MANAGING YOUR PERSONAL INFORMATION
Effective Date: Dec 11, 2020
DoubleUGames, Inc.(“DoubleUGames”, “We”, or “us”), established under the laws of the Republic of Korea (“Korea”), with address at 16F Gangnam Finance Center (Yeoksam dong), 152 Teheran-ro, Gangnam-gu, Seoul, Korea and business registration number 214-88-96326, recognizes that privacy is important to the visitors, users, customers and other parties (collectively or individually “Users”), who use our games, applications, forums and/or websites (collectively, the “Services”).
We are the controller of the personal information collected. We only collect, use, store and transfer (“process”) your personal information in accordance with applicable data protection legislation, including but not limited to, the (EU) General Data Protection Regulation (2016/679) (“GDPR”) and applicable national data protection legislation.
WHY WE COLLECT E-MAIL ADDRESS
Our primary goals in collecting your email address are to improve our Services by providing a richer, more engaging experience, and to effectively administer your participation. We collect your email address only upon your agreement, and you understand and agree that we may send you emails containing updates, newsletters, or any other contents.
WHY WE COLLECT INFORMATION
Our primary goals in collecting information are to improve our Services by providing a richer, more engaging experience, and to effectively administer your participation. We may need to collect personal information to be able to fulfil our legal obligations or fulfil the terms of a contract we have with you or to be able to even present you with the Services. If you choose not to give us this personal information, it may prevent us from meeting our obligations. It may also mean that we cannot perform the Services needed to run your DoubleUGames accounts or policies. It may also mean that we have to cancel a product or Service you have with us or that you will even be unable to play certain parts of our Services.
WHEN WE COLLECT INFORMATION
We may collect your information when you use our Services, including when:
· You register a DoubleUGames account
· You play our games
· You register on and use our forums
· You contact our Support Center via email or letters
· You use our websites, apps, or games
· You participate in our surveys
· You participate in user research initiatives
· You take part in our competitions or promotions
· You enroll in, or participate in, one of our events
· You click on one of our ads or newsletters
· You work for DoubleUGames
WHAT WE COLLECT
When you register with us on one of the Services, we may ask you for personally identifiable information, whether directly or indirectly, that can be used to contact or identify you (“Personal Information”). We also collect other information that you provide as part of registration and the administration and personalization of your account.
Personal Information that you may provide us with includes email address, username, country of residence, age or date of birth, name, performance data (like the number of clicks, impressions, and installs on an advertisement), certain technical information (e.g. Device ID, IP address, SDK version, adapter and network adapter version, session ID, free memory and external free memory, User ID, Appkey, battery status, limit ad tracking status, OS and OS version, timestamp, device OEM, language, mobile carrier, connection type, App version, non-permanent and anonymous device identifiers such as IDFA (iOS) and/or Advertiser ID (Android)), and nicknames on forums and in games.
Personal Information from third parties we work with: We may receive your Personal Information from third parties or partners, like for example Facebook. We encourage you to be aware when they leave our site to read the privacy statements of each and every website that collects personally identifiable information.
PURPOSES FOR PROCESSING INFORMATION
We may use and process your Personal Information for one of the following purposes:
· to fulfil a contract we have with you;
· when it is our legal duty (for example, to identify your age and make sure we are not collecting Personal Information from children, for bookkeeping purposes and to fulfill our obligations in relation to governmental authorities);
· when you consent to it (for example, by registering for any Services); or
· when it is in our legitimate interest (for example, to enforce our policies, manage our everyday business, to use in an anonymized and aggregated way in order to perform statistical analysis, for direct marketing purposes, to ensure information security, to prevent fraud or to transfer the Personal Information to different part of the organization when necessary).
HOW WE USE YOUR INFORMATION
We will not use your Personal Information for any other purpose than the purpose for which the data is originally collected.
To operate our business and to enhance your gaming experience, we may use your information in the following ways:
· To operate, improve, develop and provide you with our games, apps and Services
· To provide you with recommendations and game offers that you may like
· To respond to inquiries or comments from you
· To verify your identity in order to prevent unauthorized access
· To provide you with software updates
· To understand trends in usage
· To calculate marketing conversion rates and other elements of advertising performance
· To help tracking and correcting errors and bugs in games and services
· To customize your user experience
· To maintain the integrity and security of the Services
· To process transactions and communicate with you regarding these transactions
· To maintain or administer your DoubleUGames account, including contacting you in order to update your DoubleUGames account details if necessary
· To create reports, analyses or similar for the purpose of research and business intelligence and be able to track potential problems, behaviour and trends
· To send you newsletters and promotional notices and offers
· To keep our Services fair, investigate and prevent fraud and illegal behavior
· To comply with applicable laws and regulations
Special information about marketing: We use your data to inform you about relevant products and offers (e.g., provide you with targeted marketing). The data we collect in such cases contain information that you will fully provide us with, the data we collect when you use our Services or from third parties we work with. We analyses this data to form a view on what we think you might want or need or what may be of interest to you.
