MobiliSize
PRIVACY POLICY
Last
update: February 13, 2016
MobiliSize Inc. (“MobiliSize”, “we”, “our” or “us”)
respects the privacy rights of our online visitors and mobile customers and
recognizes the importance of protecting the information collected about you.
For our practices regarding children, please see below.
ABOUT
THIS PRIVACY POLICY
This Privacy Policy (the “Privacy Policy”) applies to the
collection, use and disclosure of personal and non-personal information by
MobiliSize and its affiliates through the MobiliSize.com websites (the “Sites”),
the mobile apps published by MobiliSize (the “Apps”) and the Mobilisize programs (the “Programs”) (in this Privacy Policy, the
Sites, Apps and Programs are referred to collectively as the “Platforms”). This Privacy Policy does
not apply to the collection, use or disclosure of personal and non-personal information
through any apps for which MobiliSize is not the publisher.
By using the Platforms, you signify your
assent to our Privacy Policy. If you do not agree to this Privacy Policy,
please do not use any of our Platforms.
We reserve the right to make changes to this
Privacy Policy at any time. Please check the Privacy Policy each time you use our
Platforms to ensure you are aware of any changes in our privacy practices. Our
Privacy Policy will indicate the date it was last updated. Your continued use of
our Platforms will signify your acceptance of the changes to our Privacy
Policy. If there is a substantive or material change in the way that we use your
personal information, we will notify you via email of the relevant changes or
provide other prominent notice. If you choose to opt-out of or not opt-in to
our changed practice, our email communication (if applicable) will contain
instructions on how to do so. If such change affects children users, we will
first notify and obtain the prior verifiable consent of a parent or legal guardian.
HOW
WE PROTECT THE ONLINE PRIVACY OF CHILDREN UNDER 13
MobiliSize takes many precautions to
protect the online privacy of children. Whenever we refer to “children” in this
Privacy Policy, we mean children under the age of 13. Please help us in
protecting children’s privacy by instructing them to never provide any personal
information (full name, email address, home address, phone number, etc.)
without your permission.
MobiliSize follows the principles of the Children’s Online Privacy Protection Act (“COPPA”), a U.S. law designed to
protect the online privacy of children, in our online services and Apps that
are directed to children. If you would like to learn more about COPPA, you can
refer to the “Children’s Privacy” section of the Federal Trade Commission’s
website.
Currently, MobiliSize does not knowingly
collect any personal information from children or within the child-directed
portions of our Platforms except as otherwise outlined in this Privacy Policy. If
we were to collect and store personal information from children, we would
obtain the consent of a parent or legal guardian before such collection, unless
the collection of information falls within an exception that is permitted under
COPPA.
Parents
who have registered their child to the MobiliSize Program should understand
that information, including but not limited to a child's first name, last
name's initial, country of residence and behavioral activity within the beta
version of the app tested, may be collected by MobiliSize. In addition, any
feedback provided by beta testers may be used to make adjustments to and
improve upon MobiliSize products including but not limited to the gameplay,
app flow, story, art and animation.
In our Apps directed to children users, we
collect information which includes persistent identifiers such as a device
identifier (“device ID”) or an
Internet Protocol address (“IP address”).
This information is collected solely for the purpose of providing functionality
and support for our internal operations and optimizing our users’ game
experience.
MobiliSize does not permit behaviorally-targeted
advertising to children in the Apps or in the Platforms where we have actual
knowledge that the user is under the age of 13.
If you believe that we may have
unintentionally collected your child’s personal information without your prior
consent, you may contact MobiliSize’ Privacy Officer:
By email: privacy@MobiliSize.com
By phone: 416-850-7494
By mail: D-769 Kingstod Road, Toronto, ON, M4E 1R9
INFORMATION COLLECTED BY MobiliSize
There are two types of information that may
be collected by MobiliSize. The first is called personal information which is
information that can be used to identify a specific individual. As stated in the
previous section, MobiliSize does not knowingly collect any personal
information from children outside of the information required for the support
of internal operations. MobiliSize may collect personal information that
parents, legal guardians or persons over 13 voluntarily provide on the
Platforms. The second type of information is non-personal information which
doesn’t directly identify an individual. MobiliSize may collect non-personal
information about your use of the Platforms to help us improve our services or
for other purposes as described in this Privacy Policy.
We may combine the non-personal and personal
information you provide us through our Platforms. Information collected will
vary depending upon the activity and may include your name, email address,
phone number, mobile number, device type, operating system, home address, birth
date, statistical and usage data (as further explained below), proof of
identify (such as the Social Security, Social Identification Number or Social
Insurance Number) of contest prize winners and, to the extent required to
process any payment, your credit card information. In addition, we may collect
demographic information such as gender, zip code or postal code and other data
that you may provide in surveys or online profiles, for instance. We may
combine demographic information with personal information.
