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Privacy Policy

NEW PRIVACY POLICY AND CHILDREN’S PRIVACY NOTICE

 

Effective Date: October 7th, 2015.


Prior policy dated June 1, 2013 is available here

 


Overview

You should read this entire Privacy Policy, but here is a partial list of some of the key topics. Any capitalized terms have the meanings given to them where defined in the Privacy Policy.

  • Click here for a summary of each section of the Privacy Policy. Click on the topic for full details.

  • Some of our Services are for a general audience and some are for a mixed audience of users both under 13 years of age and older (“Mixed Audience”), our Mixed Audience Services are designed to comply with the U.S. Children’s Online Privacy Protection Act (“COPPA”). Click here for details.

  • Tracking and Targeting:

    • We as you for, and use Tracking Technologies (defined below), to detect information, and third parties may also do in connection with our Services. Some of the Tracking Technologies may be Location identifying Technologies (defined below). Click here for details, and to find out how to opt out of certain collection and/or uses of your personal information, including Tracking Technologies.

    • Third parties, including advertisers and advertising services providers, may collect information about you. They may use Tracking Technologies in connection with our Services, which may include the collection of information about your online activities over time and across third-party sites or services where permitted by applicable law. Their privacy policies, not ours, govern their practices.

    • We do not monitor or take any action with respect to so-called browser do not track signals.

  • We do not disclose your Personal Information to third parties for their direct marketing purposes without giving you the choice to give or withhold consent.

  • You consent to our practices detailed in our Privacy Policy. Each time you use the Services, the then effective version of our Privacy Policy as posted on our Service will apply to that use, subject to Section 10, so you should check back each time you return for updates. To prospectively change your consent, terminate your account, stop using the Service and uninstall any downloads and apps.

Introduction

Welcome! You have arrived at www.ludia.com and/or are otherwise interacting with our Service (defined below), which is owned and operated by Ludia, Inc. and/or our Affiliates (defined below) (collectively “Ludia” or “we,” “our” or “us”). This Privacy Policy governs your use of any online service location (e.g., web site or mobile app) that posts a link to this Privacy Policy (each a “Site” except when we refer only to our mobile apps, in which case an “App”) (including, without limitation, both mobile and online versions), and also applies to your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other services that we own and control and make available through a Site and/or that posts a link to this Privacy Policy (collectively, the “Service”), regardless of how you access or use them, whether via personal computers, mobile devices or otherwise, but does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy.

Some of our Services are intended for a general audience and are not directed to children under 13 years of age. However, some of our Services are intended as appropriate for all ages, or in other words a mixed audience of users under 13 years of age (“Child” or “Children”) and users 13 and over (“Mixed Audience”). For these Services, we screen for user age and provide a version of the Service for those identified as under 13 that does not collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) except in so far as permitted by COPPA.

This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Service (unless otherwise stated below), and does not govern the data practices of third parties that may interact with our Service. Also, it is limited to our practices and our Service includes access to third party content and services we do not control. Consult their privacy policies regarding their practices.

To the extent we provide you notice on our Service of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the Service’s Terms of Service, which governs your use of the Service, and includes among other things limits on our liability and your remedies, mandatory arbitration, and waiver of jury trial and class actions, some of which may or may not apply to you.

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express or implied (for example, when you provide personal information necessary for a service you have requested or the purpose is obvious). You may be asked to provide your specific consent in some special and specific circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an ”opt out” option provided, if any. Unless required by law, we will not use or disclose, for any new purpose, your personal information that has been collected without first identifying the new purpose and obtaining your consent. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney).

By using our Service, you agree to our Terms of Service (which grants us rights from you, limits our liability to you and limits your remedies) and consent to our collection, use and sharing or disclosure of your personal information and data, and other activities, for the purposes identified or described in this Privacy Policy and Children’s Privacy Notice or otherwise at the time of collection.


Linkable Table of Contents

This Privacy Policy is posted in interactive format to ease your review, especially using smart phones and other devices with small screens. It is important that you read and understand the entire Privacy Policy before using the Service. Each section below contains a brief introductory summary and a link to the full explanation. Click on the headings and the “More” buttons to be taken to the full explanation. Any capitalized terms that appear in but are not otherwise defined in the introduction have the meanings given to them elsewhere in the Privacy Policy.

