(Last updated on December 21, 2015)
2. Information We Collect
3. How We Collect Information About You
4. How We Use the Information We Collect
5. Sharing of Your Information
6. How to Access and Update Your Information
7. Opting Out of Promotional Communications
8. Our Policies Concerning Children
9. International Operations and Transfers out of Switzerland and the EEA
10. Privacy Policies of Linked Sites and Advertisers
11. Security of Your Information
13. Your California Privacy Rights
14. Contact Us
Collectively, Company describes its activities, including its websites, games and mobile applications, as its service for end users (the "Service"). In this policy, "Company" refers to VC Mobile Entertainment, Inc. and its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We may also refer to Company as "we" or "us".
Information about You Received from an SNS
If you are able to access or use the Service at a TPS or SNS, you allow Company to access certain information from your profile for that TPS or SNS. The information you allow Company to access varies by TPS or SNS, and it is affected by the privacy settings you and your friends establish at the TPS or SNS. You may be able to control and find out more about these settings at the TPS or SNS where you access or use our Service. For example, Company may access and store some or all of the following information, as allowed by you, the TPS or SNS, and your preferences:
Information We Collect from You Directly
When you interact with the Service (whether or not on a TPS or an SNS) through Company games, apps, software, or any Company-owned website, we may collect and store information from you directly as described below:
You may be required to provide the following information: your age or birthday (for age screening and/or to better understand who our users are); your first and last names; your e-mail address; a password and other information that helps us confirm that it is you accessing your account.
We may also offer you the option to complete a user profile that is visible to other Company users. Your user profile may include: a profile photo; one or more game username(s); your gender; biographic details that you provide; links to your profiles on various TPS or SNS; details about the games you play; and a user ID number that is created by Company and used to identify your profile.
The Company user ID number used to identify your account and profile may be public and may appear in the URL of your profile page, but will only permit access to information that is considered public or that you have designated as public in your settings. Your first and last names and profile picture are considered "public" on Company websites that offer direct access to Company's Service and search engines may index this publicly available information.
We may allow you to "register" with us through TPS or SNS authentication options to create an account or profile within the Service. We may also offer you the ability to import your address book contacts or manually enter e-mail addresses so that you can (i) locate your contacts on Company; and (ii) invite those contacts to join you in our Service. We may store those contacts for purposes of helping you and your contacts make connections on our site.
At present, Company intends to use third party payment processing services, so if you purchase a license to use any goods or services in the Service, we will not have access to your credit card details or other billing information used in that transaction. This may change, in which case Company would have access to your payment information, including credit card details, in order to process your purchases or other transactions within the Service. Please note that purchases of third party credits or currencies like Facebook Credits may also be subject to additional policies.
Customer Support Correspondence
When you ask for assistance from our customer support team, we may collect and store the contact information you provide (generally your name and e-mail address), information about your activity on the Service, and your user ID number, if any. We will also store the correspondence and any information contained within.
SMS Notifications, Push Notifications & Local Notifications
If Company offers you the ability to sign up for SMS notifications sent directly to your mobile phone, Company may receive and store the information you provide, including your telephone number.
With your consent we may send push notifications to your mobile device to provide updates and other relevant messages. You can manage push notifications from your account page on the Service.
Technical and Usage Information
When you access the Service, we may collect (i) certain technical information about your mobile device or computer system, including MAC Address, IP Address 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 number(s). For more information on how we utilize cookies and other tracking technologies please review the "Cookies and Automated Information Collection" portion of Section 3 ("How We Collect Information about You").
We may collect information about you in any one or more of the following ways:
Information about Users
When you use the Service, Company collects and stores certain information that you provide directly or through a TPS or an SNS or via other third party services or websites through which you accessed the Service. To provide a richer experience, we also collect information about your use of and interaction with other people and the Service. The bulk of this information is collected and stored through the use of Log Files, which are files on our web servers that record actions taken in our Service.
You may be able to take part in certain activities on our Service that give you the opportunity to communicate or share information not just with Company, but also with other users of our Service. These may include:
We may record and store archives of these communications on Company's servers to protect the safety and wellbeing of our users and Company's rights and property in connection with the service. You acknowledge and consent to the recording and storage of such communications for these purposes.
Cookies and Automated Information Collection
When you access the Service, we may collect certain technical information in order to (i) analyze the usage of our games, applications, sites and services; (ii) provide a more personalized experience; and (iii) manage advertising. We and service providers acting on our behalf use Log Files and tracking technologies to collect and analyze certain types of technical information, including cookies, IP addresses, device type, device identifiers, browser types, browser language, referring and exit pages, and URLs, platform type, the number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, game state and the date and time of activity on our Service, and other similar information. In some cases, we will associate this information with your user ID number for our internal use.
