[Serenity Land GAME]
Privacy
Notice
Last Updated: [0120 ], 2023
[SERENITY LAND GAME] develops and publishes
social games for the web and mobile devices. This Privacy Notice (this Notice)
describes the ways [SERENITY LAND GAME] (Studio, us, our or we) collects,
stores, uses, discloses or otherwise processes personal information of our
users (users or you) in connection with their use of our products or services,
including our product offerings such as our website available at [breakingdead@karmasgame.com] and Studio
game(s) provided on a mobile platform or any other Studio product or service
that posts or links to this Notice (each a Service, collectively, the
Services). Additionally, this Notice describes the rights and choices
concerning your information that may apply to you.
This Privacy Notice covers the following
topics:
·
Personal information we collect and how we collect it
·
How we use your information
·
Sharing of your information
·
Online advertising
·
Security of your information
·
Data retention
·
Childrens privacy
·
Third-party websites and services
·
Transfer of personal information outside your country
·
Managing your information
·
Specific provisions for EEA, UK and Swiss individuals
·
Specific provisions for California Consumers
·
Changes to this Notice
·
Contact information
If you have questions regarding this Notice
or our collection and use of personal information, please contact us as
described in the Section Contact Us.
1. PERSONAL INFORMATION WE COLLECT AND
HOW WE COLLECT IT
When you interact with or use our Services,
we are collecting personal information about you. Sometimes we collect personal
information automatically when you interact with our Services (e.g.,
information about how you interact with our Services) and sometimes we collect
the personal information directly from you when you use our Services (e.g.,
information you give us when setting up your account or user profile). At
times, we may collect personal information about you from other sources and
third parties, including other players.
A. Information We Collect Automatically or
From You Directly
Registration Information
We may offer you the option to complete a
user profile that is visible to other Studio users (Account). If you create an
Account, you may provide us your name, a username, e-mail address, a password
and other information that helps us confirm that it is you accessing your
Account. We may do this through in-game dialog boxes, which you may choose to
skip. If you sign into the Services with Facebook Connect, we will collect information
that is visible via your Facebook account such as: (1) your first and last
name, (2) Facebook ID, (3) Profile Picture/URL, and (4) list of Facebook
friends. Your Account may be used to publicly identify you as part of social
features of the Services, which may include user-to-user interaction, chat or
messaging functionality, public leaderboards, head-to-head competition, and
other similar features. Your username associated with your Account will be
public and will be shown to other users. In addition, your username will allow
others to access information on your user profile that is considered public or
that you have designated as public in your user profile settings.
Address Book Information
We may also offer you the ability to choose
to import your contacts or manually enter e-mail addresses so that you can
locate your contacts on Studio and invite your contacts to join you in the
Services. This information is typically collected through the use of
third-party mobile device software development kits. If you choose to import
your contacts or manually enter e-mail addresses, we will store those contacts
for purposes of helping you and your contacts make connections through our
Services. You are responsible for ensuring your sharing of this information
with us is compliant with applicable laws. In some countries, this may require
you to get permission from the people you invite before you share their
information.
Technical and Usage Information
When you access our Services, we may use
cookies and other similar technologies to collect (i)
certain technical information about your mobile device or computer system,
including IP Address, mobile device ID (IDFA, Google Advertising ID or other
identifiers), and the version of your operating system; and (ii) usage
statistics about your interactions with the Services, including the links,
objects, products and benefits you view, click or otherwise interact with (also
known as Clickstream Data). Our emails may also contain tracking pixels that
identify if and when you have opened an email that we have sent you, how many
times you have read it and whether you have clicked on any links in that email.
In connection with your use of certain Services, we will create and assign to
your device an identifier that is similar to an account number. In addition, in
certain circumstances, 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 username, character name, or e-mail address. We may
also infer your approximate geographic location based on your IP address.
