FirePhoenix Privacy Policy
Version: 4.0
Date updated: April 8, 2024
At VGW, we are committed to maintaining transparency and protecting the privacy of our customers.
VGW operates the FirePhoenix website and any subdomains, subpages, successor sites or any
application accessible via our website (the “Website”).
At VGW, we are committed to protecting and respecting your privacy, and maintaining the confidence and trust
of our customers. This Privacy Policy (“Privacy Policy”) explains how VGW collects, uses, maintains and
shares information collected from the Website.
We are committed to complying with obligations under all applicable North American data privacy laws,
including, but not limited to, the California Consumer Privacy Act (“CCPA”) (including the California Privacy
Rights Act (“CPRA”)), the Virginia Consumer Data Protection Act, and the Canadian Personal Information
Protection and Electronic Documents Act.
CONTENTS
1 DEFINITIONS
2 DATA CONTROLLER
3 TYPE OF INFORMATION WE COLLECT
4 HOW WE COLLECT YOUR INFORMATION
5 PERSONAL INFORMATION COLLECTED VIA TECHNOLOGY
6 HOW WE USE COLLECTED INFORMATION
7 HOW WE SHARE INFORMATION
8 YOUR PRIVACY RIGHTS
9 HOW WE PROTECT YOUR INFORMATION
10 HOW LONG WILL WE RETAIN YOUR INFORMATION
11 SHARING YOUR INFORMATION
12 MINORS
13 CHANGES TO THIS PRIVACY POLICY
14 CONTACTING US1 DEFINITIONS
Aggregate Information means information about groups or categories of customers, which does not
identify and cannot reasonably be used to identify an individual customer.
Anonymous Information means information that does not directly or indirectly identify, and cannot
reasonably be used to identify, an individual. When anonymous information is directly or indirectly
associated with personal information, the resulting information is also treated as Personal Information.
Personal Information means any information about you, whether it is true or not, that can reasonably be
used to identify you, or otherwise make you identifiable.
VGW (including “VGW Holdings Limited”, “VGW Group”, “We”, “Us” or “Our”) means VGW Holdings
Limited and any applicable subsidiaries, including VGW Malta Limited, VGW GP Limited, VGW Games
Limited, VGW Administration Malta Limited, VGW US, Inc., VGW Luckyland Inc., VGW Holdings US Inc.,
and VGW Canada Inc., that forms the VGW Group and may collect, use, maintain and disclose
information collected from the Website as applies to this Privacy Policy.
2.1 2 DATA CONTROLLER
The business responsible for managing data collected through your use of the Website (including any data
you may provide through the Website when you purchase a product or service or take part in a promotion
or competition) is VGW Malta Limited having its registered address at Trident Park, Notabile Gardens, No6
– Level 3, Central Business District, Mdina Road, Zone 2 Birkirkara CBD2010 Malta.
3.1 3.2 3 TYPE OF INFORMATION WE COLLECT
We collect three types of information (as defined in section 1, Definitions):
● Personal Information
● Anonymous Information
● Aggregated Information
Any other information that we receive and identify as your Personal Information will be treated as Personal
Information by VGW.
The types of Information we may process depend on the business context and the purposes for which it
was collected. It may include:
Contact Details, such as your first name and surname, email address, residential address, and mobile or
other phone numbers.
Personal Information, such as gender, age, age range or your image; and account login details, including
your username, password and pictures associated with your profile.
Transaction Information you provide when you make a purchase, request a redemption or otherwise use
the Website, such as your postal address, phone number and payment or redemption information
including banking and financial details, credit card details and bank account statements (we do not store
your full card details).
Geolocation Information, including approximate location information provided by a mobile or other
device interacting with the Website, or associated with your IP address, where we are permitted by law to
process this information.
Usage Data, which may include activity, technical and device information about your use of the Website,
such as the content you view, the time and duration of your visit on our Website, how often you use our
services, how you first heard about our Website, your preferences and information about your interaction
with the content offered through our Website, your hardware model, device type, other unique device
identifiers, operating system version, browser type and IP address.
Sensitive Information, which may include government issued identity (including drivers licenses,
passport and social security numbers), geolocation and financial information to comply with our business,
legal and regulatory purposes.Information we obtain from a third party, such as a site or platform provider (including Facebook and
Google), about your use of or interest in our services.
