Effective Date: September 30, 2016
The Shadow ink limited Group which is comprised of its parent company, subsidiaries and other corporate entities under common ownership (“Affiliates”) operates games in multiple territories worldwide. Depending upon the services you choose and the platform concerned, you may enter into a relationship with our Shadow ink limited entity in Luxembourg, which does business as an SARL or with Shadow ink limited, Inc.which is incorporated in the United States. These particular entities are collectively referred to as “Shadow ink limited.”
PERSONAL INFORMATION DEFINED
"Personal Information" is information that identifies you or that can be used to contact you (online or offline). Personal Information can include your name, email address, physical address, telephone number, gender, birthdate, etc.
COLLECTION OF PERSONAL INFORMATION AND PURPOSES
We collect Personal Information in a variety of ways in order to provide you with the best possible experience using our Services. Sources of information include:
Information You Provide To Us: You may choose to voluntarily provide us with information by registering or communicating with Shadow ink limited. If you communicate with us, we will collect and record the information you have shared with us so that we can provide you with the Services or address your inquiry. During the registration process, we do collect basic information about you including your name and email address.
Third Party Platforms and Social Networks: When you participate in our Services which are provided through a Third Party Service, we may obtain information about you from that service such as your name, gender, geographic area and affiliations. For example, we may use your location in association with your user name to display your game score on a top player scoreboard. Your gender designation derived from a Third Party Service may also be shown but your gender will never limit you on the levels that you can achieve while playing the game (which in the free-to-play context reflects skill, not gender) and/or to a specific gameplay style or type of character. As a developer of an application which is provided through a Third Party Service, Shadow ink limited is required to follow the governing policies of such Third Party Service (including the handling of personal information).
IP Addresses: We do monitor and store information about the IP addresses from which you access our Services. In general, these log files are used to monitor traffic on our Services, to troubleshoot technical problems and to collect aggregate information (e.g., to monitor and analyze demographic and preference information among our users). We may block certain IP addresses to comply with specific license agreements and/or in the event we detect user abuse of our Services. IP addresses could also be used to personally identify you in order to enforce our Terms of Service.
Geolocation: Geolocation refers to the identification of the geographic location of a user or computing device via a variety of data collection mechanisms. Geolocation services use various means to ascertain location including network routing addresses, internal GPS devices and/or the newer W3C Geolocation standard. Our site may use various of these standards depending upon the platform and device that you are using to play our games.
Other Data Collection Mechanisms: We may employ technologies including (i) clear Graphics Interchange Formats (“GIFs”) (i.e., web bugs, beacons or tags), 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 or identifying the source of a new installation or registration; and (iii) local shared objects also known as flash cookies, which help us to prevent fraud, remember your progress on certain in-game tasks and in-game settings. Clear GIFs are not used to collect personal information about you. However, we may use clear GIFs to capture statistical usage information for our web pages, features or other elements on a web page.
AGGREGATED DATA; NON-PERSONAL INFORMATION DATA GATHERING AND ANALYTICS
In addition to Personal Information, we collect a variety of data that is not used to specifically identify or contact you. This type of data is used to analyze and enhance our Services.
Examples of such information include:
General Use Information: We may collect general information about our users’ interaction with our product such as your internet protocol address, browser type, referring and exit URLs, clicks, domain names, pages viewed, the amount of time spent viewing a particular page, the time such activities took place, etc.
Game Play Information: We may collect and retain information relating to your interaction with our Services. For example, we may monitor the number and type of activities you participate in during a particular session, your scores and the length of time you spend on our Services.
Analytic Metrics Tool and Other Technologies: Shadow ink limited uses its own tools and technologies to analyze non-personal information when you use our Services The information collected may include data about your hardware system, mobile device (if applicable), media, Internet and website usage and how you use our Services. We also analyze and track your game statistics, feature usage and purchase history, as well as IP, MAC, Android and/or iOS Addresses, and mobile ID (as applicable).
USER GENERATED CONTENT
User generated content includes various types of content which is publicly available and is produced by end users. For example, wall posts, messages, and actions with other end users would fall under this definition. It is possible that the user generated content you choose to provide may contain Personal Information. Please be aware that we cannot guarantee protection for information you make available publicly through comments, information sharing mechanisms, wall posts, etc. Any user generated content you share while using our Services on a social network, will very likely be disseminated broadly through the social network. Also, any Personal Information that is publicly shared by the user could be harvested by third parties (including by other users of the social network) with access to it and we cannot control those third parties' use of such information. Please bear these factors in mind before sharing any content with us.
WHAT WE DO NOT DO WITH YOUR INFORMATION
Third Party Services - Social Network Data: We do not directly or indirectly transfer any personal information we receive from social networks such as Facebook or Google Play to third parties. However, you should recognize that we may display the information we receive from social networks within our Services. For example, we may display your profile picture, name and location so people can identify you in the Services.
We May Log, But We Will Not Disclose, Individual Internet Protocol Addresses: We may maintain log files which contain IP addresses for purposes such as traffic monitoring. As you know, an IP address is a numeric address assigned to your computer (or router) by your Internet Service Provider. We will not disclose individual IP addresses to third parties.