Payment Information
When you order any good or service through
the Services, including any virtual currency or virtual good, we collect
certain non-financial transaction information related to these purchases,
including what you purchased, the price, and the date. Your
in-app purchase transactions are processed by third-party payment processors,
such as Apple (for purchases on iOS devices), Google (for purchases on Android
devices), or Amazon (for purchases on Kindle devices). The third-party payment
processors will collect your name, phone number, e-mail address, mailing
address, billing address, and complete credit card information to enable them
to process your payment. The third-party payment processors may also retain
this information to enable you to purchase additional items through our
Services without having to re-enter your payment information each time. Please
note third-party payment processors do not share your financial information,
like credit card numbers, with us. In addition, please note that the
third-party payment processors processing of transactions and collection and
use of your personal information is governed by their terms of service and privacy
policy, and purchases through these third parties may also be subject to
additional policies. We encourage you to review the terms of service and
privacy policies of those third parties to learn more about how they handle
your personal information.
Information Collected by or Provided to
Customer Support
When you ask for assistance from our
Customer Support team, we will collect and store the contact information you
provide (generally your name and e-mail address), information about your
game-play or activity on the Services, and your username or ID number. We will
also store the correspondence and information within the correspondence that
you choose to share with us.
Communication Preferences
We may collect information about your
interests and communication preferences that you choose to provide, such as
when subscribing to news or alerts.
Surveys, User Research Projects,
Competitions and Promotional Events
If you choose to participate in, or fill
out any forms relating to, Studio surveys, user research projects, competitions
(contests/sweepstakes), promotional events, or similar activities, we will
collect your contact information (such as your name, email, and phone number,
address and postal code) to enable you to participate in the activity and to allow
us to communicate with you, as well as any other information that we request
that you provide for purposes of the activities, including audio or video
recordings, photos, and/or screen captures. In connection with Studio surveys
and user research projects, we may also collect your age, gender, opinions,
responses to certain research questions, prompts, or surveys, and other
personal information, consistent with the purposes of the Studio survey or user
research project.
On occasion, we may also collect your
shipping and billing information to send you certain rewards or incentives,
such as if you are a participant in a Studio survey or
user research project, a competition winner, or if you purchase our products or
services. In addition, if you are a part of our event or promotion partner, we
may also collect your personal information including your name, company email,
and company address.
Please note that your participation in any
Studio surveys, user research projects, competitions (contests/sweepstakes),
promotional events, or similar activities, is completely voluntary.
B. Information We Collect From Other Sources
We may collect or receive information from
the following other sources (i) other Service users
who choose to upload their email contacts; (ii) third party information
providers, such as digital advertising companies; and (iii) social networking
sites. We may combine this information with the information we collect from an
individual directly.
C. Sensitive or Special Categories of
Information
We typically do not request or seek to
elicit sensitive or special categories of information, but you may choose to
provide this information to us in connection with certain of the interactions
described above, including when you ask for assistance from our Customer
Support team. The meaning of sensitive or special categories of information
varies by jurisdiction and it could include, for example, health, genetic or
biometric data, or precise location information.
2. HOW WE USE YOUR INFORMATION
We use information collected through our
Service for purposes described in this Notice or disclosed to you in connection
with our Service. For example, we may use your information for:
*Service Delivery*
− Create your Service accounts and allow
access to our Services;
− Identify and suggest connections with
other Studio users;
− Operate our Services;
− Improve our Services;
− Understand you and your preferences to enhance
your experience and enjoyment using our Services;
− Respond to your comments and questions
and provide customer service;
− Provide and deliver products and services
you request;
− Send you related information, including
confirmations, invoices, technical notices, updates, security alerts, and
support and administrative messages;
− Conduct and administer surveys, user
research projects, competitions and promotional events that you participate in;
− Prevent fraud or potentially illegal
activities, and enforce our Terms of Use;
− Enable you to communicate with other
users; and
− Fulfill any other purpose for which you
provide personal information.
*Marketing and Advertising*
− Deliver and target advertising and
marketing and promotional information to you; and
− Communicate with you (including via email
and push notifications) about promotions, contests, rewards, upcoming events,
and other news about products and services offered by us and our selected
partners.
