UPDATED 14th May 2018
There are two types of information which may be registered with the use of Webpages/Apps:
“Personal data” which consist of information which can be related to a specific user, such as full name, address and email address, phone number, picture, location, credit card information and, in some cases, username; and
“Usage data” which consist of anonymous information registered by the use of the Webpages/Apps, linked to the computer and/or device used for this.
1.- How we register and process Personal data and Usage data:
If you decided to open an account with us, we shall register your name, address and email address and/or phone number.
If you connect with one of our Webpages/Apps through a social network, such as Facebook or Game Center (on iOS devices), we shall gather personal information form your profile on this network, such as your name, username and photo.
If you decide to carry out a transaction through our Webpages/Apps, we shall register the data of your credit card or other payment information.
If you decide to use any public forum, comments section or chat apps, we shall compile all information disclosed by this medium.
If you decide to send a message to a specific user or group of users through our messaging apps, chat, comments or others, we shall gather all the information you disclose therein, as well as the relevant personal information of the user(s) with whom you have been in contact, in order to facilitate communication (note: we shall not compile information sent which is not linked to our Webpages/Apps, including emails and text messages).
If you decide to enable notifications, ee shall register your Personal and Usage data, such as device ID, in order to send you these notifications.
If you decide to share your Personal data with us for any other reason and in any other way, we shall compile the personal information provided and use it for the purposes for which it has been provided.
We shall gather the following information when use your our Webpages/Apps: IP address of your computer, the unique ID of your mobile device or other linked identification elements, information on your location, the firmware software platform of your device, the type of browser used, the date and time on which you use our Webpages/Apps, the actions you undertake within them, your game progress, the duration of the game, your score and achievements, the URLs visited and/or apps you have used before or after the use of our Webpages/Apps.
We shall not gather any personal data if you only visit our webpage; we shall only register them if you decide to share them with us. You state and guarantee that all Personal data provided by you to use are real and correct and linked to you and no one else.
2.- Use of Personal data and Usage data which we gather
We shall use the Usage data for administrative, analysis and investigation, optimisation, security and other purposes. Specifically, we shall process your Usage data to learn about your game activities, personalise your game content, compile statistics, answer customer service questions, provide security, as well as improving your experience as a player. These data may also be useful to direct publicity to you which might be of interest to you. The information on your location shall be used to determine the jurisdiction in which you are resident and known the applicable law in your case. Your device ID is useful for sending you notifications (if you enable this option) and follow up on your use of our Webpages/Apps in order to better understand your preferences and trends, which will allow us to improve your experience and provide you with offers within the game and tailored notifications.
4.- Disclosure of Personal data and Usage data which we gather
We shall not trade, loan or transfer your Personal data to third parties, unless this is stipulated in this text. We shall not store information of your credit card. Likewise, we shall have a secure server service to process transactions with it.
Associated service supplier parties have restricted access to your Personal data, which they only process for the agreed purposes, such as processing the credit card, granting a prize, marketing assistance, customer service and data analysis. The companies we shall hire for said procedures have access to your information for its use exclusively in the way requested. Likewise, we shall share your Usage data anonymously with these partners to perform administrative, analysis, investigation and optimisation processes.
We may disclose your Personal data or other gathered information if required by law or a judicial order, if said information is linked to a threatening or damaging action, in order to investigate and/or take legal steps against illegal, suspicious activity in terms of abuse and non-authorised use of the Webpages/Apps and in order to protect the property and security of third persons.
With regard to an entire sale of the company or commercial line (including derivative assets), user data are considered to be part of the transferred assets, which includes your Personal data, which shall be shared with or sold to the requesting party if this sale or commercial procedure is performed.
We collect information from a number of different sources, but most of it comes directly from you when interact with our Games, Website, advertising, or other Services. Broadly, the information we collect about you relates to the type of device you are using and how you play our Games (such as levels attempted and purchases made). We may also collect information from advertising platforms and partners and other third parties such as information about purchases and interests.
You are not required to provide any personally identifiable information to us to visit the Website unless you choose to access features on the Website that require such information, for example, using the “Contact Us” page of the Website.