WHAT WE MAY DO WITH INFORMATION WE COLLECT
Enhancement of Services. We may use the information we collect to improve the quality of our games, facilitate gameplay as well as offer new features to you. This might include looking at how segments of our user population interact with our Services and what areas elicit the most interest. Further, we will also use the information we gather to optimize our content, provide you with more of what you like as well as to fix any bugs that we detect in our Services.
Notices. Occasionally, we do reach out to our players using the contact information you have given us in order to provide information concerning our Services or to announce a new game. You may opt out of these communications at any time.
Legal Requirements and Safety Issues. Please be aware, we will disclose information, including Personal Information, to the extent it may be necessary to prevent harm to third parties or if it is required by law. We may disclose information pursuant to subpoenas, court orders, or other requests if we have a good faith belief that the response is required by law. We may also share information when we have a good faith belief it is necessary to prevent fraud or other illegal activity, to prevent imminent bodily harm, or to protect ourselves and you from people violating the Terms of Service. This may include sharing information with other companies, lawyers, courts or other government entities.
TRANSFER IN THE EVENT OF SALE OR CHANGE OF CONTROL
In the event that we no longer operate a specific game through our Services, we may work with the subsequent game operator to offer you the ability to continue to play the game with the new game operator. This might involve inviting you to create a new user name and password in order to continue playing the game with the new game operator.
SECURITY OF OUR SERVICES
We use encryption and authentication tools to protect the security of the information that you share with us. Once we receive your transmission, we will do our best to protect its security on our systems. For example, all personal information we gather in connection with our Services is maintained on a secured server behind a firewall.
Unfortunately, while we strive to protect your personal information, no data transmission over the Internet can be guaranteed to be 100% secure and we caution you that any information you transmit to or from our Services is at your own risk. Accordingly, we disclaim liability for any theft, loss, or interception of or any unauthorized access or damage to any data or communications. By using the Services, you acknowledge that you understand and agree to assume these risks.
You may review, update, correct or delete personal information we receive from a Third Party Service by updating that information on your profile. If you elect to register with us and you would like to review, update, correct or delete that personal information, you may do so by removing and unsubscribing yourself in our email notifications. If you have any difficulties implementing any such changes on a Shadow ink limited Service, please contact our Customer Service team for the applicable Service and/or write to privacy@Shadow.ink.
If you access our Services through a Third Party Service such as Facebook, links may appear in the same window or on screens before you commence playing. Any links you see adjacent to our Services may link you to parties completely unrelated to Shadow ink limited. Because we cannot control the activities of third parties, we cannot accept responsibility for your use of their services or 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 ourselves. The presence of a third party link within the Services does not represent an endorsement of the content of that third party's link and Shadow ink limited disclaims all liability arising from such content.
Personally identifiable information provided to Shadow ink limited will be collected, processed and stored by Shadow ink limited in the European Union (“EU”), Russia and the United States.
As part of our international operations, our Affiliates have access to such personal identifiable information data for our legitimate business purposes. To operate and distribute the Services, our Affiliates provide certain services to Shadow ink limited. Shadow ink limited stores information about site visitors, players, gameplay and players’ transactions on servers located in the EU, Russia and the United States. Shadow ink limited may also store such information on servers and equipment in other countries. Personal data collected within the EU and Switzerland may be transferred to, and stored at a destination outside of the EU and Switzerland (e.g., in the United States and Russia). The data we hold may also be processed by employees who work for us or one of our Affiliates, or for one of our vendors outside of Switzerland and the EU. For example, such parties may be involved in payment processing or provide support services for our games.
To the extent that any of our Affiliates have access to personal identifiable information derived from the Services, such Affiliate will adhere to applicable laws.
OTHER JURISDICTIONS; RIGHT TO ACCESS PERSONAL INFORMATION AND OPT-OUT RIGHTS
If you are resident in a jurisdiction which grants you the right to access the personal information that we maintain concerning you and/or any disclosures we may have made concerning such information, 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 privacy@Shadow.ink.
If you are resident in a jurisdiction where we are required to notify you that you may choose to opt out of Shadow ink limited’s disclosure of personal information to third parties for direct marketing purposes, your right to opt out can be exercised by writing to privacy@Shadow.ink.
CHILDREN AND PRIVACY
Our Services are not directed to children under 13 years old. By using our Services, you represent and warrant that you are at least 13 years old. If we become aware that a user under the age of 13 has registered without prior verifiable parental consent, we will remove that user's personal information.
If you believe that we might have collected any information from a child under age 13, please contact us at privacy@Shadow.ink so that we can investigate and remove the information.
DO NOT TRACK
Some web browsers allow the setting of a “Do Not Track” feature that communicates to websites that you do not want to have your online activity tracked. However, the communication of the Do Not Track signal is not yet uniform across the web.
Currently, Shadow ink limited and its third party service providers do employ tracking technology in order to ascertain, for example, whether you have responded to an advertisement and as a result become an end user of our games. Shadow ink limited also tracks a user’s history and progress in our games.
Shadow ink limited does not interpret, respond to or alter its practices when it receives a Do Not Track signal.
To find out more about "Do Not Track," you may wish to visit www.allaboutdnt.com.
If you have any questions or concerns, please email us at privacy@Shadow.ink