Privacy Policy

Privacy Policy

Effective date: September 21, 2022

Pipeworks, Inc. (“us”, “we”, “Pipeworks”, or alternative first-person reference) thank you for your interest in connection with our interactive entertainment products, namely our video game currently entitled “Prominence Poker” (available on the following platforms: Xbox One, Playstation 4 and Steam) (collectively the “Game(s)”). If you are here, you have either been directed here through our Game(s) or website(s): at https://www.pipeworks.com, [INSERT ANY OTHER WEBSITES AS APPLICABLE] and associated social media (collectively the “Website(s)”).

This page informs you of our policies regarding the collection, use, and disclosure of Personal Data when you use our Services, both defined below, and your rights to your data under the US and International Law, including but not limited to the EU Directive 2002/58/EC and the EU General Data Protection Regulation (“GDPR”), the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (“CAN-SPAM”), the US Children’s Online Privacy Protection Act (“COPPA”), and the California Consumer Privacy Act (“CCPA”),  and the choices you have associated with that data. This privacy policy applies to the Websites, any and all of our Games (including, without limitation, enhancements thereto or future DLC), our content, events, applications, services, patches, updates, or tools (each individually a “Service” and collectively the “Services”) where this privacy policy is referenced, regardless of how you access or use them, including through mobile devices. This Privacy Policy does not apply to any third-party websites, services, or applications, even if they are accessible through our Services.

We use your data to provide and improve the Services. This Privacy Policy is solely intended to inform you of our data collection practices and your rights to any of the data that we may collect. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service and End User License Agreement, accessible here: [INSERT LINK TO TOS]

This Privacy Policy describes:

  • The information we collect, how we collect such information, and the purposes of our collection;
  • How we use and with whom we share such information;
  • How you can access and update your information; and
  • How do we protect the information we store about you.

Disclosure to California Residents: In our efforts to comply with applicable regulations, we ask and advise that California residents review the “CCPA Disclosure” at the end of this document. Although we do not sell User data, we will provide notice if at any time those circumstances change.

Definitions

Personal Data
Personal Data means information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, directly or indirectly, by reference to an identifier such as a name, a device identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small pieces of data stored on a User’s device.

Data Controller and Data Protection Officer
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data. Where we have a legal obligation to do so, we have appointed data protection officers (DPOs) to be responsible for our privacy program. You can contact our DPO via the Contact Us information detailed below in this privacy policy.

Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject
Data Subject is any living individual who is the subject of Personal Data.

User
The User is you! The individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Information Collection and Use
We collect different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data
While using our Services or when contacting us through our Websites (for example, if you have questions about our Games or you participate in any promotions or surveys we host), we, or third parties acting on our behalf, may ask you to provide certain personally identifiable information that can be used to contact or identify you for customer support or for our e-mail updates or newsletter (“Personal Data”).

Personally, identifiable information may include, but is not limited to:

    • Email address
    • Platform account IDs and platform-specific gamertags
    • With your consent, age, gender, platform/device type, as well as other information in connection with our Game and/or your gaming habits may be collected through surveys
    • Cookies and Usage Data

We may use your Personal Data to provide customer support or to otherwise contact you with newsletters, updates, submission guidelines, marketing or promotional materials, and other information that may be of interest to you. You may opt into receiving any, or all, of these communications from us, and you may opt-out of such by following the applicable opt-out instructions provided at such time.

Usage Data
We, or third parties operating through our Services, may also collect information concerning your access and use of the Services (“Usage Data”). This Usage Data may include information such as your behavioral data and information concerning your interactions with our Games, platform/device type and usage, the time, date, and duration of your use, unique device identifiers, acquisition sources, and other diagnostic data.

Location Data
We may use and store information about your general location (“Location Data”). We use this data to provide features of our Service and to improve and customize our Service. You can enable or disable location services when you use our Service at any time, through your device settings.

Tracking Cookies Data
We, or third parties acting on our or their own behalf via pipeworks.com, use cookies and similar tracking technologies to track the activity on our Services and hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from our website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

    • Session and “Uncode” Cookies. We use Session and “Uncode” Cookies to enable interoperability with your device and to operate the Website.
    • Preference and Analytics Cookies. We use Preference Cookies to distinguish Users and individual settings and to improve Services based on your usage of our Website.