4.1 4.2 4.3 4 HOW WE COLLECT YOUR INFORMATION
Information you provide to us directly
This includes information collected when you visit our website, register, purchase products, respond to a
survey, fill out a form, and in connection with other activities, services, features or resources we make
available on our Website.
We collect information from you by telephone, video or in correspondence (including email, live chat, mail,
text message or social media). All telephone or video calls between you and VGW Group representatives
may be recorded for training, quality control and compliance purposes and by continuing with any such
call you consent to it being recorded.
Information we collect as you use our services
We also collect information about your use of our products and services through a variety of technologies
that are present when you visit our websites, including the Website, or use our applications on third party
sites or platforms (whether or not you are logged in or registered) including cookies, flash cookies,
application programming interfaces (“API”), pixels and tags (further information in set out in section 5,
Personal Information Collected via Technology). Analytics tools are also used by us to collect
information, including when you visit our Website or use our applications or services on third party sites or
platforms.
Information we receive from third party service providers
Finally, we also use trusted sources to update or supplement the information you have provided, or we
have collected, including in order to verify or validate information (for example, postal address,
documentation and names).
5.1 5.2 5.3 5.4 5 PERSONAL INFORMATION COLLECTED VIA TECHNOLOGY
We and our service providers use industry standard identifiers, such as cookies or other similar
technologies, to provide an enhanced experience.
These technologies allow us to record certain pieces of information whenever you visit or interact with the
Website. 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 VGW associates it with you as a specific and identifiable
person, VGW will treat it as Personal Information.
The following are examples of these types of technologies:
a) b) c) d) 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.
Cookies. These are small text files placed in your device browsers to store your preferences.
Cookies help us to better understand your behavior including for security and fraud prevention
purposes, they tell us which websites you have visited and facilitate advertisements and web
searches. When you first access our Website you will be given the option to enable or disable
cookies through our cookie banner. You can revisit your choice at any time by going to the cookie
tool bar in your browser. Most browsers allow you to block and delete cookies. However, if you do
that, certain features of the service may not be available or work properly if all cookies are disabled.
Event tagging. Event tagging (including Facebook App Events) allows us to track actions that occur
on the Website such as application installs and purchase events. By tracking these events we can
view analytics, measure ad performance, and build audiences for ad targeting.
Mobile device identifiers. When you download or access our products via a mobile device, we and
our service providers may receive information about your geolocation (based on your IP address)
and your mobile device including advertising identifiers, hardware type, your operating system ande) 5.5 6.1 6.2 your in-game activity. We may share the advertising identifier associated with your mobile device or
tablet (such as the Apple IDFA and Google Advertising ID) with advertisers. We and our service
providers may use this information to provide you with tailored advertising and other content. When
you download or access our games through your mobile device, we may ask permission to track
your activity. If you initially consent to tracking, you may later disable that permission in your device
settings or withdraw your consent. In addition, if you do not want to receive third-party tailored
advertisements, you may opt-out by adjusting the ad tracking settings on your device (such as
turning on “Limit Ad Tracking”) and reset the advertising identifier on your device. Further,
depending on your platform provider (such as Apple or Google), you may be able to download apps
such as the Digital Advertising Alliance’s “AppChoices” app to provide you with control regarding the
collection and use of your cross-app data for tailored advertising. For more information on the
advertising choice mechanisms, visit the NAI’s Mobile Choices page here.
Pixel tags/web beacons. A pixel tag (also known as a web beacon) is a piece of code embedded
on the 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 or clicked on a
particular advertisement. We may also include web beacons in e-mails to understand whether
messages have been opened, acted on or forwarded.
For further information regarding these technologies, and how to exercise your rights, please refer to our
Cookie Notice.
6 HOW WE USE COLLECTED INFORMATION
We use the information collected to operate our Website and to provide our products and services, to
facilitate your financial transactions, to respond to your questions and to fulfill all applicable regulatory
requirements such as anti-fraud checks and other checks required by applicable anti-money laundering
and other legislation.
There may be occasions where we collect and use your information for the following specific purposes:
To provide and manage
the services you request
This includes, for example, processing your registration, setting up
and looking after your account, including checks made to guard
against fraud.
To improve customer
service and our services
Information you provide helps us respond to your customer
service requests more efficiently; we may use feedback you
provide to improve our products and services.
