Effective Date: May 18, 2018
· Information We May Collect
· Information You Provide
· Information Collected From Your Devices
· Cookies and Similar Technologies
· Information Collected From Other Sources
· How We Use Information
· How We Share Information
· Interest-Based Advertising
· Your Rights and Choices
· Data Retention
· Use By Minors
· Legal Basis for Processing Personal Information (EEA Players Only)
· EU-US and Swiss-US Privacy Shield Principles
· Contact Us
Information We May Collect
We may collect various types of information, including information you provide or make available to us directly, information collected from your devices (including web and mobile), and information collected from other sources, like social networking sites and gaming partners.
Information You Provide
You may provide information directly to MindKick when you:
· Use or access the Services, including when you create a MindKick Account (as defined in our Terms) or make in-app purchases;
· Connect with or access our Services using a third party ID or log-in, such as an ID for a social networking site or gaming service;
· Contact others using our Services, including when you use chat, “tell a friend,” “email this page,” or other similar features;
· Contact us, including for customer or technical support;
· Register for MindKick offers, contests, or special events;
· Subscribe to newsletters; and/or
· Complete surveys sent by us or on our behalf.
Depending on how you choose to use the Services, this information may include things like your first and last name, user name or handle, third party service ID, email address, phone number, photo, avatar or other image, date of birth, gender, purchase or payment information, address or shipping information, chat data, friends’ names and contact information, and location information.
Information Collected From Your Devices
We may collect information from and about the devices used to access our Services. This may include IP address, hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information. Depending on how you access the Services, we may also collect browser type, Internet service provider, referring/exit pages and URLs, clickstream data, non-precise geolocation, game scores and achievements, and other information as reasonably required to offer and enhance our Services. With your permission, we may collect more specific geolocation information to optimize your experience, such as for localization and language display, or to offer relevant advertising. You may limit sharing of this information at any time by changing the relevant preferences and permissions on your mobile device.
Cookies and Similar Technologies
Information Collected From Other Sources
We may also collect information about you from other sources, including from partners or service providers, publicly available sources, feedback from other players, or social networking sites as described below. We may combine this information with other information in our possession, which helps us to update, enhance, and analyze our Services, and provide tailored experiences for you.
How We Use Information
We may use the information we collect for a number of purposes, including to:
· Perform internal operations necessary to develop, provide, maintain, and improve our Services, including troubleshooting, providing customer and technical support, and conducting data analysis, testing, and research;
· Understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns), as well as offer discounts or personalized pricing;
· Maintain the safety, security, and integrity of our Services, for example by authenticating users and providing account security and fraud detection;
· Send you newsletters and/or marketing communications (by email, phone, or text), including information about MindKick or third party offerings we think may be of interest to you;
· Administer contests, surveys and sweepstakes you enter, and notify contest winners and award prizes;
· Fulfill a purchase or send you order confirmations or other requested product or Service information;
· Facilitate your communication with other users and buddies, and enable features that allow you to share information with other people (for example, if you choose to use friend referral features); and/or
· Comply with legal requirements and/or to investigate or address claims or disputes relating to your use of the Services.
How We Share Information
We may share the information we collect about you in various ways, including:
· With vendors, consultants, business partners, payment processors, and other service providers as necessary to carry out work on our behalf or otherwise provide the Services;
· With partners offering co-branded services or games;
· With other players, to enable you to interact with them and to share gameplay-related data such as high scores and other leaderboard information;
· With the general public, if you choose to share information when contributing content to our Services through a forum, blogs, social features, or the like;
· With the public or with social media friends, where you choose to take advantage of social sharing features or related tools that let you share actions you take on our Services;
· With others who share your device, if you make your Account available to them through that device;
· With specific third parties if we believe disclosure is required by applicable law, regulation, or legal process;
· With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our terms or other policies, and/or are fraudulent or in violation of applicable law, or as we determine necessary to protect the rights, property, or safety of MindKick or others;
· In connection with a merger, consolidation, restructuring, sale of company stock and/or assets or other corporate change, including during the course of any due diligence process;
· In an aggregated and/or anonymized form that cannot reasonably be used to identify you; and/or
· With your consent, provided that you may later limit this sharing by emailing firstname.lastname@example.org
· We do not share your personal information with third parties for their direct marketing purposes unless you give us permission to do so.
We work with third party advertising partners like Google, Facebook, and their partners. We may share certain of your information with these partners to make advertising more relevant, measure its effectiveness, and help recognize your devices and serve ads. We or they may also employ cookies or similar technologies, as described above, to ensure appropriate advertising and personalized experiences. Please note that our ad partners may combine your information with other information they have independently collected, and may treat that information in accordance with their privacy policies.
If you prefer to opt out of having your web viewing behavior used for interest-based advertising, you can learn how to do so by clicking here, or if located in the EU, by clicking here. If you would prefer to opt out of having information about your mobile app usage used for interest-based advertising, you may do so through your device settings (“Limit Ad Tracking” on iOS and “Opt Out of Ads Personalization” on Android). Please note that you may continue to receive generic ads that are not based on your preferences.
