Effective Date: April 01, 2018
It is advised that you review this Policy regularly as it may be amended from time to time as set out below (see the Changes to this Policy section below).
We collect information about you directly from you, from third parties, and automatically through your use of our Service. We may combine the information that we collect about you from these various sources.
Information we collect directly from you
We will also collect any information that you provide to us through your use of our Service. The types of personal information we collect may vary depending on your activity. Personal information may include:
- Information provided by the User which is the necessary minimum for using the Application: name, surname, gender, mobile phone number and/or e-mail address;
- Additional information provided by the User at the request of DEVGAME in order to fulfill the obligations of DEVGAME to the Users regarding the use of the Application. Specifically, DEVGAME has the right to request from the User a copy of an identity document or any other document containing the User’s name, surname and photo, as well as any additional information that, at the discretion of DEVGAME, will be necessary and sufficient to identify the User and allow it to prevent abuses and infringements on the rights of third parties;
- Any other User information processed by DEVGAME.
DEVGAME also processes other User information, including:
- Standard data automatically received by the http server when a User accesses the Application and performs any subsequent actions (host IP address, type of the User’s Operating System, the UDID of the User’s device, and content accessed by the User, etc.);
- Information obtained as a result of the User’s actions when using the Applications;
- Information obtained as a result of the actions of other Users via the Applications;
- Personal User data received via the Applications, with the consent of the User, and necessary for the use of the Applications: name, surname, date of birth, profile photo, friends list, and other data;
- Information provided by Users when using the applications, specifically, their nicknames.
When you pay for products offered for purchase though the Service, we will also collect your billing address and complete credit card information that enables us to receive your payment. Our payment processing service provider may also retain this information to enable you to purchase additional items through our Service without having to re-enter it each time. We do not directly access or store your credit card information and we will not use your payment information we collect except as needed to fulfill your purchase and/or communicate with you regarding your transaction.
If you contact us via email (e.g., to contact customer support), we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We may use your personal information submitted in your communications to contact and respond to you.
Information we collect automatically about your use of our Service
The Service will also record game play information such as your high scores or game session duration. When you invite new members into your network on the Service or send messages through the Service, we collect and maintain the information associated with those messages, including email address and content.
If you use the Service on your mobile telephone or other mobile device, including iPads and tablets, we collect mobile device identifiers, including Media Access Control (MAC) address, and possibly 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, general location (based on your Internet Protocol (“IP”) address) or e-mail address. This information is useful to us for troubleshooting and helps us understand usage trends.
Except as described in this Policy, we will not share this information with any third party. If you no longer wish to allow us to track or use this information, you may turn it off at the device level. Please note, the application may not work properly if we are unable to tell where you are coming from (country specific).
In addition, we create a unique user ID to track your use of our Service. This unique user ID is stored in connection with your account information to track the DEVGAME games you are playing.
Please see the Cookies section below for more information about the information we automatically collect about you.
Some of the information you give us when you register to play our games is open to the public, such as your profile picture, number of friends, your username, the list of games that you play and the date of registration. Should you wish to hide any of the information that is made public, you can do so by changing the settings to “only me” in the privacy settings tab of your profile.
We need the above personal information for the purposes as described in this Policy, and not providing this information will have an impact on our ability to provide you with the Service. DEVGAME’s primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service. This includes sending you electronic communications related to the Service, from which you can unsubscribe at any time using the instructions in such communications. In addition, we may use user information for the following purposes:
Providing and improving our Services.To communicate with you, including via email or push notification, about your account and use of the Service, including to send Service and product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. For more information about opting out of certain communications, please see the Your rights and choices in relation to your personal information section below.
Marketing and communications.To communicate with you, including via email or push notification, about your account and use of the Service, including to send Service and product updates; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes. For more information about opting out of certain communications, please see the Your rights and choices in relation to your personal information section below.
Research and analytics.To analyze how you interact with the Service; to monitor and analyze usage and activity trends; and for other research, analytical, and statistical purposes.
Legal compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
We may also employ web beacons or other technology for a variety of reasons such as: (i) allowing us to know if a certain page was visited or whether an email was opened; and (ii) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages or identifying the source of a new installation.