To process payments We may use the information you provide when placing an order to
service that order (including to satisfy our customer due diligence
requirements and to establish the source of funds where
necessary).
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 our Website.
To contact you about our
services including
marketing
We may contact you by email, live chat, telephone, text message,
mail or social media for communications related to your use of our
services and products, including in connection with your accounts,
offers and information about our products and services,
promotions and competitions you choose to enter, online surveys,
new features that you are entitled to access, and other important
information. Please see section 8, Your Privacy Rights, for your
opt out rights.
To send important notices
to you
From time to time, we may send important notices to you, such as
communications about purchases you have made, or legal notices
regarding the changes to our terms and conditions or other
policies. This information is important to your interactions with us
and you acknowledge that you may not opt-out of receiving these
communications.To comply with our legal
and regulatory obligations
We may use information we collect about you to assess your
social gameplay activity for responsible social gameplay
purposes, taxation purposes, to comply with fraud and anti-money
laundering laws (including to establish the source of funds where
a transaction is involved) or to comply with any other legal or
regulatory obligations (including the detection, investigation and
prevention of activity that violates our Terms and Conditions or
that may be illegal).
To offer alternative dispute
resolution services
We may provide information we collect about you to our service
provider for the specific purpose of resolving any disputes that
have not been satisfactorily resolved through our internal
processes.
To conduct market
research and analysis
We may use information we collect about you to analyze how you
interact with our products and services, to monitor and analyze
usage and activity trends, and for other research, analytical and
statistical purposes.
6.4 6.3 Behavioral Advertising
We may partner with a third-party service provider to: (a) display advertising on our Website or any
application accessible via our Website; and (b) manage our advertising on other websites (for example,
using custom audiences on Facebook) to help us provide more relevant advertisements. Under some US
state privacy laws, consumers have the right to opt out of the sharing or sale of their Personal Information
with third parties for targeted advertising (also known as behavioral advertising). “Behavioral advertising” in
this context means advertisements that may be sent to you based on your data through the use of
technologies such as cookies to gather information about your activities on our Website and other
websites.
If you wish to opt-out of behavioral advertising click here (or if located in Canada click here). Please note
you will continue to receive generic advertisements.
7 HOW WE SHARE INFORMATION
7.1 The following categories of data may be shared for behavioral advertising purposes:
a) Name and contact data;
b) Demographic data;
c) Subscription and licensing data; and
d) interactions.
7.2 The above data may be shared with third parties that perform online advertising services for VGW for the
purposes of delivering tailored advertising based on your interests.
7.3 If you do not want to receive third-party tailored ads, you may opt-out by adjusting the ad tracking settings
on your device (such as turning on “Limit Ad Tracking”). You can also reset the advertising identifier (like
an IDFA) from your device’s settings, which will prevent continued use of existing behavioral data tied to
the previous advertising identifier. Depending on your platform provider (such as Apple or Google), you
may be able to download apps such as the Digital Advertising Alliance’s “AppChoices” app, that offers to
provide you with control regarding the collection and use of cross-app data for tailored advertising. These
opt-out tools are provided by third parties, not VGW. VGW does not control or operate these tools or the
choices that advertisers and others provide through these tools.
8 YOUR PRIVACY RIGHTS
8.1 We appreciate that by law and subject to certain conditions you have a number of rights concerning the
Personal Information we hold about you. Further information and advice about your rights can be obtained
from the data protection regulator in your country or state.8.2 Your rights may include, but are not limited to, the following:
The right to access You have the right to access your Personal Information we process,
and certain other information (similar to that provided in this Privacy
Policy).
The right to rectification
or correction
You are entitled to have your Personal Information corrected if it is
inaccurate or incomplete. You can request that we rectify any errors
in information that we hold about you.
The right to be informed You have the right to know how we collect and use your information
and your rights regarding your Personal Information.
The right to object to
processing
You have the right to object to certain types of processing, including
processing for direct marketing and advertising.
The right to delete You have the right to request the deletion or removal of your
Personal Information subject to certain exceptions.
The right to data
portability
With certain exceptions, you have the right to obtain and reuse your
information in an easily understandable format.
The right to opt-out of
sharing
You have the right to opt out of the sharing of your Personal
Information to a third party for cross-context behavioral advertising.
