SPIRALBURST STUDIO
PRIVACY POLICY

Last Modified on October 26, 2021

Please read this privacy policy carefully, as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities if you have a complaint.

1. Who we are

Spiralburst Studio, LLC (“Spiralburst,” “We,” or “Us”) collects, uses, and is responsible for certain personal information about you, as part the “Hexicon: Strategy Word Game” and “Maracaibo Digital” games and the Spiralburst Studio websites located at https://spiralburst.com/, https://maracaiboapp.com/, and https://hexiconapp.com/ (collectively, the “Service”).

For those in the European Union, we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.

2. The Personal Information we collect and use

Information collected by us: In providing the Service, we collect the following personal information either automatically or when you voluntarily provide it to us:

How we use your Personal Information: We use your personal information as follows:

Who we share your Personal Information with: We share your Personal Information with certain third parties as part of our operation of the Service. This data sharing enables us to provide you with the Service in the optimal way.

Some of those third-party recipients may be based outside the European Economic Area — for further information, including how we safeguard your personal data when this occurs, see their individual privacy policies linked to above and the section entitled “Transfer of your Information out of the EEA,” below.

We share your Personal Information with the following third parties:

How long your Personal Information will be kept: We will keep your Personal Information for the length of time required to provide you with the Service, unless a longer retention period is required or permitted by law. Afterwards, we delete all aforementioned data in our possession within a reasonable timeframe. We do not verify the correctness of personal data that we collect or you provide.

Please note that some data may be retained, if necessary to resolve disputes, enforce Spiralburst user agreements, and comply with technical and legal requirements and constraints related to the security, integrity, and operation of the Service.

Children’s Privacy: We do not knowingly collect any personal information from children under the age of 13, nor do we allow them to create accounts, sign up for newsletters, make purchases, or browse the Service. In addition, we may limit how we collect, use, and store some of the information of EU users between 13 and 16. Spiralburst takes children’s privacy seriously and encourages parents to play an active role in their children’s online experience at all times. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you have any concerns about your child’s personal information, please contact us at support@spiralburst.com.

“Do Not Track” Signals: Because there’s not yet a consensus on how companies should respond to web browser-based or other “do not track” mechanisms yet, we do not respond to web browser-based do not track signals.

Mobile Advertising Opt-Out: If you would like more information about online advertising and your choices about not having personal information used to personalize ads for you, please see the links below. Only for Hexicon.:

3. Transfer of your Information out of the EEA

Spiralburst is based in the United States. No matter where you are located, you consent to the processing, transfer and storage of your information in and to the U.S., as well as Canada, Brazil, Switzerland, UK, India, Australia, Hong Kong, Japan, and Korea, in accordance with the privacy policies of third parties with whom we share your Personal Information. The laws of the U.S. and these other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live.

If you would like further information, please contact us (see “How to contact us” below).

4. EU Residents - Your Rights

Under the laws of some jurisdictions, including the General Data Protection Regulation in the EEA, you have a number of important rights with regard to your Personal Information.

If you would like to exercise any of those rights, please email us at support@spiralburst.com. We may ask for additional verification information, such as your username and other information required to be sure that you are the owner of that data.

5. California Residents – Your Rights

If you are a California resident, beginning on January 1, 2020, the California Consumer Privacy Act (CCPA) gives you the following rights:

Right to Know: You can ask us what personal data we hold about you and request a copy of the information. This information includes:

Right to Delete: You can request that your personal information be erased. However, there are some exceptions to this right, in situations where we:

Right to Opt Out: Spiralburst does not sell any of your personal information for any purposes.

Other Rights: In addition to the rights above, you also have the right to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the calendar year preceding your request. This request is free and may be made only once a year.

You also have the right not to be discriminated against for exercising any of the rights of California residents listed in this section.

If you would like to exercise any of the rights listed above, please contact us at the addresses below in the section entitled “How to contact us.”

6. Keeping your Personal Information secure

We have taken steps to put appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way.

For example, we limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner.

Additionally, we use role-based access controls, encryption of data in transit and at rest, and regular backups to protect personal information we collect and process.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

7. Resolving Disputes

We hope that we can resolve any questions or concern you raise about our use of your Personal Information. Please contact us via the methods listed below in the section entitled “How to contact us” to let us know about any of your questions or concerns, and we will get back to you to resolve the issue.

If you are an EU citizen, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

8. Changes to this Privacy Notice

This privacy notice was last updated on October 26th, 2021.

We may change this privacy notice from time to time. When we do, we will inform you via email to the email address you have provided us with through your account, or by posting a message about the change on the Service.

9. How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, you can do so by email to support@spiralburst.com or by postal mail to 144 Pius St., Pittsburgh, PA 15203.