Updated December 26, 2019
"Personal Information" means information that is about any individual, or from which any individual is directly or indirectly identifiable.
"Process", "Processing" or "Processed" means anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We may Process the following categories of Personal Information about you:
We also collect other kinds of information from you or other sources, which we refer to as "Other Information" in this Policy, which may include but is not limited to:
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as "User Information".
We do not collect or otherwise Process Personal Information about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, or any other information that may be deemed to be sensitive under GDPR (collectively, "Sensitive Personal Information") in the ordinary course of our business. Where it becomes necessary to Process Sensitive Personal Information under GDPR, we would rely on one of the following legal bases:
Children. The Services are not intended for use by children, especially those under 13. No one under the age of 13 should provide any Personal Information. Minors under the age of 18 are not permitted to make purchases through the Services or obtain coupons or codes from the Services to purchase goods or services on third party websites. If it is discovered that we have collected Personal Information from someone under 13, we will delete that information immediately.
Collection of User Information: We may collect User Information about you from the following sources:
Please note that Humble Bundle is not responsible for the information you volunteer about yourself in the discussions in certain public areas of the Services or information that you choose to make public in your member profile or other areas of the Services that allow users to upload or post content. We discourage users from posting such Personal Information in this fashion. You can change your publicly available information at any time via your profile page. To request removal of your Personal Information from these areas, please contact us using our DSAR Portal. In some cases, we may not be able to remove your Personal Information, in which case we will let you know we are unable to do so and why.
Creation of User Information. We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal administrative purposes and analysis. We may also combine data you have provided to us with data obtained from third parties such as social networks.
The purposes for which we may Process User Information, subject to applicable law, include:
We may Process your User Information to contact you via email or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.
Certain third parties may collect information about you for online behavioral advertising purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. We use Online Data as well as other User Information to send you online behavioral ads we believe are more relevant to your interests.
Tracking technologies on the Services may be deployed by Humble Bundle and/or by our service providers or partners. Certain tracking technologies enable us to assign a unique identifier to you, and relate information about your use of the Services to other information about you, including your User Information. We may match information collected from you through different means or at different times and use such information along with offline and online information obtained from other sources (including from third parties), including, but not limited to, demographic information and updated contact information, for the purposes of learning more about you so we can provide you with relevant content and advertising.
We and our partners (including but not limited to e-commerce partners, affiliates, and analytics providers) also may use technologies such as pixel tags, IP addresses, and Local Storage such as HTML5 to analyze trends; administer the Services; collect and store information such as user settings and anonymous browser identifiers; supplement our server logs and other methods of traffic and response measurement; track users' location and movements around the Services; gather demographic information about our user base; and to improve our understanding of traffic on the Services and visitor behavior. We may receive reports based on the use of these technologies by these third party companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing Local Storage.
We may use mobile analytics software to collect data and to better understand the functionality of our mobile software, devices and applications on your phone and other devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We may link this information to User Information.
Certain third parties may collect information about you for online behavioral advertising ("OBA") purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.
The specific providers we use for OBA are subject to change. For a list of some of the applicable providers, click here. For more details about OBA and opting out, see Section 15 below.
In Processing your User Information in connection with the purposes set out in this Policy, we may rely on one or more of the following legal bases, depending on the circumstances:
We may disclose your User Information to other entities within the Company group, for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users' responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where Humble Bundle advises users of the possibility of such disclosure at the time they take the survey, Humble Bundle reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.
Some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Channels. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website, app and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.
We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, such as to monitor fraud around the web.
If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.
Because of the international nature of our business, we may need to transfer your User Information within the Humble Bundle group of companies, and to third parties as noted in Section 9 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
Humble Bundle, Inc. participates in and has certified its compliance with the E.U.-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Humble Bundle is committed to subjecting all Personal Information received from European Union (E.U.) member countries and Switzerland, in reliance on the Privacy Shield Framework, to the Framework's applicable principles. To learn more about the Privacy Shield Framework, please visit the U.S. Department of Commerce's Privacy Shield List. Humble Bundle is responsible for the processing of Personal Information it receives under the Privacy Shield Framework and subsequent transfers to a third party acting as an agent on its behalf. Humble Bundle complies with the Privacy Shield principles for all onward transfers of Personal Information from the E.U. and Switzerland, including the onward transfer liability provisions. With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, Humble Bundle is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Humble Bundle may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you are a European individual with a privacy related complaint, concern or question about Ziff Davis' privacy practices, please contact us through our DSAR Portal and we will respond within a reasonable time after receiving your request. Under certain conditions, more fully described on the Privacy Shield website, European individuals may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Where we transfer your Personal Information from the EEA to recipients located outside the EEA who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Information, we do so on the basis of standard contractual clauses. You may request a copy of the relevant standard contractual clauses by using our DSAR Portal.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us are sent securely.
We take every reasonable step to ensure that your User Information that we Process is accurate and, where necessary, kept up to date, and any of your User Information that we Process that you inform us is inaccurate (having regard to the purposes for which they are Processed) is erased or rectified.
We take every reasonable step to ensure that your User Information that we Process is limited to the User Information reasonably necessary in connection with the purposes set out in this Policy or as required to provide you services or access to the Services.
We take every reasonable step to ensure that your User Information is only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will keep your User Information are as follows: we will retain copies of your User Information in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. Unless there is a specific legal requirement for us to keep the information, we plan to retain it for no longer than is necessary to fulfill a legitimate business need.