CONTROL OF YOUR INFORMATION
Be advised that if you send messages or post material containing Personal Information, that information may be collected and used by others.
Note that certain information you post and communicate through a Service or a third party site or service is public information for which you have no expectation of privacy. You may choose to disclose information about yourself in the course of contributing user generated content to our sites or Services or in its chat rooms, blogs, message boards, user “profiles” for public view or in similar forums on its sites through mobile services and/or through third party sites or services. Information that you disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality.
You should be aware that any personally identifiable information you submit in the course of these public activities can be read, collected, or used by other Users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to make public in any of these forums. If you post a video, image or photo through a Service for public view, you should be aware that these may be viewed, collected, copied and/or used by other Users without your consent. We are not responsible for the videos, images or photos that you choose to post through a Service.
DISCLOSURE OF YOUR INFORMATION
We may disclose your Personal Information to other companies and organizations. We will only do so if our partners can provide the same level of security to keep your Personal Information safe as implemented by us and if our partners can ensure that they comply with applicable laws and privacy regulations. We may share your information with the following partners:
· Market Research Agencies
· Game distribution platforms
· Co-publishing partners
· Payment providers
· Advertisers or advertising networks
· Companies and external consultants that help support our platform and services
· Advertising partners and attribution platforms to help us understand the effectiveness of our marketing campaigns
· Please note that our games or products may be advertised in other applications. If you click on one of these advertisements and install our game, you will become a User of our Services. To prevent fraud and verify the installation of the game, we may share your IDFA (iOS) and/or Advertiser ID (Android) with the relevant advertiser.
· We may release your Personal Information when we are required to by a court order, according to law or in the event of a bankruptcy or other similar unfortunate event. We are not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that we receive.
· We may also share and may acquire your Personal Information with future subsidiaries or companies if we choose to sell, transfer or merge parts of our business. We will, however, only transfer the Personal Information if we must and if these companies comply with applicable privacy regulations and can guarantee that your Personal Information will be kept safe.
We will transfer your Personal Information to countries outside the EU and EEA that may not have as strict privacy legislation as where you live.
RETENTION PERIOD OF YOUR PERSONAL INFORMATION
We will keep your information for as long as you are a player or customer of DoubleUGames. We may keep your information for longer for research or statistical purposes. If we do, we will make sure your information is anonymized and non-traceable to you as a person. We will also keep it for longer if we cannot delete it for legal or regulatory reasons.
We will however delete all Personal Information that is no longer necessary after a reasonable period.We will also delete Personal Information upon request.
Our Services are not directed to children and we do not knowingly collect information from children under 13 years of age. We strongly recommend parents or guardians to instruct their children to not disclose any information when online. If you believe that we might have any information from or about a child, please contact us via our Support Center or support e-mail. In the event that we learn that we have collected Personal Information from a child, we will promptly delete it, unless we are legally obligated to retain such data. In addition, we recommend that minors under the age of 16 ask their parents for permission before sending any information about themselves to anyone over the Internet.
THIRD PARTY ADVERTISING COMPANIES
We may use third-party advertising companies to serve ads on the Services.
When advertisers or advertising networks place advertisements on the Services, they may collect or we may share the following types of information from within the Services:
- performance data (like the number of clicks, impressions, and installs on an advertisement);
- certain technical information (e.g. Device ID, IP address, SDK version, adapter and network adapter version, session ID, free memory and external free memory, User ID, Appkey, battery status, limit ad tracking status, OS and OS version, timestamp, device OEM, language, mobile carrier, connection type, App version, non-permanent and anonymous device identifiers such as IDFA (iOS) and/or Advertiser ID (Android))
Advertisers or advertising networks may collect the aforementioned information through the use of tracking technologies like tracking pixels, browser cookies, and web beacons, and they may use a single tracking technology or multiple tracking technologies
Our system and the third-party advertising technology uses information derived from Users’ activity, our cookies on your hard drive, your visits to our site, and the Services you use, to target advertising within the Services.
In addition, our advertisers may use other third-party advertising technology to target advertising on our site and other sites.
In the course of advertisements being served to you, a unique third-party cookie or cookies may be placed on your computer.
Similarly, third-party advertising companies may provide us with pixel tags (also called “clear gifs” or “beacons”) to help manage and optimize our online advertising. Beacons enable us to recognize a browser’s cookie when a browser visits the site on which the beacon is located, and to learn which banner ads bring Users to a given site.
If you do not want us to transfer your information to third parties for personalized ads, please follow the instructions below:
• iOS devices: go to Settings > Privacy > Advertising > enable Limit Ad Tracking. Please note that if you use more than one device, you need to opt-out separately on each device.
• Android devices: Please follow the instructions set forth at: https://support.google.com/ads/answer/2662922?hl=en.
Please note that if you use more than one device, you need to opt-out separately on each device.
