Game Passport
Background
If you are a minor at law (which usually means you are aged
under 18 in countries including Australia and the United States, though this
age may vary depending on where you are located), you must get your parent or
guardian’s permission before providing us with any personal information. We may
collect Non-Personal Information, such as a device ID or other persistent
identifier linked to the device or computer, which may be used by a child to
play our Websites.
We will strictly comply with all relevant legislative
requirements and in the event of any inconsistency, the legislative
requirements will override the provisions of this document. The privacy of your
personal and non-personal information is afforded the highest level of
importance by Game Passport.
We may collect information regarding the device you use to
access the software, applications and/or services, including (where applicable)
its model, operating system, screen resolution and other technical information.
Collection of Information
We may collect any Personal Information that you disclose
when you choose to send a message to another user or defined group of users
through our message, chat, post or other in-game function as well as the
necessary Personal Information of the user(s) you are contacting, in order to
facilitate the communication. (We will never collect any information sent
outside of the functionality of our Websites/Apps, including through emails or
text messages).
We may collect information regarding your use of our
software, applications and/or services, including information about the duration
of your use, the features you use and your interactions with other users of the
software, applications and/or services.
Use and Disclosure of Information
Provide you with any goods, services, or functionality you
have requested; to respond to any inquiries you have made through our customer
service features, to send you newsletters, promotions or marketing materials.
We will provide you with the opportunity to opt out of receiving such materials
in the future. You may also opt out of receiving such materials at any time in
accordance with the instructions provided in this Privacy Policy.
Below are provider names of some of the third party
analytics and advertising services we use. Please see the links below to learn
more about the privacy policy of our third-party service providers.
Adcolony: http://www.adcolony.com/privacy-policy/
Kidoz: http://kidoz.net/privacy-policy/
• Google Analytics:
https://www.google.com/intl/en/policies/privacy/
• Game Analytics: http://www.gameanalytics.com/privacyAppLovin:
https://www.applovin.com/privacy
• Unity Ads: https://unity3d.com/legal/privacy-policy
• Chartboost:
https://answers.chartboost.com/hc/en-us/articles/200780269-Privacy-Policy
• Adcolony: http://www.adcolony.com/privacy-policy/
• Firebase: https://www.google.com/policies/privacy/
• Super Sonic: https://www.supersonic.com/privacy-policy/
• Heyzap: https://www.heyzap.com/legal/privacy
Leadbolt: https://www.leadboltnetwork.net/p/legal/privacy
Chartboost:
https://answers.chartboost.com/hc/en-us/articles/200780269-Privacy-Policy
Game Analytics: http://www.gameanalytics.com/privacy
Advertising
Usage Data and Non-Personal Information such as advertising
identifiers may be used to determine how many clicks an ad received, to measure
the effectiveness of ad campaigns, to determine the proper amount of repeat
views of a given ad, and/or to deliver ads that best relate to your interests.
Depending on your device and its operating system, you may be able to choose to
prevent your device’s ad By using our Website/Apps, you may be offered
advertising content. We or the ad networks we use may utilize ad-serving
technologies that use cookies, beacons, tracking pixels and other technologies
that are placed within the ads and allow us or our networks to collect
Non-Personal Information. Non-Personal Information such as age and gender may
be used to ensure that appropriate advertising is offered to you. identifier
being used for interest-based advertising or reset your device’s ad identifier
by changing the settings of your device.
Transfer of Information Overseas
What we do with the information we gather
We require this information to understand your needs and
provide you with a better service, and in particular for the following reasons:
Internal record keeping.
For better user experience, we may get the following
information
We may use the information to improve our products and
services.
Security
Your public information if social media is used in the app.
App Usage Data and User Behavior
Links to other websites
Sharing of information
Furthermore, if you have given your consent in accordance
with Section 6(1)(a) of the GDPR, we share your advertising ID to advertising
network companies for the purpose of them serving behavioral advertisements to
you within the App. We use or may use the advertising network companies.
We disclose information about you to the following
categories of recipients based on the legal bases in Sections 6(1)(b), 6(1)(c)
and 6(1)(f) of the GDPR (see a description of the legal bases above):
Your rights
. In this case, our response time can be up to three months
in total as permitted by Article 12 of the GDPR.