Third party services
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
DEVGAME uses a tool called “Google Analytics” to collect information about use of this Service. Google Analytics collects information such as how often users visit this Site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. DEVGAME uses the information it gets from Google Analytics to understand Service usage and patterns and to improve its Service. Google Analytics collects only the IP address assigned to you on the date you visit a Service, rather than your name or other identifying information. DEVGAME does not combine the information collected through the use of Google Analytics with personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a Service, the cookie cannot be used by anyone but Google.
DEVGAME also uses AppMetrica to help understand usage of the Service. For more information about AppMetrica privacy practices, please see the https://yandex.com/legal/metrica_termsofuse/;
Sharing of information with third parties
We will share your information with other DEVGAME users as necessary to provide our Services. For example, if you post a profile picture, that picture may be available to all other users of our Services.
We also may share your information with third parties as required by legal or regulatory obligations; as requested by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or us to legal liability; or as DEVGAME otherwise deems necessary to detect, prevent, or otherwise address fraud, security, technical issues, or other threats to DEVGAME or others.
We may share your information with third party companies that perform services on our behalf, including payment processing, order fulfillment, data analysis, marketing services, email campaigns, hosting services, and customer service. While providing the services for us, these companies may access your personal information, and are required to use it solely as directed by us for the purpose of our requested service.
In conjunction with the running of our games we may partner with a third party to assist us in providing you with our Service. We will share the information you provide us through your social network, such as (1) your first and last name; (2) your profile picture or its URL; (3) your user identification number of the pertinent social network, which is linked to publicly available information such as name and profile picture; (4) the login email you provide to the pertinent social network upon registration; and (5) game play information with these third parties so they may facilitate the use of our Service as well as contact you about other games which may be of interest to you, service notifications and to solicit your feedback and input. If you do not wish to have this information shared please do not use our Service. If you wish to no longer have your personal information used by our partners you may contact us at email@example.com and we will facilitate your request to the partner.
We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.
We may use and share with third party advertisers (and other third parties) certain technical information and other non-personal information to show general demographic and preference information among DEVGAME users. We may also allow advertisers to collect technical information and other non-personal information, which they may share with us, through the use of tracking technologies like cookies and web beacons. The information collected may be used to offer you targeted ad-selection and delivery in order to personalize your user experience by increasing the likelihood that advertisements for products and services you see will appeal to you, a practice known as behavioral advertising, and to undertake web analytics (i.e. to analyze traffic and other end user activity to improve your experience). Please see the your rights and choices in relation to your personal information section below for more information about opting out of behavioral advertising.
Information about our users is an integral part of our business. We share your personal information only as described in this Policy.
Storage of your personal information
The personal information we collect, as described in this Policy, is being stored on servers in the United States and is accessible to our offices in Estonia, Ukraine and Russia. You expressly agree with your personal information being stored and processed in those countries.
We will keep you information for as long as we need your data to allow you to use the Service, though generally no longer than 5 years.
We have implemented commercially reasonable technical, physical, managerial and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use, disclose, or alter your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so we discourage you from sending us personal information through these mediums.
In the event that personal information has been or is compromised as a result of a breach of security, DEVGAME will promptly notify those persons whose personal information has been compromised, in accordance with the notification procedures set forth in this Policy, or as otherwise required by applicable law.
To protect your privacy and security, we may take reasonable measures (such as requiring a unique password) to verify your identity before permitting you access to your account or the Service. You are responsible to maintain the secrecy of your unique password and account information, and for controlling access to your email communication or interaction through the Site or DEVGAME’s authorized social networking at all times.
Your rights and choices in relation to your personal information
Accessing, correcting, or deleting your personal information
DEVGAME takes your privacy seriously and works in a transparent way. In that sense, upon providing sufficient identification (to protect others’ privacy), you can request information from us about the personal information we hold in relation to you and you can correct any inaccurate data we hold.
Furthermore, you can change or delete any personal information by changing the applicable information found in your DEVGAME account. However, by deleting the entirety of this information your account may become deactivated.
In certain territories (including the EU), you also have a legal right to ask for a restriction of processing, to object to processing as well as the right to data portability. However, these rights are subject to conditions and may not always be applicable.
You have the right to withdraw your consent, on the basis of which we process your personal information, at any time, by closing your account or otherwise clearly indicating your withdrawal of consent. However, this does not affect our lawful processing based on your consent before this withdrawal.