*Research and Development*
− Create aggregate or anonymous information
derived from the personal information we handle, which we may use and disclose
for research, development and other lawful business purposes;
− Link or combine personal information with
other information we get from third parties to help understand your preferences
and provide you better services; and
− Analyze information to choose to provide
to us in connection with Studio surveys and user research projects to gain
insights into how users engage with our Services, to improve our Services, to
consider developing new products or services, and other lawful purposes.
*Compliance and Protection*
− Comply with applicable laws, lawful
requests, and legal process, such as to respond to subpoenas or requests from
government authorities;
− Protect our, your or others
rights, privacy, safety or property (including by investigating, bringing,
making or defending legal claims);
− Audit our internal processes for
compliance with legal and contractual requirements or our internal policies;
− Enforce the terms and conditions that
govern the Services; and
− Prevent, identify, investigate and deter
fraudulent, harmful, unauthorized, unethical or illegal activity, including
cyberattacks and identity theft.
*Push Notifications*
We may occasionally send you push
notifications through our Service to send you game updates, high scores and
other service-related notifications that may be of importance to you. You may
at any time opt-out from receiving these types of communications by turning
them off at the device level through your settings.
3. SHARING OF YOUR INFORMATION
We may share information we collect for the
following purposes:
− *Service Providers.*
With service providers that perform services on our behalf or enhance our
Services, including hosting services, customer service, analytics services and
to assist us in our marketing efforts;
− *Payment Processors.*
With third-party payment processors that process payments you make;
− *Advertising Partners.*
Advertisers, ad exchanges and other ad technology companies that require the
data to select and serve our relevant advertisements to you and others, and
assist us in our marketing efforts, including as described in the Online
Advertising section below;
− *Affiliates.*
With our parent company, subsidiaries and other affiliates;
− *Professional Advisors.*
With professional advisors, such as lawyers, auditors, bankers and insurers,
where necessary in the course of the professional services that they render to us;
− *Authorities and others.* With law enforcement and public
authorities, as we believe in good faith to be necessary or appropriate for the
compliance and protection purposes described above;
− *Business Transferees.*
With acquirers and other relevant participants (and their advisors) in business
transactions (or negotiations of or due diligence for such transactions)
involving a corporate divestiture, merger, consolidation, acquisition,
reorganization, sale or other disposition of all or any portion of the business
or assets of, or equity interests in, Studio or our affiliates (including, in
connection with a bankruptcy or similar proceedings); and
− *Your specified recipients.* We may disclose personal information
about an individual to certain other third parties or publicly with their
consent or direction.
4. ONLINE ADVERTISING
Interest-Based Advertising
To the extent we display advertising in our
Services, with your consent as may be required by applicable law, we may share
or we may allow online advertising networks, social media companies, and other
third-party services to collect information about your use of our Services over
time to enable them to play or display ads on our Services, on other devices
you may use, and on other websites, apps, or services. Typically, though not
always, the information we share is provided through cookies, software
integrations, or similar tracking technologies, which recognize the device you
are using. We and our third-party partners use this information to try to make
the advertisements you see online more relevant and tailored to your interests,
as well as to provide advertising-related services such as reporting,
attribution, analytics, and market research. Such information includes the
following:
·
Device make, model and operating system;
·
Device properties related to screen size &
orientation, audio volume and battery;
·
Carrier;
·
Operating system;
·
Name and properties of mobile application through which
the user interacts with the Services;
·
Country, time zone and locale settings (country and
preferred language);
·
Network connection type and speed;
·
IP Address;
·
Gender;
·
Keywords;
·
City- and/or country-level geolocation data;
·
Internet browser user-agent used to access the Services;
and
·
Advertising ID (IDFA on iOS devices and GAID on Android
devices).
A list of these advertising partners and
their privacy policies is available at [breakingdead@karmasgame.com]. The privacy policies of our partners
may include additional terms and disclosures regarding their data collection
and use practices. We encourage you to review those privacy policies to learn
more about their data collection and use practices.