PURPOSES FOR WHICH WE USE THE INFORMATION
COLLECTED
MobiliSize may use the personal
information you provide us for the purposes of (1) administering contests and
awarding prizes which are only directed to parents and adult users, (2)
warranty registration and/or providing customer support or responding to technical
service requests, (3) providing online services for parents and users over 13,
(4) registration for games or special game-specific event participation for
parents and users over 13, (5) registration for membership and participation on
our Sites or in our MobiliSize program, (6) processing your order(s) of products
or subscriptions from us online, (7) responding to or forwarding your
request(s) for services from third party service providers on our Sites; (8)
enabling your use of our software or online services and access to certain
areas of our Sites, features or programs; (9) beta-testing; (10) newsletter
sign-up or (11) improving our products and services. You are not required to
provide personal information to us to obtain access to any of our Platforms;
however, the collection, use and disclosure of your personal information is
required for registration to access certain areas or features of our Platforms and,
if you do not provide the required information, you will not have access to
these areas or features.
Statistical and Usage Data:
When you use our Apps on your device, we may retrieve information about your
hardware system and how your game is played, including your IP address or
device ID. We may also collect information about your computer, hardware,
software, platform, media, connection, information about online activity such
as feature usage, game play statistics and scores, user rankings, click paths,
and in-app purchases. We use this information to enable you to play our game
over the Internet. We also use this information to better understand the behavior
and preferences of our customers, so that we can improve our products and
services. We work with a third party analytics company (SWERV - www.swrve.com) to help us collect and analyze this
information with the goal of improving our Platforms and providing you with the
best services.
Other Uses: We may also use your information for other legitimate
business purposes. Whatever the purpose may be, we will only collect
information to the extent reasonably necessary to fulfill the purposes for
which it was collected and our legitimate business objectives or as permitted
or required by law.
Use of "Cookies":
Our Sites may use cookies to enhance your experience while using them. Cookies
are pieces of information that some websites transfer to the computer that is
browsing that website and are used for record-keeping purposes at many
websites. Use of cookies makes Web-surfing easier by performing certain
functions such as saving language preferences and maintaining your sessions
while you are on our Sites. The cookies used on our Sites contain generic
information used for page navigation. If you would prefer not to receive
cookies, you can alter the configuration of your browser to refuse cookies. If
you choose to have your browser refuse cookies, some areas of our Sites may not
function properly. We also use cookies related to the use of Google Analytics on our Sites. Google
Analytics uses first-party cookies to report on visitor interactions. These cookies are used to collect information about how
visitors use our Sites. We use the information to compile reports and to help
us improve the Sites. You can opt out of tracking by Google Analytics by
visiting: http://tools.google.com/dlpage/gaoptout?hl=en-GB.In any event, we do not link information collected
through cookies with any personally identifiable information.
Internet Protocol Address:
We collect an IP address from every visitor to our Platforms. An IP address is
a number that is automatically assigned to your computer or device when you use
the Internet. We use IP addresses to help diagnose problems with our servers,
administer our Platforms, analyze trends, track users' movement on our Platforms,
gather broad demographic information for aggregate use in order for us to
improve the Platforms, and deliver customized, personalized content. We do not
link IP addresses with any personally identifiable information.
In-Game Advertising:
Our Platforms may incorporate dynamic advertisement serving technology offered
by our Ad Provider (Chartboost - www.chartboost.com),
which enables advertising to be temporarily uploaded into the game and replaced
while you play. The data collected for this purpose may include IP address or
players’ user name, downloaded or purchased Apps, in game location, length of
time an advertisement was visible, size of the advertisements, and angle of
view. The Apps you are using may be assigned an ID number, which is stored on
your device, and used by our Ad Provider to calculate the number of unique and
repeat views of dynamic in-game advertising. The ID number is not associated
with any personal data and for children-directed Apps is not used for behavioral
advertising purposes. None of the information collected and used for
advertising purposes is used to personally identify you. The servers used by
the Ad Provider may be located outside your country of residence. This ad
serving technology is integrated into the Apps; if you do not want to use this
technology, do not play the Apps while connected to the Internet.
HOW WE SHARE OR DISCLOSE INFORMATION
MobiliSize may
share your information with third parties for the limited purposes described
below.
Third Parties: You
may register for other services from our Platforms which are offered by third
parties. If you opt in to any of these third party services, we may collect
additional information requested by this third party and pass this information,
together with all other registration information (including personal information),
to that third party. Use of your information by a third party will be governed
by that third party’s terms of service and privacy policy. Participation in
these other related services is optional and is not required to play or
participate in any of our Platforms.
Partners:
MobiliSize may also share non-personal information with our brand partners,
which may include without limitation game session information, retention,
purchases, gameplay events and user behavior. MobiliSize does not share any
personal information with these partners.
Marketing: The
personal information you provide will allow us to alert you to new products,
features and enhancements; special offers; upgrade opportunities; and contests
and events of interest. From time to time, we may also inform you on other
companies and organizations that provide products or services that we believe
may be of interest to you. We see this as a value-added service helping you to
find useful products or services. We strive to limit use of the information you
provide to those offers that we think you would appreciate receiving. You may
opt out of this service by contacting us as set out in the opt-out provision
below. Currently, MobiliSize does not share personal information with third
parties for marketing purposes (except to the extent required by law, court
order, or as requested by other government or law enforcement authority).
