Privacy Policy


Last Updated:  February 5, 2020

Sugar Loaf® Games Privacy Policy

Summary

Thank you for visiting the Sugar Loaf Games website located at www.Sugar Loaf Games.com (the “Site”). The Site is owned and operated by Digital Claw, LLC (“Sugar Loaf® Games,” “we,” “our” or “us”). The SUGAR LOAF trademark and associated logo is a registered trademark of National Entertainment Network, LLC, used by us with permission. The following Sugar Loaf® Games Website Privacy Policy (“Privacy Policy”) sets forth our policy with respect to the collection, storage and use of your personal information and other information that we collect from you. Please note, if you are a resident of a European Union Member State, you are not permitted to use the Site and/or other Sugar Loaf Games Offerings (as defined below).

Background

This Privacy Policy covers our treatment of personal information, as defined herein, and other information that we collect when an end-user (“User,” “you” or “your”): (a) accesses the Site; (b) accesses and/or downloads any of the text, audio, video, photographs, graphics, artwork, testimonials and/or other content featured on the Site (collectively, “Content”); (c) registers (including via our SMS text message-based program (the “Text Service”)) to receive free plays (“Free Plays”) to be used on one (1) or more physical “claw” type amusement games (“Claw Games”), as operated by third-party game operators (“Third-Party Game Operators”); and/or (d) purchases Claw Game plays in bulk by and through the Site (“Bulk Plays,” and together with the Site, Content, Text Service and Free Plays, the “Sugar Loaf Games Offerings”).

Capitalized terms not defined herein shall have the meanings set forth in the Sugar Loaf Games Website Terms and Conditions (“Terms and Conditions”).IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE UTILIZE THE SUGAR LOAF GAMES OFFERINGS.

Your California Privacy Rights

If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third-parties, what categories of personal information that we have shared with third-parties in the preceding year, as well as the names and addresses of those third-parties, please call us at: 551-253-2127; e-mail us at: support@digital-claw.com; or send us U.S. Mail to: Digital Claw, LLC, 910 Sylvan Avenue, Suite 140, Englewood Cliffs, NJ, 07632.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third-party for marketing purposes, please call us at: 551-253-2127; e-mail us at: support@digital-claw.com; or send us U.S. Mail to: Digital Claw, LLC, 910 Sylvan Avenue, Suite 140,Englewood Cliffs, NJ, 07632.

If You are a resident of the State of Nevada and would like to opt-out from the sale of Your personal information to any third party data broker, please e-mail us at: support@digital-claw.com or send U.S. mail to: Digital Claw, LLC, 910 Sylvan Avenue, Suite 140, Englewood Cliffs, NJ, 07632.

Personal Information Collected

For purposes of this Privacy Policy, “personal information ” shall mean individually identifiable information from or about an individual, which may include your name, date of birth, company name, e-mail address, phone number, and other information that identifies you. We collect personal information when you access certain of the Sugar Loaf Games Offerings and complete the required information request form and/or otherwise provide such information to us.

Where a User attempts to utilize the Sugar Loaf Games Offerings, that User may be required to submit, and Sugar Loaf Games may collect, some or all of the following information: (a) full name; (b) mailing/billing address; (c) e-mail address; (d) telephone number; (e) credit card information (where purchasing Bulk Plays); and/or (f) any other information requested by us on the Form. For purposes of this Privacy Policy, the personal information described item (e) in the preceding sentence shall be referred to as “Sensitive Data.”

Use of Personal Information

By submitting your personal information by and through the Sugar Loaf Games Offerings, you agree that we may share, sell, rent, lease, seek third party advertisers, or otherwise provide that personal information to any third-party for any purpose permitted by law, and we may work with other businesses to bring selected retail opportunities to our Users (other than: (a) Sensitive Information and (b) any information collected through the SLG Short Code associated with the Text Service, which will not be shared and/or sold in such a manner). These businesses and third-parties may include, but are not limited to: (i) providers of direct marketing services and applications, including lookup and reference, data enhancement, suppression and validation; (ii) e-mail marketers; (iiii) telemarketers (where permitted by applicable law); and (iv) direct marketers. We may also use your personal information to send you promotional messages regarding various Sugar Loaf Games products and/or services, as well as third-party products and/or services that we think may be of interest to you.

Where you submit personal information, we use the personal information that you make available to personalize your experience with the Site and to facilitate the delivery of the applicable Sugar Loaf Games Offerings to you, including to respond to any inquiries made by you. We also utilize analytic services, including, without limitation Google Analytics and Smartlook to capture and analyze visits and traffic in using the Sugar Loaf Games Offerings. These analytic services collect information about your use of the Sugar Loaf Games Offerings, including, without limitation, information about your visit to the Site, any referral website, the type of web browser and operating system you are currently using, geolocation, and your network location and IP address. The information collected by these analytic services is anonymous.

 

You also agree that we may contact you at any time with updates and/or any other information that we may deem appropriate for you to receive in connection with your continued use of the Sugar Loaf Games Offerings, and to keep you informed of our other products and services.