    1. What Information Does the Service Collect?

    We collect and receive certain information about you as you interact with our Service, explained further in this section. More

      (a) Information About You That You Provide to Us

      We may collect certain Personal Information and Demographic Information that you provide to us when you interact with the Service. For example, we may collect this information through various forms and in various places on the Service, including job application forms, “contact us” forms, and when you otherwise interact with the Service. More

      (b) Information Collected and Stored As You Access and Use the Service

      Certain information may be collected from you automatically when you access and use the Service. For example, we and third parties may use Tracking Technologies to collect Usage Information based on your UID for a variety of purposes, including (where permitted) serving you advertising, based on your having visited our Services or your activities across time and third party locations. We do not look for or respond to do not track signals, but you may have certain other options regarding tracking and/or targeting. This Section provides details on:

  • Usage Information
  • Tracking Technologies
  • Tracking Technologies Usage
  • Tracking Technologies Choices and Consent
  • Third Party Tracking and Do Not Track

More

(c) Information Third Parties Provide About You

We may obtain information about you from third parties. More

(d) Third-Party Content and Services

If you interact with third-party services, such as using Facebook Connect to log in, those services may send us information about you and you or we may send them information about you. More

(e) Information You Provide About a Third Party

You may provide us information about others, such as when you send a friend a message. If so, the information you provide (names, e-mail addresses, etc.) may be used to facilitate the communication, but will not be used for other marketing purposes unless your friend consents. You may be identified to the friend in connection with such a message. More


2. How Do We Use The Information Collected?

We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this section including:

  • Generally
  • Interest-based Advertising and Location-based Services, where permitted
  • Contact Us
  • Use of Information For Recruitment Purposes

More



3. How and When Do We Disclose Information To Third Parties?

We may provide your information to third parties under various circumstances detailed in this section. These may include:


4. Do Third-Party Content, Links to Third-Party Services and/or Third-Party Apps Appear on the Service?

We may allow you to access third-party content on the Service, or to link to or interact with third-party applications and locations from the Service, but we are not responsible for third-party content, apps, and locations. More


5. Are Ads Served On the Service Or Retargeted to You Later?

We and third parties may send you targeted ads based on your location, information and/or behavior, subject to restrictions under COPPA or other applicable law for Children on Mixed Use Services. If you object, do not use our Service and/or exercise choices some third parties may offer. More


6. How Do I Change My Information And Communications Preferences?

You may change certain account information and communications preferences as more fully detailed in this section. More


7. What About Transfer of Information to the United States and Canada?

You consent to your data being transferred to the United States and Canada, which have different data protection laws than other countries, and than each other. More


8. What Should Parents Know About Children? (Children’s Privacy Notice)

We do not intend to collect personal information as defined by COPPA from Children, except as permitted by COPPA. If you think we have, let us know. California minors have certain content removal rights. More


9. What About Security?

No data security is absolute, but we endeavor to take reasonable steps to secure data appropriately. More


10. What About Changes to the Privacy Policy?

We may change this Privacy Policy upon posting of a revised Privacy Policy. However, we will continue to treat your Personal Information under the terms of the privacy policy in effect when it was collected unless you otherwise consent. More


The Full Detailed Privacy Policy

    1. WHAT INFORMATION DOES THE SERVICE COLLECT?

      (a) Information About You That You Provide to Us

      Personal Information and Demographic Information. On the Service, we may ask you to provide us with certain categories of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name and e-mail address (“Personal Information”); and (2) demographic information, such as information about your gender, age, marital status, education level, occupation, hobbies, interests, zip code, etc., some of which may also be Personal Information (“Demographic Information”). We may collect this information through various forms and in various places on the Service, including at registration, job application forms and “contact us” forms, or when you otherwise interact with customer support or with the Service. To the extent Demographic Information is also Personal Information, or to the extent we combine Demographic Information with your Personal Information we collect directly from you on the Service, we will treat the combined data as Personal Information under this Privacy Policy.


      (b) Information Collected or Stored As You Access and Use the Service

      Generally.

      In addition to any Personal Information or other information that you choose to submit to us via our Service, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Service (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Service. To the extent we associate Usage Information with your Personal Information we collect directly from you on the Service, we will treat such combined data as Personal Information, but we do not otherwise treat it (including UIDs (defined below) as Personal Information.