Use of Data

We use your personal information to fulfill a contract with you and provide you with our Services, to comply with our legal obligation, to protect your vital interest, or as may be required for the public good.

This includes:

    • To provide and maintain our Services;
    • To notify you about changes to our Services;
    • To allow you to participate in interactive features of our Services when you choose to do so and to the extent applicable;
    • To provide customer support; and
    • To prevent, detect, mitigate, and investigate fraud, security breaches, or other potentially prohibited or illegal activities.

We also use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests. We have implemented controls to balance our interests with your rights. This includes to:

    • To improve gameplay and delivery with regard to our Games and Services;
    • Gather analysis or valuable information so that we can improve our Services;
    • Receive and review submissions from Users for inclusion on the Websites;
    • Monitor the usage of our Service;
    • Detect, prevent and address customer support and technical issues; and
    • To enforce any Terms and Conditions with respect to our Games and Services, to the extent applicable.

With your consent, we may use your personal information to:

    • Provide you with news, special offers, and general information about other goods, and services that we offer, unless you have opted not to receive such information;
    • Provide you with updates concerning our Games or future titles;
    • Contact you in connection with prior customer support or Services you have experienced; and
    • Contact you through social media via our Service Provider, AgoraPulse, whereby such consent will be obtained through the applicable social media channel(s).

You have the right to withdraw your consent at any time.

When you submit your Personal Data through our customer support page or through social media, you acknowledge that the information may be used by Pipeworks to provide and improve our Services to you, and to contact you in connection with those Services. You will at all times retain ownership and control over your data, and you will have the opportunity to access, modify, or delete such information as set forth below. Pipeworks is not responsible for any inaccuracies in the information you provide.

Retention of Data

Pipeworks will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Pipeworks will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally or contractually obligated to retain this data for longer time periods.

Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Pipeworks will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information. The transfer of such data is typically for the purpose of fulfilling our contract with you, as specified above. Therefore, any request to delete or modify such Personal Data may result in the termination or interruption of our Services with respect to your usage of such Services.

Disclosure Of Data

Disclosure for Law Enforcement
Under certain circumstances, Pipeworks may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Legal Requirements
Pipeworks may disclose your Personal Data in the good faith belief that such action is necessary to:

    • To comply with a legal obligation;
    • To protect and defend the rights or property of Pipeworks;
    • To prevent or investigate possible wrongdoing in connection with the Services;
    • To protect the personal safety of Users of the Service or the public; or
    • To protect against legal liability.

 Change of Control
If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy policy with respect to your Personal Data. If we intend to handle your Personal Data for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your Personal Data for the new purposes.

Security Of Data
We protect your Personal Data using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards we use may include firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

“Do Not Track” Signals

 California Do Not Track Disclosure
In September 2013, California enacted amendments to the California Online Privacy Protection Act (California Business & Professions Code §§22575-22579) which require operators of websites to disclose how they respond to “do not track” (DNT) signals from browsers used by consumers or other mechanisms that provide consumers a choice regarding the collection of personally identifiable information about the consumer’s online activities over time and across different websites or online services. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

While some newer browsers have incorporated “Do Not Track” features which, when turned on, send a signal or preference to the websites you visit indicating that you do not wish your online activity to be tracked, a DNT protocol that can be implemented across multiple devices and sites has not yet been widely adopted. Currently, our computer system does not support, and cannot act on DNT signal headers that we may receive; accordingly, the choices that we provide you concerning our collection and use of personally identifiable information will continue to operate as described in this policy. For information about Do Not Track, please visit: www.allaboutdnt.org.

Your Rights

Pipeworks aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

You may update, correct, or provide additional information to your Personal Data by resubmitting your information or contacting us directly. If you are correcting information provided to a third party (such as those identified in the “Service Providers” section below – i.e., MailChimp or social media controlled or operated by Pipeworks) please correct your information via the methods and direction provided by the third party.

If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please contact us via any of the contact options provided at the end of this Privacy Policy.

