Effective Date: 25th May, 2018
Creative Mobile designs, develops, and publishes fun games for play on various computing devices including smartphones, tablet PCs, and traditional desktop computers with internet access. To provide our players with the best possible experience, we also offer certain related services such as providing forums, fan pages, and various promotions. For the purpose of this Policy, all of our products and related services, including the services recited above in this paragraph are referred to as “Products and Services.”
We recognize that our Users value their privacy, and we thus view the safeguarding of your private information as a serious matter. We encourage all of our users to carefully read this Policy before playing any of our games or using any other Products and Services. Please note that by downloading or installing a game, or by registering with us using any of our available platforms (including mobile, social media, or otherwise), or using any of our Products and Services, you consent to our collection, storage, use, or disclosure of your information according to this Policy.
This Policy will remain in full force and effect, even if your use of our Products and Services, features, functions or promotional activities terminates, expires, ceases, is suspended or deactivated for any reason. If you do not agree with this Policy, please do not use any of our Products or Services.
This Policy applies regardless of the computing device you use to access our Products and Services and whether you are accessing such Products and Services as a registered user or otherwise. This Policy governs only the information collected by us and does not cover any other information collected in any other manner or collected by any other entity, unless specifically stated herein. We may combine your information with other information we collect from other sources, such as information received from our affiliated companies, marketing companies or advertisers, and if we do so, our use of the resulting combined Information will be subject to this Policy.
1. What type of information do we collect?
2. What specific information do we collect and where do we collect information?
3. How do we use collected information?
4. With whom do we share collected information?
5. What are your choices regarding collection, use and distribution of your information?
6. How can you update, correct, or delete your Personally Identifiable Information?
7. What security precautions are in place to protect against the loss, misuse, or alteration of your information?
8. Do we use “cookies”?
9. What should you know about privacy policies and data collection at any third party websites accessible from our Products and Services?
10. How are links treated?
11. Is information from children collected?
12. What else should you know regarding privacy online?
13. Miscellaneous items.
1. WHAT TYPE OF INFORMATION DO WE COLLECT?
To best provide you with our Products and Services, we collect two types of information about our Users known as (a) Personally Identifiable Information (“PII”) and (b) Non-Personally Identifiable Information (“NPII”) PII and NPII is collectively referred to herein as “Information”. Our primary goal in collecting Information from you is to provide you with a smooth, efficient, and customized experience.
A. Personally Identifiable Information. This refers to information that may be used to ascertain an individual’s identity. When you engage in certain activities related to our Products and Services, such as registering for a membership, ordering a product or service, submitting content and/or posting content in discussion forums or other public areas, entering a contest or sweepstakes, filling out a survey, or sending us feedback, we may ask you to provide certain information about yourself by filling out and submitting one or more online forms. It is completely optional for you to engage in these activities. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
B. Non-Personally Identifiable Information. This refers to information that does not by itself identify a specific individual. We gather certain information about Users in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the Web site’s Uniform Resource Locator (“URL”) that you just came from, which URL you go to next, what browser you are using, and your Internet Protocol (“IP”) address. A URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet. This information may further include locational data transmitted via your mobile device’s beacon, GPS, or Wi-Fi signals.
We share data we collect about you including unique identification numbers associated with mobile devices (including, for example, a Unique ID for Advertisers (“IDFA”), Unique ID for Vendors (“IDFV”), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, and, depending on the user’s mobile device settings, the geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of the mobile device (“User Data”), device-specific information, such as the hardware model, operating system version, advertising identifier, unique application identifiers, unique device identifiers browser type, language, wireless network, and mobiile network information (including the mobile phone number) with our third party partners, that enables us to use Bluetooth beacons to provide you with information or offers specific to your location and interests. By accepting our terms of service, you consent to the collection, storage and processing of your data by our third party partners for the purposes of: (i) providing or improving their services; (ii) enabling third parties to assist us and the retailer and venues (in which the beacons are located) in better serving and understanding our users; and (iii) sharing your data with third parties so they can provide or enable the provision of content, offers or other marketing solutions that may be of interest to you. You also consent to having your data transferred to and processed in your or any other jurisdiction in which our third party partners or their parent, subsidiaries, affiliates, service providers or partners maintain facilities. If you do not consent to the collection and transfer of the aforementioned data through the identification of your mobile device, we recommend that you: (a) delete our app or adjust the in-app settings of the app; or (b) delete the applicable mobile advertiser ID by limiting ad tracking on the device.
