Last revised: January 30, 2019
If you sign up for any of our Services, we process your personal data in order to perform our contractual obligations towards you;
If we have a legitimate interest in processing data, such as for direct marketing or online identifiers when you access our website or Services; or
We will also process your personal data where you have provided us with consent to do so.
What information do we collect?
We collect two types of information from our Users:
The first type of information is information that identifies or may reasonably identify an individual reasonable effort (“Personal Information”). Personal Information which is being gathered may consist of the following:
Contact details: you may voluntarily provide us with certain contact details, such as your full name and email address.
Voluntary information: We also collect information which you provide us voluntarily. For example, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services, such as on the chat feature and in games.
Device information: we collect specific types of connection details and information with regard to your device, software or hardware that may identify you, such as: device’s unique identifiers (e.g. UDID, IMEI, MAC address), browser fingerprinting, IP address and geo-location data.
Social networks: when you voluntarily decide to register through your social network account (such as your Facebook account), we will have access to basic information from your social network account, such as your name, birthdate, profile picture and friends’ list, as well as information you made publicly available on such account.
The second type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via the User’s use of the Services (“Non-Personal Information”).
Non-Personal Information which is being collected consists of technical information and aggregated usage information, and may contain, among other things, the User’s operating system, type of browser, screen resolution, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User visited the Services and related time stamps, etc.
For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
Types of Non-Personal Information we collect from or about you:
Technical information: In order to enhance the functionality of the Services and to provide you with a better user experience, we collect technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.). This information also includes anonymous online identifiers, such as the Google Advertising ID and the IDFA.
Device and app information– this category includes your device’s type and model, system language, the device’s operating system (such as Android or iOS), SDK version, mobile carrier name, mobile browsers installed on the device (such as Chrome or Safari), app history and usage information (such as information about running and installed apps on the device), information regarding downloads and installations of mobile applications and any information regarding in-app events (such as in-app purchases), and anonymous identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Google Advertising ID, or other types of device identifiers.
Location information– we collect information about your general location (such as city and country). For example, we may use the IP address to identify your general location. This information does not tell us where your device is precisely located. This information is sent as a normal part of internet traffic. In addition, we also collect implicit location information, which allows us to infer that you are either interested in a place or that you might be at the place – this information does not actually tell us where your device is precisely located.
Ad information– this category includes information about the online ads and personalized content we have served (or attempted to serve) to you. It includes things like how many times an ad has been served to you, what page the ad appeared on, whether you viewed, clicked on or otherwise interacted with the ad, ad engagement history and whether you visited the advertiser’s website, downloaded an app or purchased the product or service advertised.
Log and analytics information: we collect information about your use of the Services, such as applications’ usage, log files, user activity (e.g. referral URL, pages viewed, the amount of time spent on particular pages, online browsing, clicks, actions, etc.), time stamps, alerts, etc. This information is collected for amongst other things troubleshooting errors and bugs as well as for research and analytics purposes about your use of the Services.
How we use the collected information?
We use your Personal Information for the purposes listed below:
To provide and operate the Services, such as to provide our clients with performance marketing, online user acquisition network, online promotions, and for the purposes of user attribution;
To communicate with you and to keep you informed of our latest updates to our Services and special offers;
To market our Services (see more below under “Marketing”), as well as to serve you advertisements, including behavioral advertising;
To conduct analytics, statistical and research purposes, in order to improve and customize the Services to your needs and interests (such as by compiling aggregated reports about the usage of certain features of our Services);
To support and troubleshoot the Services and to respond to your queries;
To enable us to further develop, customize and improve the Services based on Users’ common preferences and uses;
To identify and authenticate your access to certain features of the Services;
To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services, including by identifying risks associated with your activity on our Services;
To investigate violations of our policies and User Agreement as well as enforce our policies and the User Agreement;
To investigate and resolve disputes in connection with your use of the Services; and
As required by law or regulation, or as required by other governmental authorities, or to comply with a subpoena or similar legal process or respond to a government request.