We may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us to advertise more efficiently by excluding our current users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help us to prevent fraud, remember your in-game preferences and speed up load times.
We may collect or receive information from other sources including (i) other users who choose to upload their email contacts; and (ii) third party information providers. This information may be used to supplement your profile and to help you and your friends connect, and may be combined with other information we collect.
In general, we collect, store and use your information to provide you with a safe, smooth, efficient, and customized experience. For example, we may use information collected from you in any one or more of the following ways:
One important use of your information is communication. If you have provided your e-mail address to Company, we'll use it to respond to (i) customer support inquiries, and (ii) keep you informed of your in-game activity, including comments from friends and notifications about in-game statuses. Some messages, such as invites for friends to join you in a game, may include your name and profile photo. We may also send promotional e-mail messages and promotional SMS messages ("Promotional Communications") directly or in partnership with parties other than Company. Each Promotional Communication will generally offer recipients choices about receiving additional messages.
We may share your information (in some cases personal information) with parties other than Company, in the following circumstances:
Third Party Service Providers
We may provide your information to third party companies to perform services on our behalf, including payment processing, data analysis, e-mail delivery, hosting services, customer service and to assist us in our marketing efforts. We direct all such third party service providers to maintain the confidentiality of the information disclosed to them and to not use your information for any purpose other than to provide services on Company's behalf.
Third party site, platform or service operators, such as Amazon, Apple, Facebook or Google, may collect, or require that we provide, your information relating to the Services. Any information made available to such third parties will be used by them in accordance with their own privacy policies. You may be required to consent to, and be fully bound by, those third party privacy policies in order to access, purchase or otherwise use our Services through those third parties' sites, platforms or services. We cannot control, and will not be responsible for, the contents of those third party privacy policies. We therefore advise you to carefully review their terms before accepting them.
Friends and Other Users
The Service may encourage interaction among players. In some Company games your TPS or SNS friends may see your name, profile photo and descriptions of your game activity. In some Company games friends and other players may be able to see your game profile, which may include your name or a "handle" or alias and your profile photo, which in certain cases can reveal your TPS or SNS user ID number or Company ID. Access to a Company ID or your TPS or SNS user ID may allow others to view the public information associated with your related TPS or SNS or Company account.
Advertising of Third Party Products and Services
We may share (i) aggregated information (information about you and other users collectively, but not specifically identifiable to you); (ii) anonymous information; and (iii) certain technical information (including IP Addresses, MAC Addresses for mobile devices and mobile device IDs) to develop and deliver targeted advertising in the Service and on the websites of third parties. We may also allow advertisers to collect these types of information within the Service and they may share it with us. Advertisers may collect this information through the use of tracking technologies like browser 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 ensuring 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). To learn more about behavioral advertising or to opt-out of this type of advertising for participating ad networks, you can visit the Network Advertising Initiative or the Digital Advertising Alliance.
Company may share your information with third party companies for affiliate marketing associated with the promotion of Service if such disclosure is reasonably necessary to conduct, administer, or fulfill such a marketing activity.
Advertising of Third Party Products/Services
Company will not actively share personal information with third party advertisers for their direct marketing purposes unless we obtain your prior consent. Company may share (a) aggregated information (information about you and other users collectively, but not specifically identifiable to you); (b) anonymous information; and (c) certain technical information (including IP Addresses, MAC Addresses for mobile devices and mobile device IDs) to develop and deliver targeted advertising in the third party advertiser's website or application. We may also allow advertisers to collect these and similar types of information within the Service and they may share it with us and/or use it for advertising purposes. Advertisers may collect this information through the use of a variety of tracking technologies, including without limitation, browser 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 ensuring 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).
The Service may contain an "offer wall" that is hosted by an offer wall provider. The offer wall allows third party advertisers to provide virtual currency to users in exchange for interacting with an advertisement or for completing a marketing offer that may include signing up for an account with one of those advertisers. These are not offers made by Company. These offers may be displayed to you based on certain technical information, such as your geographic area or anonymous demographic information. After clicking on one of these advertisements, you will no longer be on a site hosted by Company. To properly credit user accounts and to prevent fraud, a unique identifier, in some cases your user ID number, will be shared with the offer wall provider.