You have the right:

    • To know what personal information we maintain about you;
    • To receive a copy of your personal information in a structured, commonly used and machine-readable or commonly used electronic format on request;
    • To update and modify personal information that is incorrect or incomplete;
    • To object to our processing of your personal information when the collection is based on legitimate interest; and
    • To delete or restrict how we use your personal information, but this right is determined by applicable law and may impact your access to some of our Services

Please note that we may ask you to verify your identity before responding to such requests.

How to Control Your Information

Under the EU General Data Protection Regulation, individuals residing in the EU and other territories that have adopted GDPR compliance or comparable regulation have a right to:

    • Access their User data;
    • Correct the data they have provided to us;
    • Have information provided to them in a portable format;
    • Request the deletion of the data we have collected;
    • Restrict processing; and
    • Object to processing or the legal basis on which we rely to process their data.

Please note that we may ask you to verify your identity before responding to such requests.

You may send an e-mail to danw@pipeworks.com with your request to exercise any of the rights identified above. Place the reason for your request (e.g., “Delete my Data” or “Correct my Data”) in the subject line and include your first name, last name, and e-mail address in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example, those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. If you have sent or posted content through the Services, we may not be able to delete it.

We are unable to delete data controlled solely by third parties; for example, if you purchase one of our Games through a third-party platform such as Xbox or Playstation, we will not be able to delete your Game from your library, nor the data collected by such platform in connection with your purchase or your platform account. Similarly, if you access any our of Services through third-party social media or service platforms, or if you are routed to a third-party service provider’s website through our Services, you will need to make any deletion requests to those respective third parties separately.

Social Media Communications

You may be able to take part in certain activities through our Services that give you the opportunity to communicate or share information not just with Pipeworks, but also with other Users of our Services, generally by engaging with official Pipeworks social media accounts. We are not responsible for your use of those services. If you communicate to us or other Users publicly via our social media accounts, you are strongly encouraged to review the privacy policies of those services if you have questions about the use of your data. We only access the information you make available to the public on our social media pages and do not receive any information concerning your social media account from any social media platform.

Service Providers

We may employ third-party companies and individuals to facilitate our Services (“Service Providers”), to provide the Services on our behalf, to perform Service-related services, or to assist us in analyzing how our Services are used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Web Services, Payment Processing and Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

MailChimp

We collect your e-mail, name, and location when you sign up for our newsletter through MailChimp on the Website. The information collected is retained by MailChimp’s database, which may be made accessible to us. For more information concerning MailChimp’s data collection practices and protection, please visit their privacy policy at: https://mailchimp.com/legal/privacy/

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms website: https://policies.google.com/privacy?hl=en-US

YouTube
Our website may from time to time embed videos from YouTube. In such event YouTube may send cookies to your device to enable viewing of any videos embedded on the Website. YouTube is a subsidiary of Google: For more information on Google’s privacy practices, please see the link provided above.

AgoraPulse
AgoraPulse allows Pipeworks to interact with all of our social media channels and networks through a single dashboard. If you interact with Pipeworks via social media (including “following” or subscribing to any social media “feed”), those social media networks may share your social media account information with us so that we may respond to inquiries or customer support questions through those networks. For more information about AgoraPulse’s privacy practices, please visit the AgoraPulse Privacy Policy website: https://www.agorapulse.com/privacy-policy

Microsoft
For more information about Microsoft’s privacy practices, please visit the Microsoft Privacy Policy website:https://privacy.microsoft.com/en-us/privacystatement

Survey Monkey
In the event you agree to participate in one of our surveys, we may ask you to provide your age, gender, platform/device type, as well as other information in connection with our Game and/or your gaming habits. The information collected is retained by Survey Monkey’s database, which may be made accessible to us. For more information about Survey Monkey’s collection practices and protection, please visit the Survey Monkey Privacy Notice at: https://www.surveymonkey.com/mp/legal/privacy/

Links To Other Sites
Our Service may contain links to other sites that are not operated by us, including advertisements provided by our ad providers. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

Children’s Privacy

Our Services are intended for a general audience and are not intended for children. However, we take children’s privacy very seriously, and we do not knowingly collect any Personal Data from Users deemed to be children under their respective national laws through our Services. We strive to comply with the Children’s Online Privacy Protection Act of 1998, the US law that protects the privacy and information of children. We strongly encourage parents and guardians to learn more about this important regulation. For more information, you can visit: https://epic.org/privacy/kids/#introduction. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

If you are under the age of 13 and using our Services, please have a parent or guardian nearby to provide any information we may request, including an e-mail address if you are subscribing to our mailing list.