Your Rights and Choices
You can manage your information as described in this Policy, and you may have additional rights related to that information as described below. You can exercise these rights by opening a help ticket directly in-game via the Help section, or by emailing MindKick at email@example.com. Please note that we will need sufficient information establishing your identity in order for us to fulfill your request. Where we can validate your identity, we will process any such request within a reasonable timeframe and in accordance with applicable law.
Accessing, Updating, or Correcting Your Data
You are expected to maintain accurate, complete, and up-to-date information in connection with your Account, but we provide you functionality to update or correct your information directly in-app. You can also access a range of information in-app, including things like your user name, picture or avatar, social log-in, game performance and progress, Virtual Items, chats, or other information you may have entered in-app. For any information are not able to access or update directly, please open an in-game help ticket via the Help section for that particular game, or contact firstname.lastname@example.org
Deletion of Your Data
Email, phone, and text: We may contact you at the email address(es) or phone number(s) provided in connection with your Account. You may opt out of these messages by following the unsubscribe instructions in the message (e.g. by tapping an unsubscribe link or replying “STOP”) or by contacting us at email@example.com
Push: In connection with certain Services, you may choose to opt in to receiving push notifications. If you no longer want to receive them, you can turn them off at the device level.
Cookies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
In some cases, particularly if you are a resident of the EU, you may have the right to object to or restrict processing of your personal information, which you can exercise by opening a help ticket directly in-game or by contacting us at firstname.lastname@example.org. If we have collected and process certain types of personal information with your consent, you may withdraw that consent in the manner described when you provided consent. Withdrawing your consent will not affect the lawfulness of any processing conducted prior to then, nor will it affect any processing based on lawful grounds other than consent.
In some cases, you may have the right to file a complaint with a data protection authority about our collection and use of your personal information. For more information, contact your local data protection authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us.
We may retain personal information where required by law or where we have an ongoing legitimate business need to do so. For example, we may retain such information to provide you a service you have requested, to comply with applicable legal, tax or accounting requirements, or where necessary for fraud prevention, dispute resolution, enforcement of our contracts and terms, or for safety reasons (e.g., we may retain certain information about an Account to prevent that user from opening a new Account). When we no longer have an ongoing legitimate business need to process your personal information or a legal obligation to retain it, we will either delete or anonymize that information or, if this is not possible (for example, because it has been stored in backup archives), then we will securely store that information and isolate it from any further processing until deletion is possible.
We follow generally accepted industry standards and maintain reasonable safeguards designed to secure and prevent unauthorized access to the information in our possession. Some of the safeguards we use include firewalls and data encryption. Personal information is stored in secure operating environments, and only those at MindKick with a legitimate business need to do so may access your personal information. We also take reasonable steps to assure that third parties to whom we transfer information will provide protections appropriate to that type of information. If you have reason to believe that your interaction with us is no longer secure, please immediately contact us.
Use by Minors
We do not knowingly collect or process personal data from or about, or direct or target interest-based advertising to, anyone under the age of 13 (or under the age of 16 for those in the EU), nor do we knowingly allow such individuals to use our Services. If you believe we might have any data from or about a child under this age, please contact us. If we learn that we have inadvertently gathered such information, we will delete it.
Legal Basis for Processing Personal Information (EEA Players Only)
If you are from the European Economic Area, our legal basis for collecting and using your personal information will depend on the type of information and the context in which we collect it. In general, we collect personal information from you only where we have your consent to do so, where we need it to perform a contract with you, or where it is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need it to protect your vital interests or those of another person. If you have questions about the legal basis on which we collect and use your information, please contact us.
EU-US and Swiss-US Privacy Shield Principles
We comply with the EU-US and Swiss-US Privacy Shield Principles regarding the collection, use, sharing, onward transfer, and retention of personal data received from the European Union (EU) and Switzerland, as described in our EU-US and Swiss-US Privacy Shield certifications. Privacy Shield participants are subject to the regulatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal data from the EU or Switzerland to third parties outside the EU and Switzerland.
If you have a Privacy Shield-related complaint, please contact us. If you feel your complaint remains unresolved after doing so, you may contact our US-based third party dispute resolution provider (free of charge) here. Under certain conditions more fully described here, you may be entitled to invoke the Privacy Shield arbitration process when other dispute resolution procedures have been exhausted. In certain situations, MindKick may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have questions or concerns about this Policy or our data practices, you can contact us by email at email@example.com, or by postal mail at: MindKick, Inc., Attn: 1745 Saratoga Ave suite 205, San Jose, CA 95129 If we receive a formal written complaint from you, we will attempt to contact you directly to resolve your concerns. If you have an unresolved privacy or data use concern that you feel we have not addressed satisfactorily, you may contact our US-based third party dispute resolution provider (free of charge) here.
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