The right to complain to
a supervisory authority
You also have the right to complain to the relevant data protection
supervisory authority about VGW’s processing of your Personal
Information. Please complete the FirePhoenix Privacy Request
Form here or alternatively, email [email protected].
8.3 Additional Rights
8.4 Residents of California have the right to: (1) request to know more about the categories and specific
pieces of Personal Information we collect, use and disclose; (2) request deletion of your Personal
Information; (3) opt out of sale of your Personal Information (if any); (4) not be discriminated against for
exercising these rights; and (5) limit use of your sensitive Personal Information if we use such Personal
Information to infer characteristics about you. We do not currently use sensitive Personal Information for
such purposes. In some states, we may be required to obtain your consent before collecting your sensitive
Personal Information.
Under some US state privacy laws, consumers have the right to opt out of the sharing or sale of their
Personal Information with third parties for targeted advertising (behavioral advertising). Please refer to
section 6.4 above for more details.
If you want to stop receiving promotional communications from us, you can click on the "unsubscribe" link
in any promotional email received from us.
How to Exercise Your Rights
You can exercise any of these rights by completing the FirePhoenix Privacy Request Form here or
alternatively, email [email protected]. We will not discriminate against you (e.g., through denying
products and services or providing a different level or quality of goods or services) for exercising any of the
rights afforded to you.
You may opt-out of receiving commercial messages from us by following the instructions contained in
those messages or by contacting Customer Support. 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.
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.8.5 Cookies
You can change your preferences with regards to cookies and other trackers at any time by clicking on the
Your Privacy Choices link at the bottom of our Website.
9 HOW WE PROTECT YOUR INFORMATION
9.1 We use physical, electronic and operational safeguards to protect the information we gather. We follow
appropriate practices for collecting, storing, and handling data, along with security measures to prevent
unauthorized access, changes, exposure, or loss of your Personal Information. We regularly review and
update our security measures to stay current with technology advancements.
9.2 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 VGW to contain and investigate the data breach.
10 HOW LONG WILL WE RETAIN YOUR INFORMATION
10.1 We will retain the categories of Personal Information listed in section 3 above for various periods of time to
reasonably fulfill the purposes specified in this Privacy Policy which will be determined based on (1) the
length of time we need to retain the information to achieve the business or commercial purpose for which it
was obtained; (2) any legal, accounting, reporting or regulatory requirements applicable to such
information; (3) internal operational needs; and (4) any need for the information based on any actual or
anticipated investigation, dispute or litigation.
10.2 We will take reasonable steps to destroy or permanently de-identify any Personal Information where:
a) we no longer need the Personal Information for any purpose for which the Personal Information was
collected; and
b) we are not required by law, a regulator or a court/tribunal order, to retain the Personal Information.
11 SHARING YOUR INFORMATION
11.1 We share your Personal Information with the following categories of third parties:
a) b) c) Affiliates – other companies in the VGW Group;
Service providers – other companies who provide services to you on our behalf; and
Third parties that interact with us in connection with the services we perform.
11.2 If we share your Personal Information with a third party, we will take reasonable steps to ensure your
information is protected to the same standards as we protect our own and prohibit them from using your
Personal Information for purposes other than those requested by us or required by law.
11.3 With Third Parties
We only share information with third parties in limited circumstances including the following:
a) b) c) d) e) f) g) when you allow us to share your information with third parties;
when providing you with products and services and notifying you about important changes or
developments to the features and operation of those products and services;
with our service providers who help us offer our services, such as companies that assist us with
things like technology, storing and combining data, processing payments and redemptions, or
providing relevant marketing and advertising for our products and services. Where service providers
use Personal Information for their own purposes, where permitted by law, such service providers will
act as the business who determines, individually or jointly with others, the purposes and means of
processing that data;
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;
when instructing and authorizing the financial institution with which a user’s account is held to
disclose any information as may be requested by a regulator in respect of the user’s account;
to enforce our terms and conditions set out on our Website, to protect our rights and property and
the rights and property of our customers and third parties, to detect fraud or other illegal activities,
and to comply with law or legal processes;
when performing web analytics to analyze traffic and player activity; andto perform customer due diligence including ID verification.
