©2019 by Doublethink Games

Privacy Policy

PRIVACY POLICY

This Privacy Policy is part of the Terms of Service agreement and is governed by the terms and conditions in the Terms of Service, found on our website at www.doublethinkgames.com.  The Privacy Policy describes how Doublethink Games (the “Company”) uses, stores and protects your information when you use our website, Apps, a device upon which our App is pre-installed or any other websites, features, content or pages that are owned or operated by Company.

AGREEMENT TO THIS POLICY

BY INSTALLING OR DOWNLOADING THE APP OR SERVICES, YOU WARRANT AND AGREE THAT YOU HAVE READ THIS PRIVACY POLICY AND THE TERMS OF SERVICE, THAT YOU UNDERSTAND THE TERMS AND CONDITIONS OF BOTH THE PRIVACY POLICY AND THE TERMS OF SERVICE AND THAT YOU AGREE TO EVERYTHING.  IF YOU  DO NOT AGREE WITH ANYTHING IN THE PRIVACY POLICY, YOU MUST NOT USE OR ACCESS THE SERVICES.


LABELS USED IN THE PRIVACY POLICY

Company is a data controller for any personal information collected from users.  A “user” is  someone who provides personal information to us by creating an account with an App, signing up for a newsletter or otherwise using or accessing our services.  A “data controller” is a person or entity that determines which information and processed and how it is processed.  Any third parties acting as service providers are “data processors” and they act according to our instructions.


PERSONAL INFORMATION

We may transfer, process or maintain your personal information on servers or data bases outside of your country or jurisdiction.  The data protection laws in another country or jurisdiction may not be as protective as the laws in the state where you live.  If you do not agree to this, do not download the App or use the website or other services.


INFORMATION THAT YOU GIVE US VOLUNTARILY

You provide us with some information voluntarily when you access or use services.  This includes::

  1. Your e-mail address is required to register when you sign up to create an account with some of our Apps.  As an alternative, you could choose to use your Facebook account or other social media account for registration.  If you do choose to use a social media account, we will need you to provide the e-mail associated with that account but you will be able to choose what other information you are willing to share.

  2. When you use some of our services, you may be able to add information to your profile on social media if you register through social media.  You voluntarily provide that information to us by deciding to register through social media.

  3. When you use some of our content and provide us with access to your photos, files and media, camera and microphone, you are voluntarily giving us access to the data and content in the files, media, photos, camera or microphone.  


INFORMATION THAT COMPANY COLLECTS AUTOMATICALLY

Company collects information about you automatically when you use services.

  1. Information collected automatically when you access services through a mobile device may include:   general location of your mobile device, Bluetooth settings, internet connection, brand and model of your mobile device, your mobile device’s operating system, screen size, system version, make, model and resolution, random access memory and advertising ID, the App that you have installed and the applications running in the background.

  2. Tracking technology such as Cookies may be used to collect information such as account activation time, content displayed to you and whether you have clicked on it, URLs that you visited, your Internet Protocol (“IP address”) your mobile country code, your user ID, and ads displayed on your device and whether or not you clicked on them.  

  3. Depending on the adjustments you may make to your device or browser settings, we may automatically collect information about your call information settings and Wi-Fi connection when you share content with us.  By making adjustments to prevent collection of information, you may prevent us from providing some functions.  

  4. Information that you put on social media or third party websites may be shared with us automatically if the third party site collects or shares the information.  Company recommends that you review the privacy policies and settings on third party websites that you contact through a link to make sure that you understand their privacy protection policy.


INFORMATION FROM CHILDREN

We do not knowingly collect information from children under the age of 18 unless it is permitted by law.  Children are not permitted to use services unless they provide Company with consent from a parent or legal guardian.  If we learn that we have unknowingly collected personal information from a child, we will make all reasonable efforts  to remove that information from our data base.  Parents and guardians of children who have provided us with personal information are encouraged to contact us immediately.


THIRD PARTIES WHO MAY SEE YOUR INFORMATION

In some circumstances, company may share your personal information with third parties.  This includes:

  1. Company employees and those who work for us to deliver service to you may need access to your information to do their jobs.   This includes contractors, affiliates, dealers, distributors and service providers who operate or support our services by doing marketing or consulting or analyzing data.   We give them the least amount of personal information needed to do their job.

  2. Information may be provided in response to a subpoena or court order, to protect the rights of other users, third parties or the general public or to prevent you from abusing our services to engage in spamming, to attack our systems or get unauthorized access to our system or to violate the law.


WHAT DO WE DO WITH COLLECTED INFORMATION?