Social Media Widgets
Our Service may include social media
features, such as the Facebook button, Google, Instagram, Twitter, or other
widgets. These social media companies may recognize you and collect information
about your visit to our Services, and they may set a cookie or employ other
tracking technologies. These companies have interest-based advertising programs
that allow us to direct advertisements to users who have shown interest in our
Services while those users are on the social media platform or to groups of
other users who share similar traits, such as likely commercial interests and
demographics. Your interactions with those features are governed by the privacy
notices of those companies.
Cross-Device Linking
We, or our third-party partners, may link your
various devices so that content you see on one device can result in relevant
advertising on another device. We do this by collecting information about each
device you use when you are logged in to our Service. We may also work with
third-parties who employ tracking technologies or the application of
statistical modeling tools to determine if two or more devices are linked to a
single user or household. We may share a common account identifier (such as an
email address or user ID) with third-party advertising partners to help
recognize you across devices. We, and our partners, can use this cross-device
linkage to serve interest-based advertising and other personalized content to
you across your devices, to perform analytics, and to measure the performance
of our advertising campaigns.
Google Analytics and Advertising
We utilize certain forms of display
advertising and other advanced features through Google Analytics, including,
but not limited to, Remarketing with Google Analytics, the DoubleClick Campaign
Manager Integration, Google Ads, and Google Analytics Demographics and Interest
Reporting. These features enable us to use first-party cookies (such as the
Google Analytics cookie) and third-party cookies (such as the DoubleClick
advertising cookie) or other third-party cookies together to inform, optimize,
and display ads based on your past visits to the Service and to tailor our
advertisements and content to you. You may control your advertising preferences
or opt-out of certain Google advertising products by visiting the Google Ads
Preferences Manager, currently available at https://google.com/ads/preferences. To learn how
you can opt-out of data collection by Google Analytics, visit https://tools.google.com/dlpage/gaoptout.
Opting-Out of Interest-Based Advertising
You may visit www.aboutads.info/choices or www.youronlinechoices.eu (for
individuals in the EU) to learn more about interest-based advertising and how
to opt-out of this form of advertising on your web browser by companies
participating in the Digital Advertising Alliance (DAA) self-regulatory
program. If you wish to opt-out of interest-based advertising in mobile apps on
your device by companies that participate in the DAAs AppChoices
app, you may download that app onto your device and exercise your choice. AppChoices is available at the links below:
You may also limit data collection by third
parties by visiting your mobile device settings and adjusting the devices ad tracking settings (such as turning off the feature to
Allow Apps to Request to Track) or by exercising other privacy options in your devices settings.
Please note that electing to opt-out will
not stop advertising from appearing in your browser or applications or reduce
the number of ads that you receive. You will still receive ads, but those ads
may be less relevant to your interests. In addition, if you use a different
browser or erase cookies from your browser, or use a different mobile device,
you may need to apply your opt-out choices to that
particular browser or device.
Please note that the opt-out tools
described in this section are provided by third parties, not by us. We do not
control and are not responsible for the effectiveness of, or compliance with,
any third-parties opt-out options or programs or the accuracy of their
statements regarding their programs. In addition, third parties may still use
cookies to collect information about your use of our online services, including
for analytics and fraud prevention as well as any other purpose permitted under
the DAAs Principles.
*Do Not Track*
Some Internet browsers may be configured to
send Do Not Track signals to the online services that you visit. We currently
do not respond to Do Not Track or similar signals. To find out more about Do
Not Track, please visit http://www.allaboutdnt.com.
5. SECURITY OF YOUR INFORMATION
We implement reasonable and appropriate technical
and organizational measures to protect the security of your personal
information against accidental or unlawful destruction, loss, change or damage.
However, no security system is
impenetrable, and we cannot guarantee the security of your personal
information. Any transmission is at your own risk.
