Privacy Policy
20160218

Scope of this Policy: 
This document describes our policy when collecting, working with, and disclosing your personal information. Note specific applications, games, or services you may install, use, or interact with, may include their own overriding policy or policies.

Definitions:
Personal Information –means information about an identifiable individual. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy.
Collected Information – means information that may include personal, contact, derivatives, or a combination thereof, and any other information related to the individual if present.
Authorized entity – means any permitted person(s) interacting with the applications, games or service, irrespective of the ownership of the mode of interaction. Examples but not limited to may include: multiple people sharing a single device; multiple people sharing a single account, incidental users.
User, customer, client, member – may be used interchangeably and refer to the same authorized entity or entities.
Application, game, service, product – may be used interchangeably to refer to our software, content, and digital materials offerings.
Policies:

1.	Collection:
1.1.	Unless the purposes for collecting personal information are obvious and the client, customer, member voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either in the same collection medium, orally or in writing, before or at the time of collection.
2.	Consent:
2.1.	We will apply reasonable effort to obtain consent to collect, use or disclose personal information, except as noted below.
2.1.1.	Consent may be implied where the purpose for collecting, using, or disclosing the personal information would be considered obvious and the user voluntarily provides personal information for that purpose.
2.1.2.	Consent may also be implied where a notice is given with a reasonable opportunity to opt-out and the user does not.
2.1.2.1.	The notice should describe in brief the purposes of consent and may include document(s) or link(s) to more information regarding the notice.
2.2.	Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product; the withdrawal of consent would frustrate the performance of a legal obligation; an internal or third-party policy, security or systems investigation), users can withhold or withdraw their consent for use of their personal information in certain ways.  A user’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the user in making the decision.
2.3.	Any person or entity interacting with a notice to consent is automatically assumed to be an authorized entity in responding to the notice.
2.4.	
3.	Use and Disclosure:
3.1.	We normally only collect user information that is necessary to fulfill the following purposes:
3.1.1.	To uniquely identify the user and their preferences.
3.1.2.	To open and manage an account.
3.1.3.	To deliver the requested applications, games, service or products.
3.1.4.	To meet regulatory and or legal requirements.
3.1.5.	To meet the requirements of third-party service providers or facilitators 
3.1.6.	To maintain, diagnose, or defend the computer, information, and associated systems.
3.2.	We may use or disclose collected information without further consent in the following limited circumstances:
3.2.1.	When the collection, use or disclosure of personal information is permitted or required by law.
3.2.2.	In an emergency that threatens an individual's life, health, or personal security.
3.2.3.	When the personal information is available from a public source.
3.2.4.	When we require legal advice from a lawyer.
3.2.5.	To protect ourselves from fraud.
3.2.6.	To protect ourselves from unauthorized computer or network attacks, intrusion, or manipulation.
3.2.7.	To investigate an anticipated breach of an agreement or a contravention of law.
3.2.8.	To comply with selected third-party requests and requirements as reasonable.
4.	Retention:
4.1.	Any information collected may be retained as long as reasonably necessary to fulfill the identified, legal or business purposes.
4.2.	Subject to certain exceptions (e.g. the withdrawal of consent would frustrate the performance of a legal obligation; an internal or third-party policy, security or systems investigation), users can request their collected information be disposed. A user’s decision to dispose their collected information may restrict our ability to provide a particular service, or product, or related.  If so, we will explain the situation to assist the user in making the decision.
4.2.1.	Where we deem the disposal of collected information is reasonable, a subset of that information may be retained for the purposes in sections 3.1.4, 3.1.5, 3.1.6, and 3.2.
5.	Access to Information
5.1.	Users may request access to their personal information subject to limited exceptions below:
5.1.1.	The disclosure of the information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization.
5.1.2.	As permitted or required by law.
5.1.3.	The disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request.
5.1.4.	The disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request.
5.1.5.	The disclosure would reveal personal information about another individual.
5.1.6.	The disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.
5.2.	A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. The user can contact a member of our support staff via email for assistance in the identification requirements to locate their information and furnish their request.
6.	Security:
6.1.	We are committed to ensuring the security of collected information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2.	The following security measures have been employed to ensure information is appropriately protected:
6.2.1.	Encrypted communications channels.
6.2.2.	Encrypted storage systems.
6.2.3.	Limited access to systems containing collected information.
7.	Revisions:
7.1.	This policy is subject to change and may be revised at any time.
7.1.1.	We may at our option provide notification of changes.
7.2.	We encourage users to review this policy regularly.
8.	Questions and Complaints:
8.1.	Our support staff is able to respond to your questions or complaints you may have regarding this policy. Please refer to the contact information located on the main page of our website.