Unless we specifically tell you otherwise, your personal information will only be used as we tell you here.  You can choose not to share information with third parties who will use it for marketing or any other reason.  If you decide to limit the ways we can use your information, you may make some services unavailable.   We collect information for the following purposes:

  1. Certain information is needed so we can provide the services that you want.  This might include your contact information and device information.  We only share this information with service providers and employees to the extent that we must in order to provide you with services.

  2. We collect some information to personalize your experience with our services by keeping track of your preferences.   This may include your display name, time zone, language preference or knick-name.  If you are in a Designated Country, we process your information to satisfy our legitimate business purposes.

  3. We collect some information so that we can communicate with you about services.  We use your contact information for administration and account management, to give you updates about service, to exchange information about a transaction and to tell you about security issues.  Service-related communications are not promotional.  You cannot choose not to get these communications because they are necessary for use services.

  4. We use your personal information to enforce and to improve security, to combat malware and spam or other security risks and to verify your identity so we can protect your account from being accessed by others without authorization.    If you are in a Designated Country, your personal information is processed in accordance with our contract with you.

  5. We use your personal information to provide you with customer service.  We use it when you contact us with a problem or question or concern.  This information is necessary so that we can be responsive to your needs and to help you to continue to use and enjoy services.

  6. Your personal information is necessary so that we can pay our taxes, fulfill our other business obligations and manage risks as the law requires.  We must process information to meet our legal and regulatory requirements while providing services.  If you are in a Designated Country, we process your personal information to comply with legal obligations.

  7. We process information about your use of services and interactions on our services to improve services, create new services and build customized services or features.  This is necessary to keep you satisfied with our services.  If you are in a Designated Country, your personal information is processed to satisfy our legitimate business interests.

  8. We may process your contact information or information about interactions with services to send you information about events, webinars or other materials and to keep you up-to-date with products and services. If you share a friend’s contact information with us, your friend may be invited to receive services or communications from us.  You can choose not to receive marketing communications, but this does not include as transactions communications about your account or our services.   


SECURITY

Security is important to us.  We have physical, administrative and technical safeguards for keeping your personal information safe and confidential.  All service providers who have access to your personal information are required to undergo training to keep your information safe.  However, we cannot guarantee that your personal information will not be lost, misused, taken without authorization or that data will not be altered.   We cannot protect your personal information that is beyond our control, like information sent by e-mail or wireless connections.

You share the responsibility for security.   Choose a password that is long enough and complex enough to keep it confidential.  Do not leave your device unprotected or available for unauthorized people to access.  Use only a trustworthy wireless connection.  If you believe that your account has been used or accessed by someone without authorization, contact us immediately.


HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We try not to keep your personal information longer than necessary.  Retention periods vary from country to country, but use generally follows the following guidelines.

  1. Marketing information is stored until your unsubscribe.  

  2. We may indefinitely store information about your interactions on our services and any content that you create or post or share about our services after your account is closed.  This is for our protections in case of audit or legal claim or for crime prevention.

  3. Phone calls will not be recorded unless you are first informed.  Then the  recording may be kept for up to six (6) years.

  4. We keep information collected via cookies, flash cookies, clear gifs, webpage counters and other analytic or technical tools for up to one year from the date of collection or expiration of the cookie.

BUSINESS TRANSFERS OR BANKRUPTCY

If Company merges with another company or a significant part of its assets are purchased by another company, your personal information may also be sold or transferred.  If the Company declares bankruptcy, your personal information may be considered a business asset.  We would notify you by e-mail or a prominent notification in our Services of any such occurrence and we would also tell you about any choices you may have concerning your personal information.  A bankruptcy court or other court could also order disclosure of personal information.  A company that purchases Company would control your personal information according to the new company’s privacy policy.



WHY DO WE PROCESS YOUR PERSONAL INFORMATION

You have, by using or accessing services, agreed to let us process your personal information.  We process information to satisfy our legal responsibilities and duties, to protect your vital interests, to carry out our contractual obligations to you or to do something you have asked us to do before entering into a contact with you, to protect the public interests and to protect our legitimate interests.



USERS IN THE EUROPEAN ECONOMIC AREA, UNITED KINGDOM OR SWITZERLAND

If you reside in the European Economic Area, the United Kingdom or Switzerland when we collect data, we may ask you to tell us which country you are located in, or we may rely on your IP address for that information.  If we rely on your IP address, we cannot apply the terms of this section to any other user that hides or obfuscates location information so that the user does not appear to be in a Designated Country.  If any terms in this section conflict with other terms in the Privacy Policy, then the terms in this section are applicable to users in the Designated Country.