We may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Service you have requested or received from us.
We may occasionally send you push notifications through our mobile applications 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.
Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page information about opting out of interest-based advertising and your choices regarding having information used by NAI members. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.
Users in the European Union may go the European Interactive Digital Advertising Alliance (“EDAA”) Your Online Choices website and select their country to learn more about interest-based advertising and how to opt out in their own country. For example, users in France may go to the Controler ses cookies website to opt out of certain third-party ad networks’ interest-based advertising and find additional information at www.youronlinechoices.com/fr.
Opting out from one or more companies listed on the DAA Consumer Choice Page, the NAI Consumer Opt-Out Page, or through the various EDAA websites will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or App or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). If your browser is configured to reject cookies when you opt out on the DAA, NAI, and/or EDAA websites, your opt out may not be effective. Please note that if you use multiple devices you will have to opt out on each individual device.
Links to other websites or applications
Policy regarding children under the age of 13
Through other Services, however, DEVGAME may be more likely to collect some personal information about children under 13. For such Services, DEVGAME will request users’ ages and, if a user indicates that s/he is under 13, DEVGAME will only collect personal information, such as persistent identifiers (e.g., IP address and device information), necessary for internal operations of the Service. DEVGAME will only use such information to support internal operations of the Service and not for other purposes.
If you are under 13, please do not attempt to register an account with any of the Services or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information other than persistent identifiers used to support internal operations of the Services, from a child under the age of 13, we will delete that information as quickly as possible. We recommend that minors over the age of 13 ask their parents or guardians for permission before sending any information about themselves to anyone over the Internet.
1. THE INFORMATION WE COLLECT FROM CHILDREN, HOW WE USE IT, AND HOW AND WHEN WE COMMUNICATE WITH PARENTS
DEVGAME offers to its users a range of sites and applications, some of which are primarily targeted at children, and others that are intended for users of all ages and their families. Our sites and applications offer a variety of activities, including activities that may collect information from children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.
Children can, in many cases, register with our sites and applications to view content, play games, participate in contests, and engage in special features, among other things. During the registration process, we may ask the child to provide certain information for notification and security purposes, including a parent or guardian’s email address, the child’s first name and gender, the child’s member or account username, and password. We also may ask for birth dates from children to validate their ages. We strongly advise children never to provide any personal information in their usernames. Please note that children can choose whether to share their information with us, but certain features cannot function without it. As a result, children may not be able to access certain features if required information has not been provided. We will not require a child to provide more information than is reasonably necessary in order to participate in an online activity.
About the collection of parent email address: Consistent with the requirements of COPPA, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 12 or under, we will ask for a parent or guardian email address before we collect any personal information from the child. If you believe your child is participating in an activity that collects personal information and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please feel free to contact us at firstname.lastname@example.org. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
Content Generated by a Child
Certain activities on our sites and applications allow children to create or manipulate content and save it with DEVGAME. Some of these activities do not require children to provide any personal information and therefore may not result in notice to the parent or require parental consent. If an activity potentially allows a child to insert personal information in their created content, we will either pre-screen the submission to delete any personal information, or we will seek verifiable parental consent by email for the collection. Examples of created content that may include personal information are stories or other open-text fields, and drawings that allow text or free-hand entry of information. If, in addition to collecting content that includes personal information, DEVGAME also plans to post the content publicly or share it with a third party for the third party’s own use, we will obtain a higher level of parental consent.
About Verifiable Parental Consent:
Email Consent. In the event DEVGAME wishes to collect personal information from a child, COPPA requires that we first seek a parent or guardian’s consent by email. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child in connection with that activity.
High-Level Consent. In the event DEVGAME collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to asking for a credit card or other payment method for verification (with a nominal charge involved), speaking to a trained customer service representative by telephone or video chat, or requiring a signed consent form by mail, email attachment, or fax. After providing high-level consent, a parent may have the opportunity to use a pin or password in future communications as a way to confirm the parent’s identity.
Teacher consent in lieu of a parent. With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit the FERPA site.
Certain games and activities that are directed to children allow users to communicate directly with other users by means of a chat system. In most cases, these chat systems employ filters that are intended to prevent the communication of both personal information and age-inappropriate words and phrases. In addition to filters, we may employ live moderation and/or encourage other users to flag inappropriate communications. We strongly encourage children who use these interactive features on our sites and applications never to provide personal information about themselves or any third party, and certainly never to attempt to circumvent our filters or moderation. We also recommend that parents carefully supervise their children when the children participate in online activities.