      This Usage Information may include:

  • your IP address, UDID, device identifier or other unique identifier (“UID”). A device identifier is a number that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its device identifier;

  • your Device functionality (including browser, operating system, hardware, mobile network information);

  • the URL that referred you to our Service;

  • the areas within our Service that you visit and your activities there, including remembering you and your preferences;

  • your Device location;

  • your Device characteristics; and

  • certain other Device data, including the time of day, among other information.

Tracking Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. The Apps may also receive signals from and otherwise interact with Tracking Technologies that exist in the physical world (e.g., iBeacons, wifi, and Bluetooth Low Energy at retail locations, discussed below). A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

Cookies. A cookie is a data file placed on a Device when it is used to visit the Service. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. To identify local shared objects on your computer and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 GIFs” or “clear GIFs”) may be included in our Service’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Service, to monitor how users navigate the Service, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Service, and is deactivated or deleted thereafter.

Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.

ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of UID. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.

Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices in the same user).

Location-identifying Technologies. Additionally, the Services may use GPS (global positioning systems) software and other location-based technologies such as iBeacons to locate you so we may verify your location, deliver you relevant content based on your location, as well as allow you to share your location to other users as part of the services we provide via the Services. Upon downloading the App, we provide location-based services to your approximate and/or exact location information. In addition, to traditional GPS location-based services, some of the retailers and others we work with may install low power Bluetooth, wifi, radio transmitters, or other devices in physical locations, which emit a signal that the App can detect to pinpoint your location or otherwise interact with the App (“iBeacons”). Because iBeacons are more precise than GPS, we can improve the Services such as to send you more specific and relevant messages and offers. In addition, you may be able to send your location information via the Services to other Services users. You should consider the pros and cons involved in disclosing your location information to us and to other people. Where a user of the Services requests that their location information be revealed to other persons, the user will be provided options for managing sharing services, which may be through third party services such as through Twitter and Facebook. We are not responsible for the acts, omissions or policies of such third parties.

There may be other Tracking Technologies now and later devised and used by us in connection with the Service.

Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:

Strictly Necessary. We may use cookies or other Tracking Technologies that we consider are strictly necessary to allow you to use and access our Service, including cookies required to prevent fraudulent activity, improve security or allow you to make use of shopping cart functionality.

Performance Related. We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Service, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Service.

Functionality Related. We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Service, including identifying you when you sign in to our Service or keeping track of our specified preferences, including in terms of the presentation of content on our Service.

Targeting Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our Service and third party sites based on how you interact with advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements and content delivered to you. Further information on this, and your opt-out choices, is found in Section 6 below. However, the Mixed Use Services will not use Tracking Technologies, such as cookies, to track user activity for behavioral advertising purposes, except to the extent we do so only for those identfied as non-Children. Mixed Use Services may still use cookies for non-behavioral advertising without regard to a user’s age. Further information on our policies for Children is found in Section 8 below.

Tracking Technologies Choices and Consent.

We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.

Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies some parts of our Services may not work and that when you revisit our Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations. Further, app-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of the App) can only be disabled by uninstalling the App. To uninstall an app, follow the instructions from your operating system or handset manufacturer. For information on third party Tracking Technologies and browser Do Not Track signals, see the next section.

Third Party Tracking and Do Not Track.

Third parties may use Tracking Technologies in connection with our Service, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of our Service and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. For more information on our vendors, and their Tracking Technologies, click here. For more information on advertising and advertisers, and related Tracking Technologies, click here.

Also, various third parties are developing or have developed signals or other mechanisms known as “do not track signals”. For instance, some browsers may have such signal options, though they differ as to if the signal is set as default or must be turned on by the user. Further, there is not yet an industry consensus as to what sites and app operators should do with regard to these signals. Accordingly, we do not monitor or take any action with respect to these signals or other mechanisms, though we may consider doing so if an understandable and practical standard is developed and widely adopted.


(c) Information Third Parties Provide About You

We may receive information about you from your friends and others that use the Service, such as when they submit content to us or post on the Service. Additionally, we may, from time to time with your consent or as permitted by applicable law, supplement the information we collect directly from you on our Service with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the Service, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties (although we take other steps to ensure that we comply with our obligations under applicable law with respect to this information).