6. DATA RETENTION
We store data on servers in the U.S. or any
other country in which the Studio or its affiliates, subsidiaries, agents or
contractors or service providers maintain facilities. We retain your personal
information for as long as needed to provide you Services, unless we are
required by law to delete or if we accept your request to delete the
information pursuant to applicable law. We will also retain and use your
personal information as necessary to comply with our legal obligations, resolve
disputes, and enforce our agreements.
When we no longer require your personal
information, we will look to delete or anonymize it or, if this is not possible
(for example, because your personal information has been stored in backup
archives), then we will apply security measures to your personal information
and isolate it from any further processing until deletion is possible. If we
anonymize your personal information (so that it can no longer be associated
with you), we may use this information indefinitely without further notice to
you.
7. CHILDRENS PRIVACY
The Services are not intended for use by
children (aged 16 or such higher age as required by applicable law). We do not
knowingly collect personal information from children through the Services or
knowingly allow them to use our Services. If we learn that we have
unintentionally collected personal information from a child, we will delete
that information. If you believe that we might have collected personal
information from or about a child, please contact us at [breakingdead@karmasgame.com].
8. THIRD-PARTY WEBSITES AND SERVICES
The Services may contain integrations or
links to third-party websites or services, including those of our business
partners. By interacting with these third parties, you are providing
information directly to the third party. Please note that the Studio is not
responsible for the privacy practices of these third parties or any entity that
it does not own or control. We encourage you to review the privacy policies and
online terms of those third parties to learn more about how they handle your
personal information.
9. TRANSFER OF PERSONAL INFORMATION
OUTSIDE YOUR COUNTRY
We may transfer information that we collect
about you to affiliated entities, or to other third parties across borders and
from your country or jurisdiction to other countries or jurisdictions around
the world. If you are located in the European Economic Area, United Kingdom or
Switzerland, your personal information may be processed outside of those
regions, including in the United States.
10. MANAGING YOUR INFORMATION
Subject to certain exemptions, you can
manage information we receive about you.
If you would like us to delete your
information, you may send an e-mail to [breakingdead@karmasgame.com] and place Delete My Account in the
subject line [or request to delete your information inside the app you are
using]. If you proceed with the deletion of your account, you will no longer
have access to the game account or services associated with your account. Other
steps you should take should you wish to delete your account include
disassociating your Facebook account from our mobile games, if applicable, and
deleting the game from your mobile device. Please note that if you ask us to
delete your account, all your progress in the game and any unused virtual items
will be lost and we may not be able to restore them in the future. Please note
that your information, for example records pertaining to payments or customer
service matters, may be retained for legal and accounting purposes. If you have
sent or posted content on the Service, we may not be able to delete it.
If you wish to review, change or correct
the information we have about you, you may send an e-mail to [breakingdead@karmasgame.com] making this
request.
For all of the above requests, we will need
to verify your identity before processing your request. In order to verify your
identity, we will generally require the matching of sufficient information you
provide us to the information we maintain about you in our systems.
11. SPECIFIC PROVISIONS FOR EEA, UK AND
SWISS INDIVIDUALS
These additional provisions apply to
individuals who are located in European Economic Area (EEA), United Kingdom
(UK) and Switzerland.
[SERENITY LAND GAME], having its registered
address at [60 PAYA LEBAR ROAD #08-10、PAYA LEABAR SQUARE、、409051、新加坡],is the data
controller responsible for the processing of personal data in connection with
our Services. This means that we determine and are responsible for how your
personal information is used.
Your Rights With
Respect to Your Personal Information
In accordance with applicable privacy law, you
have the following rights in respect of your personal information that we hold:
·
Accessing and Correcting Your Personal Information. At any time,
you may request to access the personal data that we hold about you. We may need
to ask you to provide certain information to make sure you are who you claim to
be. If you find the information on your account is not accurate, complete or
updated, then please provide us with the necessary information to correct it.
·
Erasing or Restricting Access to Your Information. You may
request to delete or restrict access to your personal data. We may postpone or
deny your request if your personal data is in current use for providing
Services or for other legitimate purposes, in which case we will let you know
if we are unable to do so and why.