That being said, we understand that children may use our Services without directly providing personal information. We may allow third parties to place and read their own cookies and similar technologies to collect information through our Services, including helping with analytics or facilitating transactions. You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). If you choose to refuse, disable, or delete these technologies, some of the functionality of our Websites may no longer be available to you or your child.

Note regarding do-not-track signals and similar mechanisms: Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether Users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

  • Reach our Data Protection Officer by email: danw@pipeworks.com
  • By visiting this page on our website: https://www.pipeworks.com/
  • By phone number: 1+ (541) 393-3500
  • Or by mail at:

Pipeworks, Inc.

Attention: Dan White

133 W Broadway
Eugene, OR 97401

California Consumer Data Rights

Pipeworks, Inc. complies with the California Consumer Privacy Act of 2018 (CCPA), effective January 1, 2020. This landmark piece of legislation secures new privacy rights for California consumers.

Categories of Data We Collect and Their Uses

In addition to the details provided in our Privacy Policy, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

Category Examples Collected Reason for Collection Info “Sold” to 3rdPty?
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Yes

We collect platform specific account ids and gamertags to connect Users to their data in our database for purposes such as in-Game leaderboards, as well as platform/device types (such as Steam, Xbox and Playstation 4) and analytical data, which we may use in the aggregate to make future business decisions.

 

We also collect e-mail addresses for customer support and our newsletter.

No
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. No N/A N/A
Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Yes We may collect age and gender through our provision of surveys which Users can opt into participating in. N/A
Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes

We collect records of all in-Game purchases to ensure Users receive the digital products or services they purchase, and for analytical purposes.

 

No
Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No N/A N/A
Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes

We save a history of Users’ interaction within our Games, such as when purchases are made, the duration a User plays a Game and Gameplay metrics.

 

No
Geolocation data. Physical location or movements. Yes

We ascertain the country that a User last connected from to inform our sales and community event strategies based on time zone/country of origin.

 

No
Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. No N/A N/A
Professional or employment-related information. Current or past job history or performance evaluations. No N/A N/A
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No N/A N/A
Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes We collect analytical data to track User trends in our Games which we may use in the aggregate to make future business decisions. We also collect information in connection with our Game and/or your gaming habits through surveys for the same purpose.

Personal Information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of Personal Information listed above from the following categories of sources:

    • Directly from our Users. For example, customers who sign up for our mailing lists, engage us for customer support, or provide customer feedback.
    • Indirectly from our Users. For example, through information, we collect from our Users in the course of providing customer support to them.
    • Directly and indirectly from activity through the Services. For example, from cookies and Usage Data (described above) embedded in our Services, as applicable, and other information related to improving our products and Services.
    • From third parties that interact with us in connection with the Services we perform.

All such Personal Information is used as otherwise described above in our Privacy Policy.

Sharing Personal Information

We may disclose your Personal Information to a third party for business purposes.  When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

That being said, in the preceding twelve (12) months, we have not disclosed any Personal Information for business purposes.

Your Rights and Choices

 Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

    • The categories of Personal Information we collected about you;
    • The categories of sources for the Personal Information we collected about you;
    • Our business or commercial purpose for collecting that Personal Information;
    • The categories of third parties with whom we share that Personal Information; and
    • The specific pieces of Personal Information we collected about you (also called a “data portability” request).

We generally do not sell User data. However, if we do sell your Personal Information for a business purpose, we will also disclose to you:

    • The Personal Information that each category of recipient purchased; and
    • Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Service Providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:

    • Complete any transaction for which we collected the Personal Information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
    • Debug products, including our Websites and Games, to identify and repair errors that impair existing intended functionality;
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent;
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
    • Comply with a legal obligation; or
    • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at: 1+ (541) 393-3500
  • Sending us a letter at:

Pipeworks, Inc.

Attention: Dan White

133 W Broadway
Eugene, OR 97401

Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period. The verifiable consumer request must:

    • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt.  If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

    • Deny you goods or services;
    • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
    • Provide you a different level or quality of goods or services; or
    • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.