Information from Use of our Services. We also collect/compile non-personally identifiable information from Users of our Services. Non-personally identifiable information is information that usually cannot by itself be used to identify a particular person or entity, and may include: the Internet Protocol (IP) address, unique device identifiers, anonymous IDs for advertising, operating system, mobile network information, browser type, existing applications, browsing activity and non-precise device location information (e.g., city or region).
We enable you to send messages to other Users in the community. We ordinarily don’t read the content of these messages unless we reasonably believe the Service is being misused or as required by law; we keep track of the number of messages sent and similar information to keep our Services running smoothly. We also enable you to ‘friend’; other members of the our community, and records which members of the community you’ve friended, which our groups you’ve joined, and what pieces of content you’ve uploaded via the Services.
By visiting, accessing or otherwise using the Product and Services, you affirmatively consent to our collection and use of Information in accordance with the terms of this Policy.
2. WHAT SPECIFIC INFORMATION DO WE COLLECT AND WHERE DO WE COLLECT IT?
A. User Registration. If you elect to become a registered user by creating one or more user accounts in connection with any of our Products and Services, we may require you to provide certain information including your birth date, your first and last name, email address, physical address, Facebook username or Twitter handle, and your selected password.
B. Profile Creation. We may also offer Users the option to complete, or import from a third party social network, a user profile that is visible to other users. Such User profiles may include: a profile photo; one or more game username(s); gender; biographic details; links to third party social media profiles; details about the games Users play or services Users use, and a User ID
The User ID used to identify your account and profile may be public and will appear in the URL of your profile page, but will only permit access to information that is considered public or that you have designate as public in your settings. First and last names, and profile pictures are considered “public.” Third party search engines may index this publicly available information.
C. Third Party Websites. When you use any our Products and Services on or with an association with a third party social network such as Facebook or Google + or any other compatible social networks, you allow Us to access certain information from your profile for that social network. You may adjust the information we can access by making corresponding changes in the social network’s privacy settings. You can control and find out more about these settings at the third party social network where you play our games.
By using any of our Products and Services in a manner that interacts with any third party social network, you agree to authorize Us to collect, store, and use in accordance with this Policy any and all information that you agreed the social networks could provide to Us through an Application Programming Interface (“API”).
D. Contact Sharing and Importation. We may also offer you the ability to import your address book contacts, third party social network contacts, or manually enter e-mail addresses. We will store those contacts for purposes of helping you and your contacts make connections using our Products and Services.
E. Gameplay. If you play Our games on your mobile phone, tablet PCs, or PCs, We collect certain device identifiers, including MAC Address, and IP Address. In certain games, We will create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, geo-location or e-mail address. We may also access your contacts to enable you to invite friends to join you in the Service.
F. Payment. If you purchase a license to use in-game virtual currency or virtual items directly from Us, We may collect the billing and financial information necessary to process your charges, which may include your postal and e-mail addresses. We may also receive the billing and payment information that you provide when your purchase is processed by a third party, such as Facebook, Google, Apple, PayPal, MoPay, or your telephone or internet service or data provider. Our Terms of Service explain our policies and terms relevant to our charges and billing practices. Please note that purchases of third party credits or fictional currencies may be subject to additional policies.
G. Support. When Users ask for assistance from our Customer Support team, We will collect and store the contact information Users provide (generally User ID, name and contact information such as an e-mail address), information about your game play or activity on the Service, and your user ID. We will also store the correspondence and any information contained within.
H. Contests, Sweepstakes and Surveys. In order to participate in certain contests, sweepstakes or surveys, there may be a separate registration process which may require the submission of both PII and NPII. We will use the Information you provide for the purpose of conducting the promotion (for example, to contact you if you have won). You may also have the opportunity to opt-in to receive special Promotions or offers from our advertisers as a result of your use of our Products and Services.