·
Transferring Your Personal Data (Otherwise Known as Your
Right to Data Portability). You have the right to receive your personal data that
you have provided us in a structured, commonly used and machine
readable format and the right to transmit that data to another party of
your choice, where technically feasible. However, this right shall not apply
where it would adversely affect the rights and freedoms of others.
·
Right to Object to Processing. You have the
right to object to our processing of your personal data, under certain
conditions.
·
Withdrawing Your Consent. Contact us if you would like to
withdraw your consent to the processing of your personal data based on that
consent. Exercising this right will not affect the lawfulness of processing
based on consent before withdrawal.
If you wish to exercise any of your rights
detailed above, please contact us at [breakingdead@karmasgame.com] or write to us at the address set
forth in the Contact Us section. If you make a request, we will typically look
to respond within one month, although a longer period may be permitted.
Right to Make a Complaint. In the event
that you wish to make a complaint about how we process your personal data,
please contact us in the first instance at [breakingdead@karmasgame.com and we will endeavor to deal with your
request. This is without prejudice to your right to make a complaint with an EU
data protection supervisory. If you are based in the European Union,
information about how to contact your local data protection authority is
available at https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en. If you are
based in the UK or Switzerland, your local data protection authorities are the
UK Information Commissioner's Office (https://ico.org.uk/global/contact-us/) and the Swiss
Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact/address.html), respectively.
Lawful Basis for Processing
With respect to each of the purposes for
which we use your personal information (see Sections 2, 3 and 4 above), the
lawful basis that we may rely upon will vary based on the nature of, and reason
for, particular use to which we are putting your personal information. However,
typically we will use your personal information:
·
Where we need to do so to perform a contract
we are about to enter into with you or have entered into with you C for
example, this will be relevant where we use your personal information to
provide you with the Services, to operate the Services and to create and
maintain your Account.
·
Where it is necessary for our legitimate interests,
and/or those of a third party, and your interests and fundamental rights do not
override those interests C for example, this will be relevant where we share
your personal information in the context of an actual or prospective corporate
event, in these cases we and any relevant third parties have a legitimate
interest in enabling those parties to investigate and, where relevant, to
continue to operate, all or relevant part(s) of our operations.
·
Where we need to comply with a legal or regulatory
obligation C for example, this will be relevant where we are legally obliged to
provide your personal information to authorities to comply with lawful
governmental or regulatory requests.
·
Where we have your specific consent to carry out the
processing for the purpose in question C for example, this will be relevant
where we use your personal information to show you targeted online advertising.
For questions about the lawful basis we rely on for data processing, please contact us at [breakingdead@karmasgame.com]. Visit the
Contact Us section below for contact information.
Marketing and Advertising
From time to time we
may contact you with information about our services, including sending you
marketing messages and asking for your feedback on our services. Most marketing
messages we send will be by email or push notifications. For some marketing
messages, we may use personal information we collect about you to help us
determine the most relevant marketing information to share with you.
Where we rely on consent to send you
marketing communications, we will only send you such messages if you have given
us your consent to do so. You can withdraw your consent at a later date by
clicking on the unsubscribe link at the bottom of our marketing emails or by
updating your preferences in the settings page of the App or Service.
Data Transfers and Processing Outside
Europe
If you are located in the EEA, UK or
Switzerland, your personal information may be processed outside of those
regions, including in the United States. In the event of such a transfer, we
typically try to ensure a degree of protection similar to that applied in your
home country is afforded to it by employing one of the following mechanisms:
·
*Transfers to territories with an adequacy decision.* We may transfer your personal information
to countries or territories whose laws have been deemed to provide an adequate
level of protection for personal information by the relevant authorities (e.g.,
by the European Commission, UK Government and/or Swiss Federal Council).