If you are interested in more information about online behavioral advertising and your choices to prevent third parties from delivering online behavioral web and mobile web advertising, you may visit the following websites:
We encourage you to review the privacy policies of our advertising network partners to ensure that you understand their treatment of personal data that they may process.
You have the right to access your Personal Information. This includes the right to be informed whether or not your Personal Information is being processed, what Personal Information is being processed, and the purpose of the processing. You also have a right, upon your request, to access information about any evaluation or assessment of the balancing test we are required to conduct when we process your Personal Information based on our legitimate interest. Furthermore, you have the right to rectify or add your Personal Information if such Personal Information is inaccurate or incomplete.As soon as we become aware of any inaccurate information being processed, we will always rectify such Personal Information without undue delay and notify you accordingly. If you have created a DoubleUGames account, you can access, change and delete some of the Personal Information provided on your profile by logging into your DoubleUGames account.
RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL INFORMATION
You have the right to object to the processing of your Personal Information on grounds related to your particular situation. Please note however, that we must still process some of your Personal Information to provide the Services to you. This means that you cannot object to all our use of Personal Information and still require us to provide Services to you.
RIGHT TO ERASURE
You have the right to request that we erase your Personal Information. We will erase your Personal Information upon request if it is no longer necessary for the purpose or we have a legal obligation to store Personal Information.
RIGHT TO RESTRICTION
You have the right to require us to restrict our processing of your Personal Information if you contest the accuracy of your Personal Information, if the processing is unlawful but you do still not want us to erase your Personal Information, if your Personal Information is no longer needed to fulfil the purpose it was collected for or you have informed us that you do not consider us to have a legitimate interest for certain processing.
RIGHT TO RECEIVE A COPY OF YOUR PERSONAL INFORMATION
You can access a copy of your Personal Information by logging into your DoubleUGames account and then contact our Support Center at any time at http://apps.facebook.com/takefiveslots/?action=helpdesk
or email to: email to:firstname.lastname@example.org
ENFORCEMENTOF YOUR RIGHTS
You can contact us at http://apps.facebook.com/takefiveslots/?action=helpdesk
or email to: email@example.com
any time to get a list of all the Personal Information we have collected from you or to get such Personal Information deleted or invoke your other rights as explained above. We will do our bests to answer your request in a timely manner but please note that it may take a couple of days.
Please note that if we cannot identify and guarantee who you are, we might ask you to provide us with additional information or log into your DoubleUGames account if possible. Please note that we will not delete any Personal Information if we are unable to verify that you are their rightful owner. We will however always use our best effort to help you out.
UK and the European Economic Area (EEA) Privacy Representative
In accordance with Article 27 of the GDPR, VeraSafe, LLC (“VeraSafe”) has been appointed as DoubleUGames’ representative in the United Kingdom and in the EEA for data protection matters. If you are located within the United Kingdom or EEA, VeraSafe can be contacted related to the processing of personal data by DoubleUGames. To make such an inquiry, please contact VeraSafe using the contact form available at: https://verasafe.com/public-resources/contact-data-protection-representative.
To contact VeraSafe via telephone or mail, please use the information below, respective of your location:
For users in the United Kingdom:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London, SE1 7TL
Telephone: +44 (20) 4532 2003
For users in the European Economic Area:
Unit 3D North Point House
North Point Business Park New Mallow Road
Telephone: +420 228 881 031
You may also contact DoubleUGames on privacy matters via email at firstname.lastname@example.org
WITHDRAWAL OF YOUR CONSENT AND CLOSING DOWN OF YOUR ACCOUNT
You can log into your DoubleUGames account at any time if you want to remove it. However, we will no longer be able to provide you with certain products or Services if you do so and your game experience will be impacted. You will also lose all of your achievements by closing down your DoubleUGames account and also lose any items or data stored on your DoubleUGames account and any other contents stored on your DoubleUGames account.
It is also possible for you to opt-out from third parties tracking systems, for example via Adjust Opt-Out Tracking on www.adjust.com/opt-out.
You can request deletion of your account information by dissociating or removing our application from your social network or third party service account in accordance with the instructions provided by the social network or third party service.
We are very concerned with safeguarding your information. Your account information is located on a secured server behind a firewall. When you enter sensitive, we encrypt that information using with our best efforts. Because email and instant messaging are not recognized as secure communications, we request that you not send private information to us by email or instant messaging services. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your Personal Information for improper purposes.We encourage you to be careful when sharing your Personal Information with other Users when you use our Services like forums or chats. DoubleUGames will NEVER ask for your password to be sent separately or in clear text. Anyone doing so is probably trying to steal your stuff.
CCPA Privacy Notice
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights please click here
ADDITIONAL QUESTIONS, COMPLAINTS AND FURTHER INFORMATION
You always have the right to lodge a complaint with the relevant authority in particular where you live, work or where an alleged infringement of the GDPR has occurred. Information about privacy rights for EU residents can be found on: https://www.eugdpr.org.