Right to request access
You have the right to request access into the data that we
are processing on you, see
Article 15 of the GDPR, including information about:
• the envisaged period for which the personal data will be
stored
•the purposes of the processing
•the categories of personal data concerned
• the recipients or categories of recipient to whom the
personal data have been or will be disclosed
Furthermore, you have the right to obtain a copy of the
personal data undergoing processing. Please note that the access may be
restricted due to intellectual property or trade secrets.
Advertising
By using our Website/Apps, you may be offered advertising
content. We or the ad networks we use may utilize ad-serving technologies that
use cookies, beacons, tracking pixels and other technologies that are placed
within the ads and allow us or our networks to collect Non-Personal
Information. Non-Personal Information such as age and gender may be used to
ensure that appropriate advertising is offered to you.
The right to object
You have the right to object to our processing of your
personal data on grounds relating to your particular situation when the data
are processed based on the balancing-of-interest rule in Section 6(1)(f) of the
GDPR, see Article 21 of the GDPR. In this case, we will cease the processing
unless there are compelling legitimate grounds for the processing which
override your interests, rights and freedoms or if the processing is necessary
for the establishment, exercise or defense of legal claims.
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Right to rectification and erasure
you have the right to have inaccurate personal data
rectified, see Article 16 of the GDPR.
Furthermore, you have the right to have your personal data
erased where one of the following grounds applies, see Article 17 of the GDPR:
•if you have objected to the processing and there are no
overriding legitimate grounds for the processing
•the personal data have been collected in relation to the
offer of information society services.
•the personal data have been unlawfully processed
•the personal data have to be erased for compliance with a
legal obligation in Union or Member State law
The right to withdraw consent
Please note that if you withdraw your consent, your user
license to use the App will cease automatically.
The withdrawal of your consent does not affect the
lawfulness of processing based on your consent before its withdrawal. If you withdraw
your consent, we will cease processing of the data for which you have withdrawn
consent, unless we have a legal obligation to keep some or parts of your data.
If we have asked for your consent to our processing of your
data, you have the right to withdraw your consent at any time, see Article 7 of
the GDPR.Use of information – purpose and legal basis
We use information about you for the following purposes in
accordance with the legal bases for each type of personal data as described
below:
Age
-is being processed:
a.to identify whether you are a child or adult for data
protection purposes to determine the legal requirements for our processing of your
data.
Our processing for the above purpose is necessary for
compliance purposes, see Article 6(1)(c) of the GDPR.
Log-, device-, usage-, and consumption information
-are being processed:
b.to provide and deliver the products and services you
request and send you related information as requested by you / as agreed with
you;
c.to provide and maintain the App and the game experience;
and
d.to send you technical notices, updates, security alerts,
and support and administrative messages;
f.to personalize and improve the App and provide tailored
content and features;
g.to monitor and analyze trends, usage and activities in
connection with the App; and
h.to provide children (as this term is construed under GDPR
in EU, COPPA in the US and relevant applicable legislation in other
jurisdictions) with reasonable contextual advertisements in the App.
i.to provide non-child users that have given us consent to
share their advertising IDs with our ad network partners (as further specified
under Sharing of Information) for the purpose of serving them with personalized
advertisement in the App (behavioral advertising).
Our processing for the above purpose is justified by our
legitimate interests in providing advertisements and content of interest to you
in accordance with Article 6(1)(f) of the GDPR. The disclosure of your
advertising ID to third parties for the purposes of behavioral advertising is
based on your consent in accordance with Article 6(1)(a) of the GDPR (see more
below under Sharing of Information).
Information from other sources
-are being processed:
j.to provide and deliver the products and services you
request and send you related information;
The right to withdraw consent
Please note that if you withdraw your consent, your user
license to use the App will cease automatically.
The right to restriction
You have the right to obtain restriction of processing in
certain circumstances, see Article 18 of the GDPR. If you have the right to restriction,
we will only process your data with your consent or for the establishment,
exercise or defense of a legal claim or to protect a person or important
grounds of public interest.
1. Your public information if social media is used in the
app.
2. Demographic information such as location, preferences and
interests for Re marketing purposes
3. App Usage Data and User Behavior
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