Where DEVGAME employs a chat system that does not filter all or nearly all personal information, we will first seek high-level consent from the parent.
Contests and Sweepstakes
For contests and sweepstakes, we typically require only the information necessary for a child to participate, such as first name (to distinguish among family members) and parent email address (to notify the parent where required by law). We only contact the parent for more personalized information for prize-fulfillment purposes when the child wins the contest or sweepstakes.
Of course, some contests and sweepstakes ask the child to submit their own created content along with the child’s entry. In those instances, we may require parental consent prior to submission.
Email Contact with a Child
On occasion, in order to respond to a question or request from a child, DEVGAME may need to ask for the child’s online contact information, such as an email address. DEVGAME will delete this information immediately after responding to the question or request.
In connection with certain activities or services, we may collect a child’s online contact information, such as an email address, in order to communicate with the child more than once. In such instances we will retain the child’s online contact information to honor the request and for no other purpose such as marketing. One example would be a newsletter that provides occasional updates about a site, game/activity, television show, personality/character, or feature movie. Whenever we collect a child’s online contact information for ongoing communications, we will simultaneously require a parent email address in order to notify the parent about the collection and use of the child’s information, as well as to provide the parent an opportunity to prevent further contact with the child. On some occasions a child may be engaged in more than one ongoing communication, and a parent may be required to “opt-out” of each communication individually.
Push notifications are notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not in use. We will require a child to provide a parent email address before the child can receive push notifications from our child-directed applications that collect a device identifier. We will then provide the parent with notice of our contact with the child and will provide the parent the opportunity to prevent further notifications. Finally, we will not associate the device identifier with other personal information without contacting the parent to get consent.
If a child-directed DEVGAME site or application collects geolocation information that is specific enough to equate to the collection of a street address, we will first seek parental consent via email.
When children interact with us, certain information may automatically be collected, both to make our sites and applications more interesting and useful to children and for various purposes related to our business. Examples include the type of computer operating system, the child’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our sites or applications, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers. This information may be collected by DEVGAME or by a third party. This data is principally used for internal purposes only, in order to:
- provide children with access to features and activities on our sites and applications
- customize content and improve our sites and applications
- conduct research and analysis to address the performance of our sites and applications
- generate anonymous reporting for use by DEVGAME
In the event we collect (or allow others to collect) such information from children on our sites and applications for other purposes, we will notify parents and obtain consent prior to such collection.
2. WHEN INFORMATION COLLECTED FROM CHILDREN IS AVAILABLE TO OTHERS
In addition to those rare instances where a child’s personal information is posted publicly (after receiving high-level parental consent), we also may share or disclose personal information collected from children in a limited number of instances, including the following:
- We may share information with our service providers if necessary for them to perform a business, professional, or technology support function for us.
- We may disclose personal information if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal information collected from children (i) in response to a law enforcement or public agency’s (including schools or children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our sites or applications; (iii) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.
3. PARENTAL CHOICES AND CONTROLS
At any time, parents can refuse to permit us to collect further personal information from their children in association with a particular account, and can request that we delete from our records the personal information we have collected in connection with that account. Please keep in mind that a request to delete records may lead to a termination of an account, membership, or other service.
Where a child has registered for a DEVGAME account, we use one method to allow parents to access, change, or delete the personally identifiable information that we have collected from their children: Parents can contact us to request access to, change, or delete their child’s personal information by sending an email to us at email@example.com A valid request to delete personal information will be accommodated within a reasonable time.
Changes to this policy
DEVGAME may amend this Policy from time to time. Use of information we collect now is subject to the Policy in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our Service or sending you an email. You are bound by any changes to the Policy when you use the Service after such changes have been first posted. If you object to any change, your sole recourse shall be to immediately terminate your account and cease using the Service.
Questions or concerns
If you have any questions or concerns regarding privacy at DEVGAME, please contact our Support team at firstname.lastname@example.org.
While we prefer that you contact us in case you have any issue or feel we do not respond adequately to your questions or concerns, please note that you have a right to lodge a complaint with your competent supervisory authority.