I. Information Collected Through Automatic Data Collection. In addition, we may also collect, or our third party ad server and/or content server may collect, certain Non-Personally Identifiable Information. This may include information about the physical location of your device, and time and date information used to identify the length of time spent within a given physical location. This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer our services and to gather demographic information. Our third party ad servers will also provide us with summary, but not individual, reports that will tell us how many ads were presented and clicked upon.
When you access our websites, fan forums, or play our games, We collect (i) certain technical information about your mobile device or computer system, including MAC Address, IP Address, beacon data, GPS data, Wi-Fi signal data, and mobile device ID; and (ii) usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files (“Log Files”), mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID(s).
In addition to the manner set forth above, We may also collect information from you at other points wherein We that state that such information is being collected.
3. HOW DO WE USE COLLECTED INFORMATION?
Specific uses of PII include:
• Contacting User regarding the administration of any features or functions of our Products and Services;
• Sending User promotional emails or SMS messages;
• Allowing User to participate in fan community features;
• Responding to User questions or other requests;
• Tailoring User gaming experience;
• Saving User ID or other Information (so you don’t have to re-enter it each time you use our Products and Services);
• To create your game accounts and allow play of our games;
• Enable User communication;
• Notifying Users of updates and in-game achievements;
• To prevent or potentially illegal activities, and enforce our Terms of Service;
• For other purposes disclosed at the time you provide us with Information.
Specific uses of your NPII include:
• Tracking User visits;
• Tracking User locational information such as physical areas visited, the data of such visits, and length of time spent dwelling in such areas;
• For research purposes, for marketing/promotional purposes and/or to provide anonymous reporting for internal and external clients or licensors;
• Accumulating and reporting aggregate, statistical information in connection with User activity;
• Determining which features and services Users like best to help us operate our Products and Services, enhance and improve our services and display advertising and marketing information;
• Tailoring your gaming experience;
• Saving certain NPII for use on your return visits;
• For the uses described for “Personally Identifiable Information” above;
• For other purposes disclosed at the time you provide us with the Non-Personally Identifiable Information.
4. WITH WHOM DO WE SHARE COLLECTED INFORMATION?
C. Disclosure of Certain Information in User Postings Intended to Be Disclosed. Certain Personally Identifiable Information associated with a User forum posting or social media comment may be intended for disclosure, such as your username. We will disclose any such PII in connection with the display of, and other services relating to, such User posting, and by submitting a User posting in connection with any of our Products and Services you affirmatively consent to the distribution of your PII as described herein.
D. Third Party Service Providers. We also reserve the right to disclose PII and other information to third parties for the purpose of administering and maintaining our Products and Services, and related features, functions and operations. We will refer to these third parties as “Third Party Service Providers.” We use Third Party Service Providers to efficiently provide the full range of content, activities, services, features and functions we bring you and we disclose your Information to Third Party Service Providers for the purpose of providing services to us. These Third Party service providers may temporarily store some information on their servers, but they may only use your Personal Information to provide Us with a specific service and not for any other purpose.
E. Other Third Parties. Other than as set forth in this Policy, we do not share your PII with third parties, apart from those acting as our agents in providing our Products and Services to you, which agree to use it only for that purpose and to keep it secure and confidential. Also, please be aware that our affiliated companies, including all their respective business units, subsidiaries, affiliates and sites, entities into which our companies may be merged, or entities to which any of our assets, products, sites or operations may be transferred, may obtain from us and be able to use your PII . We may share your NPII with third parties that use this data for the purpose of reselling data to third parties. Information provided to such data resellers is limited to NPII.
F. Statistical Analysis. We may also provide NPII about our customers’ sales, traffic patterns, physical location using geo-locational data, dates and times during a location was visited, time spent dwelling in such locations, and related information to third party advertisers, advertising platforms, data resellers, and advertising service providers. But these statistics do not include any PII.
