privacy policy

What This Policy Covers

This Privacy Policy applies to information that we collect about you when you use:

  • Our websites (including downtownjakebrown.com), and

  • Our mobile applications (including Fishbowl for iOS).

Throughout this Privacy Policy we’ll refer to our websites, mobile applications, and other products and services collectively as “Services.” Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:

  • Basic information: We may ask for basic information from you in order to set up an account, use our apps, or the like. For example, we require individuals who play a game on Fishbowl to provide their name (though you may use a pseudonym if you like).

  • Communications with us: You may also provide us with information when you, e.g., respond to surveys, communicate with our support team about a support question, or sign up for a newsletter. When you communicate with us via form, email, phone, comment, or otherwise, we may store a copy of our communications (including any call recordings as permitted by applicable law).

Information We Collect Automatically

We also collect some information automatically:

  • Log information: Like most online service providers, we may collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We may collect log information when you use our Services — for example, when you use our apps.

  • Usage information: We may collect information about your usage of our Services. We also collect information about what happens when you use our Services (e.g., page views, and other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.

  • Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps if you allow us to do so through your mobile device operating system’s permissions.

  • Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll.

  • Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. We may use cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

  • To provide our Services.

  • To ensure quality, maintain safety, and improve our Services.

  • To place and manage ads in our advertising program.**

  • To market our Services and measure, gauge, and improve the effectiveness of our marketing.

  • To protect our Services, our users, and the public.

  • To fix problems with our Services.

  • To customize the user experience.

  • To communicate with you.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or (5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on.

Sharing Information

How We Share Information

We may share information about you in limited circumstances, and with appropriate safeguards on your privacy.

We have a long-standing policy that we do not sell our users' data. We aren't a data broker, we don't sell your personal information to data brokers, and we don't sell your information to other companies that want to spam you with marketing emails. We show ads on some of our Services, and the revenue they generate lets us offer free access to some of our Services. Under a new California law, the California Consumer Privacy Act ("CCPA"), some personalized advertising you see online and on our services might be considered a "sale" even though we don't share information that identifies you personally, like your name or email address, as part of our advertising program.

Information Shared Publicly

Information that you choose to make public is — you guessed it — disclosed publicly. That means information like your public profile, posts, other content that you make public on our Services. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share publicly.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

  • Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information.

  • Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features.

  • Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.

  • Set your browser to reject cookies: You can usually choose to set your browser to remove or reject browser cookies before using our websites, with the drawback that certain features of our websites may not function properly without the aid of cookies.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

  • Request access to your personal data;

  • Request correction or deletion of your personal data;

  • Object to our use and processing of your personal data;

  • Request that we limit our use and processing of your personal data; and

  • Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

  • Identifiers (like your name, contact information, and device and online identifiers);

  • Commercial information (your billing information and purchase history, for example);

  • Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);

  • Internet or other electronic network activity information (such as your usage of our Services);

  • Geolocation data (such as your location based on your IP address);

  • Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one); and

  • Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the Information We Collect section above. We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

  • Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;

  • Request deletion of personal information we collect or maintain;

  • Opt out of any sale of personal information; and

  • Not receive discriminatory treatment for exercising your rights under the CCPA.

The CCPA & Personalized Advertising in Our Ads Program

We show ads on some of our Services, and the revenue these ads generate lets us offer free access to some of our Services. As part of our advertising program, we may use cookies to share certain device identifiers and information about your browsing activities with our advertising partners, and those advertising partners may use that information to show you personalized ads on some of our users’ sites and some of our own. The personal information we share includes online identifiers; internet or other network or device activity (such as cookie information, other device identifiers, and IP address); and geolocation data (approximate location information from your IP address). These disclosures may be considered a “sale” of information under the CCPA. We do not sell (or share) information through our ads program that identifies you personally, like your name or contact information. We don't knowingly sell personal information of those under 16.

Contacting Us About These Rights

If you’d like to contact us about these rights, scroll down to “How to Reach Us” to, well, find out how to reach us. When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us through our web form (https://downtownjakebrown.com/contact).

Other Things You Should Know (Keep Reading!)

Transferring Information

Because our Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third-party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

  • In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or

  • In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Ads and Analytics Services Provided by Others

Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver ads that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by us and does not cover the collection of information by any third-party advertisers or analytics providers.

Privacy Policy Changes

Although most changes are likely to be minor, we may change our Privacy Policy from time to time. We encourage visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we will alert you about any changes by updating the “Last updated” date of this Privacy Policy. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

That’s it! Thanks for reading.

Last Updated: 2020-12-09