Service
Providers: We may transfer
personal information to third party service providers that perform services on
our behalf (e.g. processing payment) or otherwise collect, use, disclose, store
or process personal information on our behalf for the purposes described in
this Privacy Policy. Some of these service providers may be located in a
country other than where you reside, including in the United States, and your
personal information may be stored or processed in those countries. We
take reasonable contractual measures to ensure that our service providers
provide appropriate protection for your personal information and use your
personal information only for the purpose of providing the services to us. Your
personal information is subject to the legal requirements of the country in
which it is located, including lawful requirements to disclose information to
government authorities in those countries. Our employees and those of our agents and service
providers who require it in order to fulfill their job requirements will have
access to your personal information.
Legal Rights and Obligations:
Finally, we may use and/or disclose your personal information to enforce legal rights
and comply with the law, or to comply with an order from a government entity or
other competent authority, or when we have reason to believe that a disclosure
is necessary to address potential or actual injury or interference with our
rights, property, operations, users or others who may be harmed or may suffer
loss or damage. When necessary, we may also disclose personal information to
law enforcement, or to the appropriate civil authorities.
MobiliSize does not knowingly share or
disclose personal information other than as set forth in this Privacy Policy.
OTHER
IMPORTANT INFORMATION
Opt-Out Provision: Currently,
MobiliSize does not share personal information with third parties for
marketing purposes. In the event this was to happen, MobiliSize would obtain
your consent prior to any such disclosure. If you do not want MobiliSize to
send you postal mail about our products and services, you can opt out at any time
and choose to have your name removed from our mailing list. You can do so by
contacting MobiliSize’ Privacy Officer:
By email: privacy@MobiliSize.com
By phone: 416-850-7494
By mail: D-769 Kingstod Road, Toronto, ON, M4E 1R9
By providing us your email, you accept to
receive emails from MobiliSize with respect to our products and services. Additionally,
by providing Budge with your email on Facebook, such as through a sweepstakes or
a newsletter sign-up, you accept to receive emails from MobiliSize with
respect to our products and services. If you opt to receive such communications,
you may opt out of this consent at any time by contacting us as described above
or by using the unsubscribe mechanism included in the email communications you
will receive. You may also modify your user settings to edit the email address
related to your account or opt-out of receiving emails, at any time.
You may withdraw your consent to our
collection, use and disclosure of personal information at any time, subject to
contractual and legal restrictions and reasonable notice, by contacting us as
described above. Please note that if you withdraw your consent to certain uses
of your personal information, we may no longer be able to provide certain of
our products or services.
Safeguarding Your Personal Information: We will only collect and use personal information in accordance with this
Privacy Policy to the extent deemed reasonably necessary to serve our
legitimate business purposes, and we will maintain appropriate safeguards to
ensure the security, integrity, accuracy and privacy of the information you
have provided. In addition, we will take reasonable steps to assure that third
parties to whom we transfer any personal information will provide sufficient
protection of that information.
Business Transactions: We reserve the right to transfer any personal information we have about you in
connection with the sale or transfer of all or a portion of our business or
assets or rights relating thereto.
Third Party Sites: If you click on a link to a third party site, including on an advertisement, an
Ad Provider link, or other third party service, you will leave the MobiliSize Platform you are visiting and go to the site you selected. Because
we cannot control the activities of third parties, we cannot accept
responsibility for any use of your personal information by such third parties,
and we cannot guarantee that they will adhere to the same privacy and security
practices as MobiliSize. We encourage you to review the privacy policies of these
third party sites from whom you request services. If you visit a third party
website that is linked to on a MobiliSize’ Platform, you should consult that site’s
privacy policy before providing any personal information on that site.
Reviewing, Correcting and Deleting Your
Information, Requesting Removal from Mailing Lists and Deactivating Your
Account: If you wish to request access to your personal
information or request that such information be corrected or deleted, or if you
have any questions, comments, or concerns about this Privacy Policy or the
information practices of MobiliSize, please contact MobiliSize’ Privacy
Officer (contact information below). Your right to access or correct your
personal information is subject to applicable legal restrictions. We may take
reasonable steps to verify your identity before granting access or making
corrections.
If we have unintentionally collected and
stored any personal information from children under 13, parents can request
access to review such information, have it deleted, or stop our further
collection or use of such information. To make any of these requests (when applicable), please use the contact
information below.
Consent: Generally, by providing
us with personal information, we will assume that you consent to our
collection, use and disclosure of such information for the purposes identified
at the time that we collect the information from you or as otherwise described
in this Privacy Policy. In the case of children under 13, as applicable, we
will obtain a parent or legal guardian’s verifiable consent prior to the
collection of personal information from such users, unless the collection of
such information falls within an exception that is permitted under COPPA.
CONTACT INFORMATION
For
any questions on this Privacy Policy, please do not hesitate to contact us!
By email: privacy@MobiliSize.com
By phone: 416-850-7494
By mail: D-769 Kingstod Road, Toronto, ON, M4E 1R9