Social Gaming Leadership Alliance (SGLA) Privacy Policy

Table of contents

1.        Data Controller

2.        Type of information we collect

3.        How we collect your information

4.        How we use collected information

5.        Personal data collected via technology

6.        Your rights over your information

7.        Exercising your rights over your information

8.        How we protect your information

9.        How long do we retain your information

10.        Sharing your information

11.        Global Privacy Control

12.        Other important information

13.        Changes to this Privacy Policy

14.        Contacting us

 

Introduction

At the Social Gaming Leadership Alliance (“SGLA”), we are committed to protecting and respecting your privacy. This privacy policy ("Privacy Policy") explains how your personal information is collected, why it is collected and how it is kept secure. We are committed to complying with obligations under all applicable data privacy laws in the United States, Canada and Australia, including but not limited to, the California Consumer Privacy Act (including the California Privacy Rights Act), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Florida Digital Bill of Rights, the Iowa Consumer Data Protection Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Privacy Act, the New Jersey Data Protection Act, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, the Canadian Personal Information Protection and Electronic Documents Act, and the Australian Privacy Act 1988 (Cth) (including the Australian Privacy Principles set out in the Privacy Act (the ‘APPs’)). This Privacy Policy governs the manner in which the SGLA and any Social Gaming Leadership Alliance Members who may be part of our alliance, that form the SGLA group ("SGLA Group") collect, use, maintain and disclose information collected through sgleadership.org/#contact-us and any subdomains, subpages, successor sites or any application accessible via our website (the "SGLA Website"). This Privacy Policy applies to the SGLA Website, and any services or applications provided through the SGLA Website.

 

1. Data Controller

1. This Privacy Policy is issued on behalf of the SGLA so when we mention "SGLA", "we", "us" or "our" in this Privacy Policy, we are referring to the SGLA.  
2. The data controller responsible for processing data collected through your use of the SGLA Website (including any data you may provide through the SGLA Website) is the sgleadership.org having its registered address at 1620 Eye Street, NW, Suite 900 Washington, DC 20006 (the "Data Controller").

2. Type of information we collect

1. Personal information is any information about you, whether it is true or not, where your identity is apparent or can reasonably be ascertained from that information.  When anonymous information is directly or indirectly associated with personal information, the resulting information is also treated as personal information. Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual.  Aggregate information means information about groups or categories of users, which does not identify and cannot reasonably be used to identify an individual user.
2. We do not collect any sensitive personal information about you (including details about your age, gender, race, ethnicity, religious or philosophical beliefs, sex life/orientation, political opinions, trade union membership, health, genetic or biometric data).  However, if you choose to share this information, then this will be deemed consent.  We may collect, use, or share aggregated data such as statistical or demographic data for the purpose of reporting.
3. We collect two basic types of information — personal information and anonymous information (as defined above at clause 2.1) — and we may use personal and anonymous information to create a third type of information, aggregate information (also defined at clause 2.1).  We collect:

1. contact details such as your first name and surname, and email address;
2. location information including location information provided by a mobile or other device interacting with the SGLA Website, or associated with your IP address, where we are permitted by law to process this information; and
3. activity, technical and device information about your use of the SGLA Website, such as the content you view, the time and duration of your visit on the SGLA Website, how often you use our services, your preferences and information about your interaction with the content offered through the SGLA Website, your hardware model, device type, other unique device identifiers, operating system version, browser type, IP address and geolocation.

3. How we collect your information

1. We collect information in a variety of ways, as set out below. You confirm that any contact information you provide is true and accurate.
2. Information you provide to us directly including when you visit the SGLA Website, submit an Enquiry Form (sgleadership.org/#contact-us) and in connection with other activities, services, features or resources we make available on the SGLA Website. When you submit an Enquiry Form, we collect your first name, last name, email address, and the details of your query. This information is sent to Seven Letter to assist in handling your Enquiry Form request.
3. Information you provide when using our services

We also collect information about your use of our services through a variety of technologies that are present when you visit the SGLA Website including cookies, flash cookies, pixels, tags and application programming interfaces (“API”).  Please see the section entitled “Personal data collected via technology” below for further information.  Analytics tools are also used by us to collect information, including when you visit the SGLA Website.