·
*Transfers to territories without an adequacy decision.*
o We may transfer
your personal information to countries or territories whose laws have *not***
been deemed to provide an adequate level of protection for personal information
by those relevant authorities (e.g., the United States).
o However, in
these cases, we may look to use specific appropriate safeguards approved by the
relevant authorities, which are designed to give personal information the same
protection it has in the EEA, UK or Switzerland C for example, standard-form
contracts approved by relevant authorities for this purpose.
In limited circumstances, we may rely on an
exception, or derogation, which permits us to transfer your personal
information to recipients in such countries despite the absence of an adequacy
decision or appropriate safeguards C for example, reliance on your explicit
consent to that transfer.
If you want further information on the
specific mechanism(s) used by us when transferring your personal information,
please contact us at [breakingdead@karmasgame.com]. Visit the Contact Us section below
for contact information.
12. SPECIFIC PROVISIONS FOR CALIFORNIA
CONSUMERS
These additional provisions for California
consumers apply only to individuals who reside in California. The California
Consumer Privacy Act of 2018 (CCPA) and California Privacy Rights Act of 2020
(CPRA) provide additional rights to know, access, correct, delete, and opt out,
and requires businesses collecting or disclosing personal information to
provide notice and a means to exercise those rights.
Your California Privacy Rights. California
residents have the rights listed below under the CCPA. However, these rights
are not absolute, and in certain cases we may decline your request as permitted
by law.
·
Information. You can request the following information
about how we have collected and used your Personal Information during the past
12 months:
o The categories
of Personal Information that we have collected.
o The categories
of sources from which we collected Personal Information.
o The business or
commercial purpose for collecting and/or selling Personal Information.
o The categories
of third parties t - whom we disclose Personal Information.
o The categories
of Personal Information that we sold or disclosed for a business purpose.
o The categories
of third parties to whom the Personal Information was sold or disclosed for a
business purpose.
·
Access**.** You can request
a copy of the Personal Information that we have collected about you during the
past 12 months.
·
*Correct.* You can request
that we correct any information on your account that is not accurate, complete,
or updated by providing us with the necessary information to correct it.
·
Deletion. You can ask us to delete the Personal Information
that we have collected from you.
·
Opt-out of sales. You can opt-out of any sale of your
Personal Information.
·
Nondiscrimination. You are entitled to exercise the rights
described above free from discrimination as prohibited by the CCPA.
Right to Opt
Out of Information Sales
We do not sell information about our users
as most people would commonly understand that term. However, consistent with
common practice among companies that operate online, we do share information in
the sense that we allow certain third-party advertising networks and other
third-party businesses to collect and disclose your personal information
directly from your browser or device through cookies or tracking technologies
when you visit or interact with our websites, use our apps or otherwise engage
with us. These third parties use your personal information for purposes of
analyzing and optimizing our Service and advertisements on our websites, on
other websites or mobile apps, or on other devices you may use, to personalize
content or to serve ads that may be more relevant to your interests, and to
perform other advertising-related services such as reporting, attribution,
analytics and market research. To learn more about how third parties collect
information automatically on our Site and the choices you may have in relation
to those activities, please see our Online Advertising section, above.
How to Exercise Your Rights
To exercise your right to know, right to
access, right to correct, right to delete, right to opt out of information
sales, or any other right you may have under applicable law, please submit a
request by emailing [breakingdead@karmasgame.com] or by writing to us at the physical
address in the Contacts section below, with the subject line California Rights
Request and specifying which right(s) you would like to exercise (for example,
your right to delete). We will need to verify your identity before processing
your request. In order to verify your identity, we will generally require the
matching of sufficient information you provide us to the information we
maintain about you in our systems. In certain circumstances, we may decline a
request to exercise the rights described above, particularly where we are
unable to verify your identity or locate your information in our systems. If we
are unable to comply with all or a portion of your request, we will explain the
reasons for declining to comply with the request.
In certain circumstances, you are permitted
to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the
requestor is an authorized agent with written permission to act on your behalf
and (ii) you successfully verify your own identity with us.
We aim to respond to a consumer request
within 45 days of receiving that request. If we require more time, we will
inform you of the reason and extension period in writing.