Whenever we collect, process or use your personal information, we will do so according to our contract with you, as required by the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively referred to a “Data Protection Laws.”)   

Company will transfer your personal information subject to appropriate safeguards under the Data Protection Laws. When your personal information is transferred from your country, we have the required contractual provisions in place with the third parties receiving the information.  We rely on legal transfer mechanisms or we work with third parties who have been certified under the E.U.-U.S. and Swiss-U.S. Privacy Shield Framework.

We will only contact you by electronic means (SMS or e-mail) if you are a current User, in accordance with your communication preferences or other information you provided when you purchased from us.   If you are a new user, we will only contact you by electronic means for marketing purposes if you have agreed to this contact.  You can withdraw your consent or change your preferences for marketing communication for free at any time.  Marketing promotions do not include communications about service or transactions but are only promotional.

In accordance with the Data Protection Laws, we process your personal information based on our contract with you, our legal obligations, the public interest and your vital interests.


CALIFORNIA RESIDENTS

Pursuant to California Law, residents of the State of California may request a free notice each year describing what categories of personal information, if any, with third parties for their direct marketing purposes during the preceding calendar year.  To request a copy of the notice, please contact us via e-mail and ask for a “California Privacy Rights Notice.”   Please allow at least thirty (30) days for us to respond.

California residents under the age of 18 who are registered Users may request that we remove content or information that you posted or stored on our servers.  To make your request, send us an e-mail clearly identifying the content or information that you want removed.  Be sure to give us enough information to allow us to locate the content or information.   We are not required to delete content or information:

  1.    If other state or federal laws require it to be maintained by us or a Third Party;

  2.    If another user has posted, stored or republished it;

  3.     If the content or information is made anonymous so that the minor cannot be    identified;

  4. You do not follow these instructions for requesting removal of the content; or

  5.   The minor has been paid or compensated or otherwise received consideration for providing that information or content.   


YOUR RIGHTS

Your rights are important but they are not without limitation.   They may be limited by the law, the need to protect another’s privacy, our rights and properties or when a request to exercise a right is frivolous or burdensome.   To exercise a right under applicable law or this agreement, contact us, verify your identity and tell us what right you want to exercise.

  1. You have the right to access and to correct the information we store about you.  If you request a copy of your personal information in our storage, we will give you a copy without undue delay. We will charge a fee only if it is permitted by law.  This right may be limited by the rights and freedoms of other individuals.  You can correct our information about you either through services or by contacting us.

  2. You have the right to have your personal information deleted when it is no longer necessary for the purpose for which it was collected or processed, or if it was collected for a processing activity that you now object to having performed, or it if you have withdrawn your consent for the processing that it was collected to perform.  This right may be restricted if Company has overriding legitimate needs for the processing.

  3. You have the right to withdraw consent to process your personal information.  This right may be exercised at any time but withdrawal of consent does not affect the lawful nature of the processing or processing by a Third Party based on consent that you gave before withdrawal.

  4. You have the right to restrict our processing of your personal information under certain circumstances as follows.  You may restrict processing if you contest the accuracy of the information.  This right is applicable only to personal information that you provided to us or that Company automatically collected.  Invoking your right to restrict processing may result in an interruption of service while we verify your identity.  You may restrict processing if it is unlawful and you request restriction of the information instead of erasure.   You may also restrict processing if we no longer need the information for the purpose for which it was collected but it is important to you in order to establish, exercise or defend against legal claims or if you have objected to processing pending proof that our legitimate grounds for processing override your rights.  If you exercise your right to restrict processing, we will inform you when or if the restriction is lifted.

  5.  You have the right to receive a copy of your personal information upon request.  We will provide you with information in a machine-readable format that is structured and commonly used.  Unless it adversely affects the rights and freedoms of others, we will provide the information directly to you or to another “controller” where technically feasible.

  6. You have a right to object to our processing of your personal information at any time according to applicable law.   We may, however, continue to process your personal information if it is necessary to defend Company against legal claims or for any other exceptions under the law.

  7. You have a right to have us notify third parties with whom we have shared your information if you invoke your right to correct, erase or restrict your personal information.   We will do this if you ask us to do so and if it is not impossible or requires a disproportionately great effort.   

  8. You have a right not to be subject to automatic decision-making based on profiling of your personal information which results in significant effects upon you, unless the law so permits.

  9. You have a right to make a complaint about Company or its services.   If you believe that we have violated your rights, please contact us so that we may resolve the issue.  You also have a right to lodge a complaint with the competent supervisory authority where you live or work or where the violation of your rights occurred.


CONTACT INFORMATION

Please contact us through e-mail at support@doublethinkgames.com if you have any questions about the Terms of Service