4. How we use collected information

1. We use the information collected to operate the SGLA Website.
2. In accordance with applicable laws and any elections made available to you, we may collect and use your information for the following specific purposes:

1. To respond to your enquiries submitted via our Enquiry Form (sgleadership.org/#contact-us) — This includes, for example, your contact details, details of your query and responding to your query.
2. To improve user service and our services — Information you provide helps us respond to your Enquiry Form requests more efficiently.  We may use feedback you provide to improve our services.
3. 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 SGLA Website.
4. To contact you about our services including marketing and newsletters — If you opt in, we may use your contact details to send you regulatory updates, industry news, and other materials for example by email, telephone, text message, or mail.  Please see the section entitled ‘Exercising your rights over your information’ for your opt out rights.
5. To support petition initiatives — We may use your contact details if you choose to sign a petition to be sent to public authorities or other officials.  Please see the section entitled ‘Exercising your rights over your information’ for your opt out rights.
6. To comply with our legal and regulatory obligations — We may use information we collect about you to comply with any legal or regulatory obligations (including the detection, investigation and prevention of activity that may be illegal).
7. To conduct market research and analysis — To analyse how you interact with our services, to monitor and analyse usage and activity trends, and for other research, analytical and statistical purposes.

3. Automated decision making

We do not use automated decision making within the definition of global data protection laws.

5. Personal data collected via technology

1. When you interact with the SGLA Website, we try to make that experience simple and useful. We and our partners use industry standard identifiers, such as cookies or other similar technologies.
2. The SGLA Website may use technologies to enhance your experience.  These technologies are small files that are placed on your computer, tablet, mobile phone or other devices when you visit a website.  They allow us to record certain pieces of information whenever you visit or interact with the SGLA Website.  Usage 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.  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 information is generally non-identifying but if we associate it with you as a specific and identifiable person, we will treat it as personal information.
3. The following are examples of these types of technologies:

1. 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.
2. Cookies.  These are small text files placed in your device browsers to store your preferences.  Most browsers allow you to block and delete cookies.  However, if you do that, the service may not work properly.
3. Event tagging.  Event tagging allows us to track actions that occur on the SGLA Website.
4. Mobile device identifiers.  We may share the advertising identifier associated with your mobile device or tablet (such as the Apple IDFA and Google Advertising ID) with advertisers. It is used to identify your device for internet-based advertising.  For instructions for using the advertising choice mechanisms provided by the most popular mobile operating systems, visit the NAI’s Mobile Choices page here.
5. Pixel tags/web beacons.  A pixel tag (also known as a web beacon) is a piece of code embedded on a website that collects information about your engagement on that web page.  The use of a pixel allows us to record, for example, that a user has visited a particular web page.  We may also include web beacons in e-mails to understand whether messages have been opened, acted on or forwarded.

6. Your rights over your information

1. Marketing communications

If we process your personal information for the purpose of direct advertising, you have the right to object at any time to this processing.  This also applies to profiling, where appropriate, insofar as it is associated with such direct advertising.

2. You may opt out of receiving commercial messages from us by following the instructions contained in those messages or alternatively please submit an Enquiry Form (sgleadership.org/#contact-us). 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.
3. Cookies

You can change your preferences with regards to cookies and other trackers at any time by clicking on the Cookies settings link provided at the bottom of the SGLA Website.

7. Exercising your rights over your information

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.  These rights include but are not limited to:  

1. the right to access the personal information we hold about you;
2. the right to object/opt out of the processing of your information;
3. the right to update and correct your information; and
4. in some circumstances, you can ask us to delete the personal information we hold about you.

2. To exercise the rights described at clause 7.1, please email info@sgleadership.org or alternatively please submit an Enquiry Form (sgleadership.org/#contact-us).
3. We will not discriminate against you (e.g., through denying services or providing a different level or quality of services) for exercising any of the rights afforded to you.
4. 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.
5. Right to Complain to a Supervisory Authority

You also have the right to complain to the relevant data protection supervisory authority about our processing of your personal information. You can contact the supervisory authority responsible in your place of residence or country.

8. How we protect your information

1. We have in place physical, electronic and operational procedures to protect the information that we collect.  We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password and data stored on the SGLA Website.  As part of our commitment to secure data practices, the SGLA Website is hosted on WP Engine, a SOC 2 Type II certified platform, which ensures high standards of infrastructure security and physical protections at the data center level.  We use encrypted HTTPS protocols to protect all data transmissions, and access to website administration is strictly limited to authorized personnel, enforced with Two-Factor Authentication (2FA).  Activity logs are maintained externally to prevent tampering, and form submissions are protected against spam and bots via reCAPTCHA.  Minimal personal information is collected and, where stored, is automatically deleted after 30 days.  Regular internal reviews and cybersecurity training for site administrators help ensure our security posture evolves with emerging threats and technology updates.  Our security measures are reviewed regularly and updated in keeping up with technological advances.
2. We use reasonable means to protect your personal information from misuse, interference, or loss, as well as any unauthorized access, modification or disclosure.
3. 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 us to contain and investigate the data breach.