Depending on which of our Services you interact with we may collect and process the following kinds of information:
personal identifiers (such as advertising identifiers when available on a device) and device identifiers (such as IP address, carrier user ID, Media Access Control (MAC) address or social network ID). We may collect, use, and provide access to your advertising identifier in accordance with the applicable platform provider's policies. We are also able to identify when you install a Game as a result of advertisements and/or campaigns that we launch on other services, including in social networks or platforms (e.g. on Facebook or otherwise) and the source-ad which led to such installation, and when a you view or click on such advertisements;
click stream data such as server address and domain name;
location data from GPS-enabled device (to the extent that you explicitly allowed it) provided by the devices’ interaction with the Games or association with your IP address. In addition, third parties may track and collect information regarding your online activities over time and across different online platforms (such as, websites, applications, etc.). For more information regarding your ability to cease such tracking and collection, please see below;
your account number(s) on Google Play Games or Apple Game Center, if enabled;
if you contact us or respond to messages and communications that we send to you, we may collect your name and email address, as well as keep a record of that correspondence;
your interactions with us on our social media channels;
information we collect via cookies and other similar technologies, as explained further below; and
We may also collect, process, and share some technical, statistical, and behavioral information in an aggregated or anonymized manner. In addition to the types of information listed above, this information may include but is not limited to device type, type and version of operating system, network provider, browser identifiers, type of browser, screen resolution, session information, click stream data, SDK version, API key, browser cookies, application version, in-app purchases and data regarding receipt validation, network status, local and time zone, clicks on advertisements, certain information about the advertisements you reviewed, your activities in the Game (including without limitation any information relating to your activity in connection with the advertising displayed therein), and gameplay details such as time spent playing, levels achieved, tools and in-app functionalities used, screens accessed, user retention, performance errors and problems, Game’s stability, crashes, functioning, etc.
5. HOW WE USE INFORMATION ABOUT YOU
We will primarily use the personal information you provide and any general information we receive from you to provide products and services to you. We may use such information:
for statistical, analytical and research purposes for development and improvement of our Services (for example, analyzing and fixing of problems, developing new offerings, providing better content, simplifying and improving your experience including based on preferences shown by usage);
to measure traffic and usage;
to promote our Services;
to enable certain ad serving features, such as, frequency capping (limiting the number of times a specific advertisement is presented to the same mobile device), etc.;
to enable certain functionalities available within the Games, for example in-app purchases;
to ensure proper functioning of the Games and Services;
to respond to questions or requests which were provided using a “Contact Us” feature;
to enable you to use Game Center Features, if available;
for authentication purposes including to verify your identity when you sign in to a Game or interact with our Services, to verify clicks and/or installs, and to verify a user’s identity for the purpose of dealing with inappropriate interactions and/or fraudulent use of our Services;
to measure reach and effectiveness of advertisements campaigns, to offer targeted advertising, to personalize experience by showing advertisements for products and services that are more likely to appeal to you (i.e. behavioral advertising).
to send push notifications to your device after you agree to accept push notifications from us or third parties. You can deactivate push notification by changing the settings within the Game and/or changing the notification settings in accordance with the instructions of the operating system running on your device;
As required or permitted by any applicable law (see below regarding Release of Information for Security); and
for any other purpose explained at the time collected.
7. NOTICE CONCERNING CHILDREN
FredBear Games Ltd is committed to protecting the privacy of children and has no intention of collecting personal data from children under the age of 18. We encourage parents and guardians of children under 18 to regularly check and monitor their children’s use of e-mail and other activities online.
Please note that we provide general audience Services, and do not direct any of our content specifically at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a user of our Services is under age 13, we will promptly delete any personal information regarding that user.
8. WEBSITE SECURITY MEASURES
This section applies only to the Website. Please note:
We do not use vulnerability scanning, malware scanning, or scanning to PCI standards.
We do not allow third-party behavioral tracking.
We have not enabled Google AdSense but may do so in the future.
We honor “Do Not Track” (DNT) signals and do not track, plant cookies, or use advertising when a DNT browser mechanism is in place.
9. RISK OF INTERCEPTION
Please keep in mind that whenever you give out personal information online there is a risk that third parties may intercept and use that information. While FredBear Games Ltd strives to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. By using any Service, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us and that any personal information, general information, or other data or information received from you pursuant to your use of the Services is provided to us at your own risk, which you expressly assume.
10. DISCLOSING INFORMATION TO THIRD PARTIES
Other than to the companies belonging to FredBear Games Ltd for the purposes set out above, and except as described in this Policy, we do not sell, trade, or otherwise transfer your information to third parties without informing you in advance. We provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively, “Service Partners”). Our Service Partners may use your personal information to operate our sites and to deliver their services. For example, your data may be transferred to website hosting partners and other parties who assist us in designing and operating the Website, executing services (such as advertising), or helping us analyze collected data. These parties will only use your data for the purpose of carrying out the work as agreed with us and will be required to keep the information confidential. We encourage our Service Partners to adopt and post privacy policies. However, the use of your personal information by our Service Partners is governed by the privacy policies of those Service Partners and is not subject to our control.
