Privacy Policy

Digital Risk Resources Game Division
Website Privacy Policy

 

Date:  November 19, 2018

 

Digital Risk Resources, LLC (DRE) enables insurance companies to offer a suite of cyber insurance products and services under their brands.  We help insurance companies offer coverage to various markets and help process claims.  As part of DRE’s service to insurance companies, DRE provides privacy risk and awareness training.  The DRE Game Division has developed games to help train users on security topics.  DRE’s “gamification” training platform gives end users, through the use of “game play,” an awareness of privacy and security risks that helps them understand security risks and enables them to be safer online.  DRE’s web and app-based games teach end users about security and privacy risks related to digital, media, and other technology.  DRE offers games that operate on personal computers and popular mobile devices.

 

This policy covers DRE’s privacy practices for the websites where its games are offered and the game apps offered on mobile operating system app stores.  The policy covers how DRE’s websites and game apps collect, use, communicate, and disclose various categories of personal information.  Any third party sites or apps of partners or other businesses have their own privacy policies and your use of such other sites or apps is subject to their privacy policies. 

 

DRE’s games are exclusively licensed from Up&Atom! Technology Ventures, which developed, published, and maintains the games offered by DRE.

 

1.     What Kinds of Personal Information and Other Data DRE Collects
 

When registering to use a game, whether on a game website or via an app, DRE collects an email address and an identifier from each user for the purpose of confirming completion of a game and sending the user a certificate of completion.  The identifier may be a user’s insurance policy number, a number assigned to a group of users, or an identifier supplied by DRE specifically for use of its games.  DRE may also collect a user-designated name for some games for display on the game’s leaderboard.  Submission of a name is optional, and pseudonyms are permitted.  DRE does not collect any other personal identifiers.
 

DRE also collects analytic data regarding users playing the games.  In particular, DRE makes use of a service provided by Unity Technologies ApS (Unity) to compile and analyze analytics. We will collect player scores, level or game completion times, and quiz responses/results for purposes of creating leaderboards and analytics usage and player behavior data related to game play. We use Unity’s Unity Analytics service to gather data about how our games perform on a player’s device.  This information does not include personal identifiers.  But it does include information such as data on where the game was downloaded from, usage data, performance data, and crash reports.  This collected information helps us to fix bugs and improve our games.  
 

As more specifically stated in Unity’s FAQ, the Unity Analytics service helps collect the following kinds of data on an aggregate basis, which we do or may in the future collect from DRE game users:

  • Core data about the usage of the game
    • New installations of the game
    • Numbers of active users over certain time periods
    • Sessions played (total and per user)
    • Time spent playing
    • Location of the users
    • Computing platforms used by users
  • Player behavior data
    • Registration
    • How far users progressed in the game
    • Economy (allocating game and bonus points to ensure players receive proper credit)
    • Data about game play to show the effectiveness of the design of the game and the way the application works, for instance, to make sure players are using the game features as expected
  • Revenue data from in-game purchases

This data does not identify any users personally, but rather is aggregate data about groups of users playing particular games or belonging to certain groups.
 

In addition, DRE collects personal information from website visitors.  DRE will collect the personal information of website visitors who complete web forms to communicate with us.  DRE’s web form collects information such as name, email address, subject (the reason for the communication), and phone number, all of which must be supplied for the communication to be sent to DRE.  Optional information that users may send to us are company name, job title, and any information that the user includes in the “Message” field where the user will supply specific information about the user’s inquiry or topic of interest.
 

We may add to the information we collect from our games and website with information you provide to us in other ways, such as information you post on our social media accounts or send to DRE via email or message on a social media platform.
 

2.     Notice Concerning “Do Not Track” Settings to California Residents
 

Under California law, online service providers must state how they respond to “do not track signals” in their privacy policies.  “Do not track” signals are settings in browser software that users can set to request that service providers not track their activities.
 

At present, there are no standards regarding what online service providers should do in response to these signals.  Accordingly, DRE does not currently take action based on these browser settings.  We may revisit our policy on “do not track” settings in the future if and when our industry establishes a standard regarding responses to “do not track” settings.