5. WHAT ARE YOUR CHOICES REGARDING COLLECTION, USE AND DISTRIBUTION OF YOUR INFORMATION?
A. Opting out. At times, you may be presented with the option of whether to receive certain marketing and promotional communications from Us and others that we think will be of interest to you. Recipients of such communications can unsubscribe by either following the specific instructions included in such communications or you may ‘opt-out’ of receiving marketing and promotional emails from us at any time by sending an email to us at privacy@Creative-mobile.com detailing your privacy request. Please note, however, that in order to keep you informed about the operation of our Products and Services, we may always send you emails and announcements that are needed for the proper functioning and administration of our Products and Services. We may also have features that allow you to submit information, questions or feedback to us. In those instances, we may retain your emails and other information you submit to us for our internal purposes, and to help us to serve you better.
B. Changing your privacy preferences. You may change your privacy preferences by making corresponding changes in the third party social network account which you use to play our game.
6. HOW CAN YOU UPDATE, CORRECT, OR DELETE YOUR PERSONALLY IDENTIFIABLE INFORMATION?
We believe you should have the ability to access and edit the PII that you have provided to us. You may change any of your PII in your account online at any. You may also access and correct your personal information and privacy preferences by writing us at:
Creative Mobile O.U.
Attn: Privacy Compliance Officer
Parnu mnt 139a, 11317 Tallinn, Estonia
Please include your name, address, and/or e-mail address when you contact us.
We encourage you to promptly update your PII if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions. In addition, it may be impossible to completely delete your information without some residual information because of backups.
7. WHAT SECURITY PRECAUTIONS ARE IN PLACE TO PROTECT AGAINST THE LOSS, MISUSE, OR ALTERATION OF YOUR INFORMATION?
The importance of security for all PII associated with our Users is of utmost concern to us. Your PII is secured consistent with current industry standard and is protected in several ways. Access by you to your PII is available through a password and unique User ID selected by you. This password is encrypted. WE RECOMMEND THAT YOU DO NOT DIVULGE YOUR PASSWORD TO ANYONE.
In addition, your PII resides on a secure server that only selected company personnel and contractors have access to via password. We encrypt your PII and thereby prevent unauthorized parties from viewing such information when it is transmitted to us.
In order to most efficiently serve you, any credit card transactions and order fulfillment are handled by established third party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.
Unfortunately, no data transmission over the internet or any wireless network can be guaranteed to be completely and 100% secure. As a result, while we strive to protect your PII, you acknowledge that: (a) there are security and privacy limitations of the internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
8. DO WE USE “COOKIES”?
We may also use a variety of third party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties to, for example, serve advertisements, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or User traffic. Such services may enable us to display advertisements based on your Product and Service use. Targeting services enable us to, among other things, help deliver advertisements or other content to you for products and services that you might be interested in, to prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you.
9. WHAT SHOULD YOU KNOW ABOUT PRIVACY POLICIES AND DATA COLLECTION AT ANY THIRD PARTY WEBSITES ACCESSIBLE FROM OUR PRODUCTS AND SERVICES?
10. HOW ARE LINKS TREATED?
11. IS INFORMATION FROM CHILDREN COLLECTED?
WE DO NOT KNOWINGLY COLLECT PERSONAL INFORMATION FROM CHILDREN UNDER THE AGE OF THIRTEEN (13) WITHOUT APPROPRIATE PARENTAL NOTICE AND CONSENT. PLEASE VISIT THE FOLLOWING WEBSITE FOR INFORMATION FROM THE FEDERAL TRADE COMMISSION ABOUT PROTECTING CHILDREN’S PRIVACY ONLINE: CLICK HERE
12. WHAT ELSE SHOULD YOU KNOW REGARDING PRIVACY ONLINE?
You should also be aware that when PII is voluntarily disclosed (i.e. your name, e-mail address, etc.) in the discussion forums or other public areas, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you’re online.
13. MISCELLANEOUS ITEMS
From time to time we may modify this Policy to reflect industry initiatives or changes in the law, our Information collection and use practices, Our features, or technology, and such modifications shall be effective upon posting. Your continued use of Our Products and Services after we post a revised Policy signifies your acceptance of the revised Policy. It is therefore important that you review this Policy regularly to ensure you are updated as to any changes. If we materially change our practices regarding collection or use of your PII, your PII will continue to be governed by the Policy under which it was collected unless you have been provided notice of, and have not objected to, the change.
Creative Mobile O.U
Attn: Privacy Compliance Officer
Parnu mnt 139a, 11317 Tallinn, Estonia