In addition to ads for our Services, we accept advertisements, in various formats (such as banners, interstitials, rewarded videos, etc.) from third-party ad networks that may be displayed in our Games. These third-party ad networks may collect and use information about your interaction with our Services in connection with such marketing, sales and advertising activities; geographic tracking and carrier network preferences; and information, such as age and gender logged from your device to ensure that appropriate advertising is presented within the Game and calculate or control the number of views of an ad, and/or deliver advertisements relating to your interests, and measure the effectiveness of advertisements campaigns.
12. RELEASE OF INFORMATION FOR SECURITY
FredBear Games Ltd will release personal or general information without your consent for security purposes, when required by law, or to prevent imminent harm to any person or entity. We will such information upon receipt of a court order or subpoena, or to cooperate with a law enforcement investigation, which may include responding to requests and court orders from jurisdictions outside the United States. We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful, as determined in our sole discretion. Release of your personal data for security purposes, as described in this Policy to any person or entity under any circumstances shall be based on a determination made solely by us, exercising our own discretion, permission for which is expressly granted by you to us in accordance with this policy.
13. LINKS TO THIRD PARTIES
A cookie is a small string of information that a website you visit transfers to your device for identification purposes. Cookies can be used to follow your online activity on the website and that information helps us to understand your preferences and improve your experience. Cookies are also used for such activities as remembering your user name and password, if such feature is available and you choose to use it. You can turn off all cookies, in case you prefer not to receive them. You can also have your device warn you whenever cookies are being used. For both options you have to adjust your browser settings (such as Chrome, Safari, Firefox, Internet Explorer, or other browser). There are also software products available that can manage cookies for you. Please be aware, however, that when you choose to reject cookies, this choice may limit the Services’ functionality and you may lose access to some of its features.
15. OPT-OUT RIGHTS
To stop all collection of information from the Website, leave and discontinue use of the Website. You can also easily stop all collection of information through a Game by uninstalling the Game.
16. DELETING OR MODIFYING PERSONAL INFORMATION
If you would like to access, modify, or delete any information that can personally identify you, please email your request to email@example.com, and we will respond promptly.
17.- Credit card transactions
If you decide to acquire a product from our Webpages/Apps, you state and guarantee that all information provided on your credit card is true and correct and that you are authorised to use this card. Under no circumstance shall you provide us with false or fraudulent information.
18.- Your rights
We ask you to maintain your Personal data provide to us up to date and that you correct any mistake by contacting us at firstname.lastname@example.org
If you decide to cancel communication with us, or wish to review and/or delete the information stored on you, please contact us and state your request at email@example.com Nevertheless, we reserve the right of preserving the file with your Personal data for some time for administrative purposes and in order to make sure that the way in which this information is eliminated does not constitute damage to the integrity of our database, also conserving an anonymous version of said information.
If you wish to cancel notifications, select the properties tab of the Webpage/App in question and follow the pertinent instruction to remove it.
You have the right of locking the cookies of your browser, in which case we cannot guarantee that the Webpages/Apps shall operate correctly.
If you use the Webpages/Apps, it is your responsibility to maintain the privacy of your account and restrict access to your computer or device, also taking responsibility for all activities conducted on this account.
19.- External companies and sources
21.- Safety of Webpages/Apps
Providing personal information to us is under your responsibility. We and/or our partners have implemented physical, electronic and management procedures to keep safe and avoid unauthorised access to these data, guarantee their protection and use the gathered information from our Webpages/Apps in a correct way. We take, or require that associated parties take, the necessary precautions to avoid the loss, inadequate use, unauthorised publication, alteration and destruction of the information gathered from our users. Nevertheless, remember that the safety of information transferred online or through other wireless networks can never be completely guaranteed. As a result, despite our efforts to protect the data, we cannot ensure or guarantee the safety of the information transferred to or by us by email or other means; and it is you who are responsible for this risk.
If security procedures with regard to your credit card are not complied with on our Webpages/Apps, we shall immediately inform you and shall take the logical steps to resolve the problem.
If you suspect that your data are being inadequately used by us or by third parties, please let us know as soon as possible by email at: firstname.lastname@example.org
If you decide to open an account with use, you should not share your access information with anyone.
22.- Legal notice
23.- Curriculums Clause
In conformity with Organic Law 15/1999 on the Protection of [Personal] Data and its implementing regulations, we inform you that your personal data will be included in the CURRICULUMS file under the responsibility of FredBear Games Ltd. in order to manage the human resources of the company and cover vacancies when necessary.