 

3.     Use of Personal Information and Collected Data
 

We use the personal identifiers, email address and personal identifiers collected in connection with registration for a game, solely to deliver certificates of completion to individual users and to show how users as a whole or as groups play DRE’s games.
 

As a general matter, we may also work with our business partners and customer to deliver in-app advertisements to our game users that are relevant to their interests.  See Section 4 for more details.
 

In addition, we use collected game data on an aggregate basis to fix bugs in the games and improve the games.
 

DRE uses information you give to us via our website form, social media platform, or other messages to communicate with you, such as to answer any questions a user sends us or otherwise respond to a user.  We will also use this information to tell users about DRE’s product and service offering.

 

4.     Sharing or Disclosing Your Personal Information
 

DRE works with Unity, which helps us collect data about the usage of our games.  We also share aggregated game analytics data with potential customers and business partners to provide insight about usage of the game and factors such as user adoption, user behavior, and engagement including.  Our customers and business partners include insurance companies (such as Aspen Insurance Holdings Limited), employers, schools, insurance third party administrators, and distributors.
 

We have an agreement with Unity regarding use of the data it collects.  Moreover, any customers or business partners having access to collected data will also have an agreement with DRE.  These agreements contain confidentiality restrictions requiring these businesses not to disclose the data we have shared with them, to use the information received from us only for purposes of our relationship with them, and to adhere to the practices described in this privacy policy.
 

We may disclose the personal information we collect and the other collected data about use of our games when required by a subpoena, court order, search warrant, other legal process, requests by law enforcement agencies, or applicable law.  Also, we may disclose your personal information and data collected about your game usage to maintain the security of our games, resolve disputes, or investigate misuse of our games.

 

We are not in the business of selling or renting personal information we have collected to anyone.  We may, however, share information as described above.   We may also sell, transfer, or otherwise share some or all of DRE’s assets, including your personal information and data collected about game usage, in connection with a merger, acquisition, reorganization, or sale of assets of our business, or in the event of bankruptcy.  Finally, We reserve the right to fully use and disclose any information that is not in personally identifiable form.

 

5.     Safeguarding Collected Personal Information
 

DRE maintains reasonable and appropriate administrative, technical, and physical safeguards to:

  • Provide assurances of the confidentiality and integrity of the personal information and game data we collect,
  • Protect against reasonably anticipated threats to the confidentiality or integrity of the personal information and game data in our possession, including unauthorized access or use, and
  • Require compliance with our privacy and security practices by DRE personnel and third parties that have received access to personal information and game data that we have collected.

DRE uses industry standard encryption to encrypt data in its database of information collected from users and for transmitting such information between the database and the application platforms or when communicating results of DRE’s analytics.

 

6.     Access to Information and Making Changes
 

If you have played or signed up to use our games or submitted a web form message to us, and wish to access the personal information we have on record about you, please contact us at gamesupport@digitalriskre.com or the postal address listed in Section 7.  Please also direct any request to delete, correct, or update personal information to us at that email or postal address.

 

7.     Contact Information and Resolving Disputes
 

If you have any questions about our privacy policy or wish to discuss anything about it or DRE’s privacy practices, please write to our support team at gamesupport@digitalriskre.com.  You may also write to us at the address below.
 

Address: 

Digital Risk Resources                                    
459 Portland Street – Suite 202

St. Johnsbury, VT 05819

Attention:  Privacy Support

 

If you have a complaint about this privacy policy or DRE’s privacy practices, please contact us by email or postal mail using the above contact information.  When our privacy team receives your complaint, it will conduct an investigation of your complaint and provide a prompt response that will discuss the resolution of your complaint.  Please provide us sufficient information about your complaint and any supporting evidence so that we may fully evaluate your complaint.  Our privacy team may ask you for additional information relating to your complaint.


8.     Changes To This Privacy Statement
 

DRE reviews this privacy policy periodically.  We reserve the right to amend this policy from time to time.
 

If we amend this privacy policy, we will post a new version of it to our website and our apps will be linked to the new policy.  Your continued use of the DRE online games or apps or DRE’s website after a new policy is posted constitutes your continued agreement to the terms of this privacy policy as amended.  Please review the latest version of the privacy policy to review the latest statement of our privacy practices for handling your personal information.