We may also employ other companies and individuals to perform certain functions on our behalf. Examples include sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis. The agents performing these limited functions on our behalf shall have access to our Users’ personal information as needed to perform these functions for us, but we do not permit them to use User personal information for other purposes.

We will also use your personal information for customer service, to provide you with information that you may request, to customize your experience with the Sugar Loaf Games Offerings and/or to contact you when necessary in connection with your use of the Sugar Loaf Games Offerings. We may also use your personal information for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the Sugar Loaf Games Offerings. We may also combine the information we have gathered about you with information from other sources.

By submitting your personal information by and through the Sugar Loaf Games Offerings, you agree that such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations. As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations.

Where you provide “prior express consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls from Sugar Loaf Games, including artificial voice calls, pre-recorded messages and/or calls (including SMS text messages associated with the Text Service, and otherwise) delivered via automated technology, to the telephone number(s) that you provided. Please note that you are not required to provide this consent in order to obtain access to the Sugar Loaf Games Offerings, and your consent simply allows Sugar Loaf Games to contact you via these means. In some instances, in order to receive Free Plays, you will be asked to send a text message to a Sugar Loaf Games-provided telephone number and/or short code, after which Sugar Loaf Games will reply with a link to the Site.

Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes. Without limiting the foregoing, if you: (A) have your telephone number reassigned to another person or entity; (B) give up your telephone number so that it is no longer used by you; (C) port your telephone number to a landline or vice versa; or (D) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify Sugar Loaf Games of the Phone Number Change via e-mail at: support@digital-claw.com, or by using one of the methods set forth in the “Contact Us” section below.

We reserve the right to release current or past personal information (including Sensitive Data): (I) in the event that we believe that the Sugar Loaf Games Offerings are being or have been used in violation of the Terms and Conditions or to commit unlawful acts; (II) if the information is subpoenaed or requested pursuant to any court order or legal proceeding; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena/court order, prior to disclosure of any personal information pursuant to a subpoena; or (III) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Sugar Loaf Games is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information.

You hereby consent to the disclosure of any record or communication to any third-party when we, in our sole discretion, determine the disclosure to be appropriate including, without limitation, sharing your e-mail address with third-parties for suppression purposes in compliance with applicable law, including the CAN-SPAM Act of 2003, as amended from time-to-time. Users should also be aware that courts of equity, such as U.S. Bankruptcy Courts, might have the authority under certain circumstances to permit personal information to be shared or transferred to third-parties without permission.

Credit Card/Debit Card Transactions

Sugar Loaf Games utilizes third party service providers to provide credit card payment processing services. If you choose to purchase Bulk Plays, the credit card/debit card information provided will either be collected directly by one of such third-party payment processing service providers, or we will share that payment information with our contracted third-party service provider(s). Sugar Loaf Games requires that its third-party payment processing service provider(s) has/have in place privacy policies and practices consistent with this Privacy Policy; provided, however, that we cannot guarantee the privacy practices of our third-party payment processing service provider(s).

Non-Personal Information Collection and Use

IP Addresses/Browser Type
We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Site. This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T). We use the non-personally identifiable information that we collect to improve the design and content of the Sugar Loaf Games Offerings and to enable us to personalize your Internet experience. We also may use this information in the aggregate to analyze usage of the Sugar Loaf Games Offerings.

Cookies
When a User visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign an anonymous, unique identifier to the applicable User’s computer. The Site may use other similar technologies (including, without limitation, tracking pixels, and other identifiers) to gather information about you, such as IP addresses and location data, to customize your visit, to enable us to enhance our Service, or for other purposes. A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you. Cookies have many benefits to enhance your experience at the Site. To find out more about Cookies, please visit www.cookiecentral.com. We use Cookies to improve the quality of the Sugar Loaf Games Offerings, including for storing User preferences and tracking Site-User trends (such as pages opened and length of stay at the Site).

Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent. To disable and reject certain Cookies, follow the instructions associated with your Internet browser. Even in the case where a User rejects a Cookie, he or she may still use the Sugar Loaf Games Offerings; provided, however, that certain functions associated with the Sugar Loaf Games Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. We reserve the right to retain Cookie data indefinitely.

Behavioral Tracking
Sugar Loaf Games, as well as third party entities such as Google®, use Cookies, pixels and other tracking technology (collectively, “Tracking Technology”) in connection with the Site for purposes of tracking Users’ activities (such as websites visited, advertisements selected and pages viewed) after they leave the Site. Sugar Loaf Games, and its third-party partners, use this Tracking Technology to target applicable Users with advertisements featuring Sugar Loaf Games products and/or services, as well as third-party products and/or services, that may be of interest to applicable Users.

In general, Users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. In addition, Users may be able to opt-out of this form of tracking utilizing the options made available by the Network Advertising Initiative or Digital Advertising Alliance.

Further, Users can opt-out of certain Google®-related tracking technology, and customize the Google® Display Network ads that they receive, by visiting the Google® Ads Settings at: http://www.google.com/settings/ads. Google® also recommends installing the Google® Analytics Opt-out Browser Add-on for your web browser, which is available here: https://tools.google.com/dlpage/gaoptout. To the greatest extent permissible by applicable law, we are not responsible for the tracking practices of third-parties in connection with the Site.