*Personal Information That We Collect,
Use and Disclose*. The chart below summarizes the Personal Information we
collect by reference to the categories of Personal Information specified in the
CCPA, and describes our practices currently and during the 12 months preceding
the effective date of this Privacy Policy. See Sections 1-3 of our Privacy Policy
for additional details. Information you voluntarily provide to us, such as in
free-form webforms, may contain other categories of personal information not
described below. We do not intentionally collect or seek to elicit sensitive
personal information under the CPRA.
*Category of
Personal Information Collected* |
*Source(s) of
Personal Information* |
*Business
Purpose(s) for Collection* |
*Categories of
Third Parties to Whom We Disclose the PI for a Business Purpose* |
*Identifiers*, such as name, user name, email address and other
contact information, IP address, and online identifiers (like advertising IDs
and cookies) |
· You or your device(s)· Advertising partners·
Affiliates |
· Service delivery· Delivery of advertisements·
Technical support· Customer support· Processing payments· Analytics· Business
research & development· Marketing & promotions· Platform protection
& fraud prevention· Compliance with legal obligations |
· Service providers· Affiliates· Your specified
recipient(s)· Government entities/law enforcement· Advertising partners
shared* for interest based advertising |
*Additional
California Customer Records*, such as address book
information |
· You or your
device(s) |
· Service delivery·
Analytics· Business research & development· Marketing & advertising |
· Affiliates· Your
specified recipients |
*Characteristics of Protected Classifications*, such as age or gender |
· You or your device(s) |
· Service Delivery· Delivery of advertisements·
Analytics· Business research & development· Platform protection &
fraud prevention· Compliance with legal obligations |
· Service providers· Affiliates· Your specified
recipient(s)· Government entities/law enforcement· Advertising partners
shared* for interest based advertising |
*Commercial Information,*such as purchase
history, in-app purchases, or other purchasing or consuming histories or
tendencies |
· You or your
device(s) |
· Service
Delivery· Delivery of advertisements· Analytics· Business research & development·
Platform protection & fraud prevention· Compliance with legal obligations |
· Service
providers· Affiliates· Your specified recipients· Payment processors·
Advertising partners shared* for interest based
advertising |
*Internet or Network Information*, such as information regarding interactions with a
website, application, or advertisement |
· You or your device(s) |
· Service delivery· Delivery of advertisements·
Analytics· Business research & development· Platform protection &
fraud prevention· Compliance with legal obligations |
· Service providers· Affiliates· Your specified
recipients · Government entities/law enforcement· Advertising partners
shared* for interest based advertising |
Geolocation Data, such as city
or county-level geolocation information |
· You or your
device(s) |
· Service
delivery· Delivery of advertisements· Analytics· Business research &
development· Platform protection & fraud prevention· Compliance with
legal obligations |
· Service
providers· Affiliates· Your specified recipients · Government entities/law
enforcement· Advertising partners shared* for interest
based advertising |
*Inferences*, such as the derivation of information, data, or
assumptions from the categories of personal information included above |
· You or your device(s) |
· Service delivery· Delivery of advertisements·
Analytics· Business research & development· Platform protection &
fraud prevention· Compliance with legal obligations |
· Service providers· Affiliates· Advertising partners
shared* for interest based advertising |
* Pursuant to the CPRA and as further
described above, this information is shared with advertising partners for
interest-based advertising.
13. CHANGES TO THIS NOTICE
We may update this Notice to reflect
changes to our data and information privacy practices. If we make any material
changes, we will notify you by means of a notice on the Services prior to the
change becoming effective. We encourage you to periodically review this Notice
for the latest information on our privacy practices. Please note that if we
need to adapt the Notice to legal requirements, the new privacy Notice will
become effective immediately or as required.
14. CONTACT US
Our Data Protection Officer
You may contact us at [breakingdead@karmasgame.com] or at the
address below for further information.
[60 PAYA LEBAR ROAD #08-10 PAYA LEBAR
SQUARE Singapore 409051]