Safety, Security and Compliance with Law
Your information, and the contents of all of your online communications (including without limitation chat text, voice communications, IP addresses and your personal information) may be accessed and monitored as necessary to provide the Service and may be disclosed: (i) when we have a good faith belief that we are required to disclose the information in response to legal process (for example, a court order, search warrant or subpoena); (ii) to satisfy any applicable laws or regulations (iii) where we believe that the Service is being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction; (iv) when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person or the public generally; and (v) in order to protect the rights or property of Company, including to enforce our Terms of Service.
Sale or Merger
Information We Receive From a TPS or SNS
To manage the information Company may receive about you from a TPS or SNS, you will need to follow the instructions at that site for updating your information and changing your privacy settings. You can manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions of each application.
Other Methods of Accessing and Controlling your Information
If you no longer want Company to make active use of your information, you may send an e-mail to firstname.lastname@example.org. Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and user ID number for the SNS from which you access our Service (if applicable) in the body of the e-mail. Please note that certain records will 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. Additionally, any information shared with a TPS or SNS may be retained by those third parties after we delete it from our records. Please consult the privacy policies of those TPS and SNS to learn about their removal procedures.
Information We Receive from TPS or SNS
If you are able to access our Service through a TPS or SNS, Company may be able to access and store profile and other information about you as described above. The categories of information you share with us will depend, in part, on the permissions you grant us and the privacy settings you have established at the TPS or SNS where you access the application. Company does not offer an "opt out" option for specific fields that are shared by the TPS or SNS where you access the Service.
Opting out of Promotional Communications
You may choose to opt out of receiving additional promotional e-mails from Company by clicking on the "unsubscribe" link in any such e-mail. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective.
Opting Out of Other Communications
You can opt out of receiving SMS messages by texting STOP to the number we send from for that particular SMS program. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.
Note that if you opt-out of our Promotional Communications, we may still e-mail or communicate with you from time to time if we need to provide you with information or if we need to request information from you with respect to a transaction initiated by you or for other legitimate non-marketing reasons.
Our Service is not intended for children under the age of 13 and we do not knowingly collect any personal information from such children. Children under the age of 13 are not permitted to use our websites or games at any time. In the event that we learn that we have inadvertently gathered personal information from children under the age of 13, we will take reasonable measures to promptly erase such information from our records.
Company may store information about site visitors and players on servers located in the United States, and Company may also store such information on servers and equipment in other countries. Personal data collected within Switzerland and the European Economic Area ("EEA") may be transferred to, and stored at, a destination outside of Switzerland and the EEA. The data we hold may also be processed by employees operating outside of Switzerland and the EEA who work for us or one of our Affiliates or for one of our vendors. Such staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. By using the Service, you agree to this transfer, storing or processing.
Our websites and games may contain advertisements from companies other than Company that may link to their own websites. We are not responsible for the privacy practices or the content of such websites. If you have any questions about how these other websites use your information, you should review their policies and contact them directly.
Company implements reasonable security measures to protect the security of your information, and we are committed to the protection of customer information.
For user accounts registered directly with Company, profile information is protected by the password each member uses to access their online account. It is important that you protect and maintain the security of your account and that you immediately notify us of any unauthorized use of your account. If you forget the password to your Company account, the website allows you to request that instructions be sent to you that explain how to reset your password. When you sign into your account or enter payment information (such as a credit card number), that transmission is encrypted using secure socket layer technology ("SSL").
While we take reasonable precautions against possible security breaches of our websites and our customer databases and records, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use. If your SNS account is hacked, this may lead to unauthorized use of the Service, so be careful to keep your account information secure. If you have questions about the security of our websites, please contact us at email@example.com.
Unfortunately, the transmission of information over the Internet is not completely secure. Although we strive to protect your personal data, we cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once we have received your information, we have procedures and security features in place to try to prevent unauthorized access.
We do not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by "opting in" to receive information from a third party that is participating in a sweepstakes or other promotion on one of our sites. If you do ask us to share your personal information with a third party for its marketing purposes, we will only share information in connection with that specific promotion, as we do not share information with any third party (other than our service providers) on a continual basis. To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt in to such use when you provide personal information on one of our sites.
Right to Access
Users in certain jurisdictions have a right to access personal information held about themselves. Your right of access can be exercised in accordance with applicable law. Please submit any requests for access to your personal data in writing to firstname.lastname@example.org.
VC Mobile Entertainment, Inc.
6701 Center Drive West, Suite 525, Los Angeles, CA 90045