We may ask you to participate in surveys (processed by us or third parties) that help us understand your use of the website and improve our advertising. Any Personal Information provided to us (or supplied by you or us to such third-party survey providers) in connection with these surveys will only be used in relation to that survey.
The Company will use your Personal Information, such as your name, home address, email address, telephone number etc., ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning the Services as well as products, services, websites and applications which relate to: (i) other companies within the Company; or (ii) the Company’s business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We may also share and disclose Personal Information with our Marketing Affiliates for the purpose of providing you different marketing offers, which we, or our Marketing Affiliates, believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, post, SMS and telephone marketing purposes.
You may at any time decline receiving further marketing offers from us or from our business partners and marketing affiliates by contacting us at to email@example.com. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
We share Personal Information with any of the following recipients:
Our clients that deploy our Services on their online properties (such as websites and mobile apps); this includes our clients whose websites or apps you have visited, as well as an advertiser whose site or app you have visited – we share information about how you have interacted with such websites or apps.
Companies within the Company and other affiliated companies;
Subcontractors and third party service providers, as well as their subcontractors, which by way of example include (but is not limited to) cloud computing companies, marketing affiliates, identity verification and fraud prevention services, and other data verifiers;
Auditors, contractors or advisers of any of the Company’s business processes;
To any third parties who investigate, detect or prevent fraudulent or illegal activity (e.g. governmental authorities, police, banks and other investigatory organizations);
Licensing authorities, governmental and regulatory bodies, in accordance with applicable laws and regulations; and
Storing such information on our behalf, for example by using cloud computing service providers;
Processing such information to assist us with our business operations (e.g. to process payments and your deposits; authenticate your access; auditing our operations; detect and prevent fraudulent or illegal activity; etc.);
Performing research, technical diagnostics or analytics (such as for geo-location);
Communicating targeted advertising, as well as promotional and informational materials, in accordance with our marketing policy (see below, under “Marketing”); and
Transfer of information
Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union.
Third party tracking technologies
When you visit or access our Services (for example when you visit our websites), we use (and authorize third parties to use) web beacons, cookies, pixels, scripts, tags and other technologies (“Tracking Technologies“).
The Tracking Technologies allow us to automatically collect information about you and your online behavior, as well as your device (for example your computer or mobile device), for different purposes, such as in order to enhance your navigation on our Services, improve our Services’ performance and customize your experience on our Services. We also use this information to collect statistics about the usage of our Services, perform analytics, deliver content which is tailored to your interests and administer services to our Users, advertisers, publishers, customers and partners.
Third party services
You should always review their privacy practices carefully before providing Personal Information to such third parties.
You are knowingly and voluntarily assuming all risks of using any third-party websites, services or applications. You agree that we shall have no liability whatsoever with respect to such third party sites and your usage of them.
Retention of personal information
If you have registered with an account through our Services, the Company will retain your Personal Information during the period your account is active. In addition, the Company will retain your Personal Data for additional periods, to enable the Company to meet its legal obligations under applicable laws or regulations, Know-Your-Customer and Anti-Money Laundering regulations.
In addition, the Company may retain your Personal Information for longer periods, provided that retaining such information is necessary for the Company’s legitimate interests, such as fraud prevention and record keeping.
If you reside in the EU or in other jurisdictions that afford you with the below rights, you may contact us at any time by email (at: firstname.lastname@example.org), and request:
To access or delete any Personal Information relating to you
To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);
That we will restrict or cease any further use of your Personal Information;
That we will provide the Personal Information you volunteered to us in a machine-readable format.
Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including any ethical reporting or document retention obligations. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.
How we keep your information secured?
We take great care in implementing and maintaining the security of the Services and your information. We have put in place appropriate physical and technological safeguards to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
We employ industry standard procedures and controls to ensure the safety of our users’ information, such as:
Secure network topology, which includes intrusion prevention and Firewall systems;
Authentication and Access Control;
External and Internal audit tests; etc.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
How to contact us
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at email@example.com or by sending a letter to:
Michael Steele, 151 West Hastings St 6th Floor, Vancouver, BC V6B1H4
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.
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