Google® is a registered trademark of Google, Inc. (“Google”). Please be advised that Sugar Loaf Games is not in any way affiliated with Google, nor are the Sugar Loaf Games Offerings endorsed, administered or sponsored by Google.

Cross Device Tracking
Sugar Loaf Games tracks your use of the Sugar Loaf Games Offerings across various devices, including your personal computer and mobile device, in order to optimize and personalize your Sugar Loaf Games Offerings experience. Sugar Loaf Games may collect certain of your personal information across various devices. If you would like to opt-out of having your use of the Sugar Loaf Games Offerings tracked across multiple devices, please e-mail us at: support@digital-claw.com. Please be advised that where you opt-out of having your use of the Sugar Loaf Games Offerings tracked across devices, you may need to upload certain information multiple times and/or input your log-in information multiple times.

Aggregate Data
Sugar Loaf Games reserves the right to transfer and/or sell aggregate or group data about Users of the Sugar Loaf Games Offerings for lawful purposes. Aggregate or group data is data that describes the demographics, usage and other characteristics of Sugar Loaf Games Offerings Users as a group, without disclosing personally identifiable information.

Third-Party Websites

This Site may contain links to third-party owned and/or operated websites. Sugar Loaf Games is not responsible for the privacy practices or the content of such websites. In some cases, you may be able to make a purchase through one of these third-party websites. In these instances, you may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Sugar Loaf Games has no responsibility or liability relating to them.

Log-In Through Social Networks

You may have the option of signing into the Services through Facebook, Google, or other social networks. Logging in through these social networks may allow us to access certain public information related to your Account. When you sign in through one of these social networks, you may be asked what information you would like to share. It is up to you what to share with us, or whether anything at all from your social network profile is shared.

Security

We endeavor to safeguard and protect our Users’ personal information. When Users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline). Where our registration/application process prompts Users to enter Sensitive Data, and when we store and transmit such Sensitive Data, that information is encrypted with advanced TLS (Transport Layer Security).

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public. All of our Users’ personal information is restricted in our offices. Only employees or third-party agents who need User personal information to perform a specific job are granted access to User personal information. Our employees are dedicated to ensuring the security and privacy of all User personal information. Employees not adhering to our firm policies are subject to disciplinary action. The servers that we store User personal information on are kept in a secure physical environment. We also have security measures in place to protect the loss, misuse and alteration of personal information under our control.

Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure. Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law. For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure. Any transmission of data at or through the Site, other Sugar Loaf Games Offerings or otherwise via the Internet or wireless networks, is done at your own risk.

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information. You will be notified via e-mail in the event of such a breach. Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures.

Minors

Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Sugar Loaf Games does not knowingly solicit or collect information from visitors under eighteen (18) years of age. Sugar Loaf Games encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.

Opt-Out/Unsubscribe

To opt-out of receiving e-mail and other forms of communication from us, you can: (a) follow the instructions included in the applicable e-mail message or other communication; or (b) e-mail us at: support@digital-claw.com.  To opt-out of the Text Service you can text "STOP" to the SLG Short Code.  After you send the "STOP" message to the SLG Short Code, we will send you an SMS message to confirm that you have been unsubscribed

Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to your request for Sugar Loaf Games Offerings, as well as to respond to any inquiry or request made by you. To opt-out of receiving Sugar Loaf Games Offerings-related and/or inquiry response-related messages from Sugar Loaf Games, you must cease requesting and/or utilizing the Sugar Loaf Games Offerings and/or cease submitting inquiries to Sugar Loaf Games, as applicable.

If you are a resident of the State of Nevada and would like to opt-out from the sale of your personal information to any third party data broker, please e-mail us at: support@digital-claw.com; or send us U.S. Mail to: Digital Claw, LLC, 910 Sylvan Avenue, Suite 140, Englewood Cliffs, NJ, 07632.

Deleting, Modifying and Updating Your Information

At your request, we will: (a) inform you of what personal information we have on file for you; (b) amend the personal information that we have on file for you; and/or (c) remove personal information that you have provided to us, or that we have collected. You may do so by e-mailing us at: support@digital-claw.com. We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and, to the extent permitted by applicable law, we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

Please be advised that deleting your personal information may terminate your access to certain of the Sugar Loaf Games Offerings. If you wish to continue using the full complement of Sugar Loaf Games Offerings, you may not be able to delete all of the personal information that we have on file for you.

Please be further advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

Transfer of Personal Information Internationally

If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers. Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy.

Changes to this Privacy Policy

Sugar Loaf Games reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy. If the manner in which we use personal information changes, Sugar Loaf Games will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) any other reasonable means acceptable under applicable state and federal law. You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices in general, please call us at: 551-253-2127; e-mail us at: support@digital-claw.com; or send us U.S. Mail to: Digital Claw, LLC, 910 Sylvan Avenue, Suite 140, Englewood Cliffs, NJ, 07632.

Filing a Complaint with the Federal Trade Commission

To file a complaint regarding our privacy practices, please click here.