9. How long do we retain your information

1. We will retain your information for a period of time to reasonably fulfil the purposes specified in this Privacy Policy, unless a longer retention period is required by law.
2. We will take reasonable steps to destroy or permanently de-identify any personal information where:

1. we no longer need the personal information for any purpose for which the personal information was collected or for a related purpose; and
2. we are not required by law, a regulator or a court/tribunal order, to retain the personal information.

10. Sharing your information

1. We do not sell, trade, or rent your personal information.  However, there are circumstances when we share your personal information with the following categories of third parties:

1. Social Gaming Leadership Alliance Members who may be part of our alliance in the SGLA Group;
2. Service providers — other companies who provide services to you on our behalf.  For example, Seven Letter manages the SGLA Website on our behalf and assists in handling your Enquiry Form request;
3. Third parties that interact with us in connection with the services we perform; and
4. Any regulatory bodies and/or legal authorities, if required by law.

2. With third parties

We only share your personal information with third parties on a need-to-know basis, in limited circumstances.  We require any third parties to maintain the same protections over your data that we provide directly to you and to only perform services on our behalf.  Simply put, they are prohibited from using your personal information for purposes other than those requested by us or required by law.

We only share your personal information with third parties for the following circumstances:

5. when you allow us to share your personal information with third parties;
6. when providing you with services and notifying you about either important changes or developments to the features and operation of those services;
7. with our service providers who enable us to provide our services, such as companies that help us with technology services, storing and combining data, processing codes and delivery services.  For example, Seven Letter manages the SGLA Website on our behalf to support our Social Gaming Leadership Alliance with other social gaming providers and payment providers.  Our service providers will have access to your personal information only to perform services on our behalf and are prohibited from using your personal information for purposes other than those requested by us or required by law;
8. 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; and
9. to protect our rights and property and the rights and property of our users and third parties, to detect fraud or other illegal activities, and to comply with law or legal processes.

3. We make available an API provided by Google Maps in order to allow you to have access to an address auto-complete function on the SGLA Website. The use of Google Maps for this purpose by you is subject to the then current Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps.html and Google Privacy Policy at https://www.google.com/policies/privacy.
4. We may also share generic aggregated demographic information not linked to any personal identification information regarding visitors to and users of the SGLA Website with our business partners, affiliates and advertisers for the purposes outlined above.
5. Transfers

The SGLA operates in several international jurisdictions and personal information we collect may be transferred to, and stored and processed by, individual companies in the SGLA or third parties in the United States, Canada, Australia 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.

11. Global Privacy Control

1. Our websites support the Global Privacy Control ("GPC") in accordance with relevant laws. GPC is a browser-based opt-out preference signal that can communicate your privacy preferences to the websites you visit. Because the GPC is browser-based, note that your choices will only apply to online data that is associated with your browser, and you should enable the signal separately for each browser on each device from which you would like to be opted out. Our websites do not support "do-not-track" signals, as there is no industry standard concerning what, if anything, websites should do when they receive such signals.

12. Other important information

1. Minors

Protecting the privacy of children is especially important to us. For that reason, we never knowingly collect or maintain information from individuals under the age of 21, and no part of the SGLA Website is structured to attract anyone under the age of 21.  We do not offer or direct any of our services or products to individuals under the age of 21.

2. Geoblocking restrictions

Access to the SGLA Website is restricted to the United States, Canada and Australia only.  We employ geoblocking measures to prevent access from other regions.

13. Changes to this Privacy Policy

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.  Notice may be by the posting of such changes on the SGLA Website or by other means in accordance with applicable laws.
2. Any changes to the Privacy Policy will become effective when the updated policy is posted on the SGLA Website.
3. This Privacy Policy, in effect as of the last modified date stated below, supersedes and replaces any and all Privacy Policies previously in effect.

14. Contacting us

1. If you have specific questions regarding your personal information or how we use it, please email info@sgleadership.org or alternatively please submit an Enquiry Form https://sgleadership.org/#contact-us.

 

Published: 04/16/2025