You can directly take steps to change your preferences for newsletters and online behavioral advertising as outlined in this section.
If you are an EU resident, you may have certain rights including: the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Information; the right to object to the Processing of your Personal Information; the right to have your Personal Information transferred to another controller; the right to withdraw consent; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.
You may directly take steps to change your preferences as follows:
Access to Your Personal Information. Upon request Humble Bundle will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account or contacting us through our DSAR Portal. We will respond to your request within a reasonable timeframe.
Your Newsletter and Email Subscriptions. You can opt out or unsubscribe to a newsletter or other email list at any time by following the instructions at the end of the newsletters or emails you receive. Please allow five to ten business days for changes to take effect. On some parts of the Service, member service-related communications are an integral part of such Services to which you subscribe and you may continue to receive emails as part of that particular portion of the Services unless you cancel your account, even if you opt out of the newsletters or email list. If you have provided more than one email address to us, you may continue to be contacted unless you request to unsubscribe each email address you have provided.
Push Notifications. We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off by adjusting the permissions in your mobile device. Please note that your opt out is limited to the device used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing or Humble Bundle's ongoing business relations.
Mobile Applications. There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as "Ad IDs" to associate app user activity to a particular app and to track user activity across apps. You can stop all collection of information via our mobile applications by uninstalling them. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device (which is usually located in the Settings area of your device).
Cookies and Pixel Tags. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you "turn off," purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.
California Residents. In accordance with the California Online Privacy Protection Act, we may collect Personal Information about your online activities when you use the Services. While we give our users many avenues to opt out of providing Personal Information, we do not respond to Web browsers' "do not track" signals. California's "Shine the Light" law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Information disclosed to third parties for direct marketing purposes. If you are a California resident and wish to make such a request or if you wish for us to refrain from gathering your Personal Information, please submit your request in writing to the contact details set out in Section 17 below.
EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us using the DSAR Portal. If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.
We recommend that you review our Terms and Conditions regularly, in order to review any changes we might make from time to time.
You may contact us at the addresses set out below or by emailing email@example.com For GDPR related inquiries, please use our webform at DSAR Portal.
c/o Ziff Davis
Attention: Legal Department
114 Fifth Avenue, 15th Floor
New York, NY 10011
If you are an EU resident, you may contact our Data Protection Officer at firstname.lastname@example.org or submit GDPR related inquiries to our DSAR Portal.
If you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of User Information carried out by us, or on our behalf, please contact:
c/o Ziff Davis
Attention: Legal Department
114 Fifth Avenue, 15th Floor
New York, NY 10011 email@example.com
Our Data Protection Officer may be contacted at firstname.lastname@example.org. For GDPR related inquiries, please use our webform at DSAR Portal.
If we are unable to resolve your complaint directly, you may submit your complaint at no cost to you to JAMS.
You have the right to request that we disclose what personal information we collect, use, disclose, and sell. To submit a verifiable request, please visit https://dsar.humblebundle.com or email email@example.com
If you have an account with us, we will verify the request by confirming the email address used to make the request is the same as the email address on file for the account. If you do not have an account with us, we will verify the request by sending an email to the email address used to make the request. We may ask for additional information reasonably related to the request to verify the request.
The categories of California consumers' Personal Information we may collect are listed above in Section 2 ("What Categories of Information We Process"). In reference to Section 2, we may collect Personal Details, Demographic Information, Contact Details, Consent Records, Purchase and Payment Details, Employer Details, Views and Opinions and User Information.
We may collect California consumers' Personal Information from the sources listed in Section 4 ("How We Collect User Information"). As defined in Section 4, this may be: Data You Provide; Business Relationship Data; Data You Make Public; Service Data; Widget Data; Content and Advertising Information; and Third Party Information. We may obtain personal information from the following sources as defined in Section 2 ("What Categories of Information We Process"): GeoIP Data; ID; IDFA; IP address; ISP; SSID; IMSI; IMEI; Log files; Web Beacons; Pixel Tags; Local Shared Objects, such as Flash cookies, and Local Storage, such as HTML5, and equivalents.
We use this data for the purposes listed above in Section 5 ("Purposes for which we may Process your Personal Information") or for Direct Marketing as outlined in Section 6 ("Direct Marketing").
We may and may have disclosed the categories of Personal Information listed in Section 9 ("What Information We Disclose to Third Parties") to our vendors, service providers and partners for a business purpose.
We may and may have disclosed Personal Information to the following categories of third parties for a business purpose:
We have not sold any personal information to third parties for a commercial purpose in the preceding twelve (12) months.
The Services are not intended for use by minors. We do not sell personal information of minors under 16 years of age without affirmative authorization.
You have the right to request deletion of Personal Information collected or maintained by us. To do so, please submit a request via https://dsar.humblebundle.com or email firstname.lastname@example.org. If submitting a request by email, we may ask for additional information to verify your request.
You have the right to opt-out of the sale of Personal Information by a business. We do not sell your personal information.
You have the right not to receive discriminatory treatment by the business for exercising your privacy rights conferred to you by the California Consumer Privacy Act.
To make a request under the California Consumer Privacy Act on a consumer's behalf, we require a signed authorization letter from the consumer to email@example.com.
If you have any questions or concerns about our privacy policies and practices, you may contact us via https://dsar.humblebundle.com or email firstname.lastname@example.org.