PRAGMA PRIVACY POLICY
Last Updated March 3, 2025
Welcome to the website (the "Site") of Pragma Platform, Inc. ("Company", "we", "us", or "our"). Company provides products and services, including Pragma’s backend game engine services and the FirstLook.gg playtesting service (collectively, including the Site, the "Service").
This Privacy Policy explains what Personal Information (defined below) we collect, how we use and share that information, and your choices concerning our information practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.
Before using the Service or submitting any Personal Information to the Company, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.
- PERSONAL INFORMATION WE COLLECT
We collect information that alone or in combination with other information in our possession could be used to identify you ("Personal Information") as follows:
Personal Information You Provide: We collect the following categories of Personal Information from you when you enter your email to sign up for a demo. (E.G. THAT YOU ENTER ON THE "CONTACT US" PAGE OF THE SITE):
Identification Information: We collect your email address and other registration information when you enter it to sign up for our Service or a demonstration. We also collect any information that you send to us in connection with your use of a Service (e.g., feedback on playtests, or other profile information established in your FirstLook.gg account).
Internet Activity Information: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:
- Log Information : Information that your browser automatically sends whenever you visit the Site. Log Information includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
- Cookies Information: Please see the "Cookies " section below to learn more about how we use cookies.
- Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
- Email Open/Click Information: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off.
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
Advertising networks may use cookies to collect Personal Information. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative's online resources and follow the opt-out instructions there.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this information, click here .
Online Tracking and Do Not Track Signals : We and our third party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
- HOW WE USE PERSONAL INFORMATION
We may use Personal Information for the following purposes:
- To provide the Service;
- To respond to your inquiries, comments, feedback, or questions;
- To send you optional surveys from time to time to help us understand how you use or products and to make improvements;
- To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
- To send you our newsletter and other updates regarding the Service;
- To send you communications in connection with your participation on one or more playtests through the FirstLook.gg service;
- To analyze how you interact with our Service;
- To maintain and improve the Service;
- To develop new products and services;
- To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
Aggregated Information. We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.
Marketing. We may use your Personal Information to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us . If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
- SHARING AND DISCLOSURE OF PERSONAL INFORMATION
Company does not sell your Personal Information. In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:
- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Information.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
- Affiliates: We may share Personal Information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Company. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.
- Third Party Integrations. If you integrate a third-party service into your use of the Service (for example, if you choose to connect your FirstLook.gg account to a third-party application), we may share your information with that third-party to enable the integration.
- Other Users: certain actions you take may be visible to other users of the Service. For example, your posts will appear in other users' feeds and your profile information will be accessible to other users. You acknowledge that by sharing posts or adding information to your profile you make the information shared available to other users and that the Company cannot control, and shall not be responsible for any use other users make of such information.
- DATA RETENTION
We keep Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.
- CALIFORNIA PRIVACY RIGHTS DISCLOSURES
Where provided for by law and subject to any applicable exceptions, California residents may have the right:
- To know the categories of Personal Information that Company has collected about you, the business purpose for collecting your Personal Information, and the categories of sources from which the Personal Information was collected;
- To access the specific pieces of Personal Information that Company has collected about you;
- To know whether Company has disclosed your Personal Information for business purposes, the categories of Personal Information so disclosed, and the categories of third parties to whom we have disclosed your Personal Information;
- To have Company, under certain circumstances, delete your Personal Information;
- To instruct businesses that sell Personal Information to stop doing so - Company, however, does not sell Personal Information; OR To opt out: we may share Identification Information and Internet Activity Information with social media platforms and other advertising partners that will use that information to serve you targeted advertisements on social media platforms and other third party websites - under certain regulations such sharing may be considered a "sale" of Personal Information; and
- To be free from discrimination related to the exercise of these rights.
If you would like to exercise any or all of these rights, you may do so by calling (323) 347-1334 or contacting us. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you have provided the agent permission to submit the request.
Please contact uswith questions or to request access to an alternative format of this Privacy Policy.
- CHILDREN
Our Service is not directed to children/minors. Company does not knowingly collect Personal Information from children. If you have reason to believe that a child has provided Personal Information to the Company through the Service please contact us and we will endeavor to delete that information from our databases.
Please contact us if you have questions about these third parties' data practices.
In addition, parents or guardians can contact us to:
- request copies of the Personal Information we collected about their child;
- direct us to delete the Personal Information we collected about their child;
- direct us to stop collecting or using Personal Information regarding their child; and
- prohibit the disclosure of Personal Information regarding their child to third parties not needed to provide the Service.
- LINKS TO OTHER WEBSITES
The Service may contain links to other websites not operated or controlled by the Company, including social media services ("Third Party Sites"). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
- DATA PROCESSOR ACTIVITIES
This Privacy Policy does not cover information that Pragma receives as a data processor on behalf of its customers that conduct playtests through the FirstLook.gg service or that operate games on the Pragma Platform. If you are a player or user participating in a game or playtest offered by one of Pragma’s customers, and have questions about how your information is collected and processed in connection with your use of that game or participation in that playtest, please contact the publisher of the applicable game for more information.
- SECURITY
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Information to the Company via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.
- INTERNATIONAL USERS
You understand that the Service(s) are operated by Pragma in the United States and the Netherlands. By using our Service, you understand and acknowledge that your Personal Data will be transferred from your location to our facilities and servers in the United States and/or the Netherlands, where data protection laws may differ from those in your jurisdiction.
- YOUR CHOICES
In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Service, you may be unable to use those features. You can contact us to request updates or corrections to your Personal Information.
- ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN EUROPE
Data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Pragma acts as a controller with respect to personal data collected as you interact with our websites, emails, and advertisements.
If you are a data subject in Europe, we only process your personal data based on a valid legal ground, including when:
- you have consented to the processing of your personal data;
- we need your personal data to provide you with services and products;
- requested by you, or to respond to your inquiries;
- we have a legal obligation to process your personal data; or
- we or a third party, have a legitimate interest in using your personal data and your interests and fundamental rights and freedoms do not override those interests.
If you are a data subject in Europe, we will transfer your personal data subject to appropriate safeguards, such as Standard Contractual Clauses.
If you are a data subject in Europe, you have the right to:
- Request access to and receive information about the personal data we maintain about you, to update and correct inaccuracies in your personal data, to restrict or to object to the processing of your personal data, to have the personal data deleted, or to exercise your right to data portability to easily transfer your personal data to another company.
- You may request that we erase the personal information we hold about you at any time.
- Withdraw any consent you previously provided to us regarding the processing of your personal data, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.
- Lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
You may exercise your rights by submitting a written request to us at the addresses set out in the “Contact Us” section above or by contacting our Data Protection Officer atprivacy@bookend.ai. We will respond to your request within 30 days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
Please note that we retain personal data as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes of our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our policies.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to access such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. As required under the General Data Protection Regulation (GDPR), we will report any applicable breaches to you or any appropriate authorities. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.
- CHANGES TO THE PRIVACY POLICY
The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
- CONTACT US
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address:
Pragma Platform, Inc
10811 Washington Blvd
Ste 360
Culver City, CA 90232
Phone: 323-347-1334