California Consumer's Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
To exercise the right to know and the right to request deletion, please submit a verifiable consumer request to us by either emailing us at privacy@tryfun.com or contacting the in-App customer service.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information.
We are required to respond to your verifiable consumer request no more than twice in a 12-month period. The verifiable consumer request must:
(a) Provide sufficient information—for example, your name, address, or other information depending on the type of request and the sensitivity of the information requested—that allows us to reasonably verify that you are the person about whom we collected Personal Information or an authorized representative; and
(b) Contain sufficient detail such that we are able to properly understand, evaluate, and respond to it.
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 cannot confirm that the Personal Information belongs 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.
We will respond to a verifiable consumer request within 45 days of its receipt when possible. If we require more time (up to 45 additional days), we will inform you in writing, within 45 days of receipt of the original request, of the extension period and the reason for the extension.
Any disclosures will cover only 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. We will deliver information by mail or electronically, at your election, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, readily-useable format that allows you to transmit the information to another entity without hindrance.
We do not charge a fee to respond or process your verifiable consumer request unless it is manifestly unfounded, excessive, or repetitive. In such a case, we may charge a reasonable fee or refuse to act on the request, but we will inform you of the reasons for that decision and provide you with a cost estimate before completing the request.
We will not discriminate against you because you have exercised any of your rights under the CCPA and CPRA, including, but not limited to, by:
Denying goods or services to you;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing a different level or quality of goods or services to you; or
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
If you have any questions or comments about this Notice, the ways in which we collect and use your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either emailing us at privacy@tryfun.com or contacting the in-App customer service.