11.4 11.5 11.6 11.7 11.8 11.9 11.10 11.11 11.12 11.13 h) Google
We make available an API provided by Google Maps in order to allow you to have access to an address
auto-complete function on our 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 and Google Privacy Policy.
We make available an API provided by Google to allow you to use your Google Account to sign into the
Website. You can manage this connection at any time via your Google Account. More information can be
found here.
Google Analytics 4.
VGW uses Google Analytics to collect data (cookies, IP addresses, pixels and tags). We use this data to
understand how you use our Website so we can improve its functionality and performance, as well as for
marketing and internal business purposes.
With your consent, Google Analytics will process and collect this data. You can find out more about
Google's use of information by visiting here and you can review Google's Privacy Policy.
You can opt out of Google’s collection and processing of data by going to here.
Google Sign-In
We make available an API service provided by Google (i.e. Google Sign-In) to allow you to use your
Google Account to register and login to the Website. Google Sign-In is a secure and convenient login
option that safeguards your personal information. Google Sign-In uses secure protocols to verify your
identity without sharing your actual password with us. Your login credentials are then securely transmitted
and stored by Google in accordance with their respective Privacy Policy for registration and identification
purposes only.
If you register to the Website using Google Sign-In, the following Personal Information will be shared with
us; first and last name, profile picture and email address. We use this data solely for the purpose of
facilitating your account creation, login and providing personalized features within our Website. We will not
share this information with any third parties without your express consent.
You can manage your permissions and revoke access at any time through your respective Google account
settings or here. You also have the option to create an account with VGW using an email address and
password if you prefer not to use Google Sign-In.
Neustar
We use Neustar to assist in processing your Personal Information for marketing analytics purposes and to
better understand your interactions with our advertising.
With your consent, we will share your Personal Information (such as first name, last name, email address,
IP address and residential address) with Neustar Information Services, Inc. (“Neustar”) to be processed in
accordance with this Privacy Policy. If you do not wish for your Personal Information to be shared, you can
opt-out by clicking on the Your Privacy Choices link at the bottom of our Website and updating your
preferences.
11.14 You can also opt-out of Neustar’s processing of your Personal Information in connection with marketing
and analytics services, such as interest-based and targeted advertising, by visiting here. Further, Neustar’s
Privacy Choice Portal provides you with more information on exercising any other privacy rights you may
have.
11.15 You can find out more about Neustar’s use of Personal Information by visiting Neustar’s Privacy Policy.
Other Third Parties
11.16 We may ask you to provide your image to assist us in verifying your identity. We do this by using facial
recognition technology provided by service providers (including, but not limited to, Jumio Corporation) that
determines whether the photo you take matches the photo in your identification document. These service
providers collect information from your image capture on our behalf and may share this confirmation
information with us. We do not collect or store biometric information. Our third-party service provider stores
your biometric data in accordance with their privacy policy. They will store it until they have achieved theoriginal purpose for collecting it, or until 3 years after your last interaction with us, whichever happens first,
provided we have no other legal obligation to retain such information for any longer period.
11.17 We may also share generic aggregated demographic information not linked to any personal identification
information regarding visitors to and users of our Website with our service providers, affiliates and
advertisers for the purposes outlined above.
11.18 Transfer of data
The VGW Group operates in several international jurisdictions and Personal Information we collect may be
transferred to, and stored and processed by, affiliates within the VGW Group or service providers in the
European Union, the United States, Canada, Australia, the Philippines 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.
12 MINORS
Protecting the privacy of children is especially important to VGW. For that reason, we never knowingly
collect or maintain information from individuals under the age of 18, and no part of our Website is
structured to attract anyone under the age of 18. VGW does not offer or direct any of its services or
products, including FirePhoenix, to individuals under the age of 18.
13 13.1 13.2 13.3 13.4 CHANGES TO THIS PRIVACY POLICY
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. We will notify you of material changes and, where required by law, will obtain your
consent. Notice may consist of posting such changes on our Website or by other means in accordance
with applicable laws.
Any changes to the Privacy Policy will become effective when the updated policy is posted on our Website.
We encourage you to frequently check this page for any changes to stay informed about how we are
helping to protect the Personal Information we collect.
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
If you have specific questions regarding your Personal Information, how we process or use it, or to
exercise your rights, please contact our Privacy Team directly by email at [email protected] or
alternatively please complete the Privacy Request Form here.