(d) Third-Party Content and Services

The Service may include functionality that allows certain kinds of interactions between the Service and a third-party web site, platform, tool, application or other service, and accessing or display of third-party content via the Service. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you register with the Service, you may have an option to use your Facebook or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the Service, or otherwise link accounts. If we offer and you choose to use this functionality to access or use our Service, the third-party service may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our Service. In addition, we may provide third-party services’ interfaces or links on the Service to facilitate your sending a communication from the Service. For example, we may use third parties to facilitate emails, tweets, “likes,” content submissions or postings of comments on Facebook or other social media platforms. We may also enable access to or display of third party content via the Service, that is actually being served or published by the third party, and such third party may be collecting data from you in connection with that content. These third parties may collect and retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Ludia may not control or have access to your communications through these third parties. Further, when you use third-party services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party services in connection with our Service.


(e) Information You Provide About a Third Party

[You may send someone else a communication from the Service, such as sending an invitation to a friend. If so, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our Service, your contact information, name or user name and message may be included in the communication sent to your addressee(s), except when sent by identified Children on Mixed Use Services, in which case the Child’s full name and e-mail will not be disclosed to the recipient. If you send a message to a friend, you represent and warrant to us that you have either obtained the express consent of this friend to do so or that you have a family relationship or a personal relationship with this friend. A “family relationship" means that you are related to this individual through a marriage, common-law partnership or a legal parent-child relationship and have had had direct, voluntary, two-way communication with this individual. A “personal relationship” means that you have had direct, voluntary, two-way communications with this individual and it would be reasonable to conclude that you have a personal relationship with this individual, taking into consideration factors such as the sharing of interests, experiences, opinions and information evidenced in the communications, the frequency of communication, the length of time since you communicated or whether you have met in person. Some of these tools may be third-party tools subject to third-party privacy policies as further detailed in [Section 1(d) and Section 5].]

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2. HOW DO WE USE THE INFORMATION COLLECTED?

Generally. We may use your Personal Information, Demographic Information or Usage Information that we collect about you: (1) to provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the Services’ features such as online entry sweepstakes, contests or other promotion; (3) to process your registration with any of the Services, including verifying your information is active and valid; (4) to improve the Services or create new service offerings, to customize your experience on any of the Services, or to serve you specific content that is most relevant to you; (5) to contact you with regard to your use of any of the Services and, in our discretion, changes to the any of the Services and/or any of the Services’ policies; (6) for internal business purposes; and (7) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy or for any other legal purpose not inconsistent with this Privacy Policy.

Interest-Based Advertising and Location-Based Services. As permitted by applicable law, including COPPA, we may also use your Personal Information, Demographic Information or Usage Information that we collect about you: (1) to specifically target relevant advertisements or content to you; (2) to understand the usefulness to you of the advertisements or content that have been delivered to you; and (3) when you comment to or add content to the Services. Further, we may use your location information (including proximity to Tracking Technologies existing the physical world that the App interacts with, for example iBeacons in a retail store) to enable or verify certain actions, as permitted by applicable law, including COPPA. For more on advertising, and your choices regarding it, see Section 6 below. However, we will not serve behavioral advertising (ads based on user profiles built by tracking user activities across sites and services) to identified Children on Mixed Use Services, though we may serve other ads as permitted by applicable law. Further information on this is found in Section 8 below.

Contact Us. Please note that information submitted to any of the Services via a “contact us” form or other similar customer inquiry function may not receive a response. We will not use the information provided by you in a customer inquiry communication to contact you for marketing purposes unrelated to your request unless you agree otherwise.

Use of Information for Recruitment Purposes. Where you have provided us with Personal Information or Demographic Information as part of an online application for employment or internship, we may use that information in order to allow us to make an informed decision about whether to proceed with your application. We may, as part of this recruitment process, collect information about your education, employment history and similar matters. Where this Personal Information or Demographic Information is considered to be sensitive, you expressly consent to our processing of this information for recruitment purposes by submitting it to us.

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3. HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?

We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your UIDs with third parties along with data related to you and your activities, subject to the requirements of COPPA and other applicable laws and this Privacy Policy. However, we do not disclose your Personal Information that we have collected directly from you on our Service to third parties (other than our Affiliates) for those third parties’ direct marketing purposes or for other purposes except as set forth in this Section 3 (e.g., as part of the sale of our business) without your consent (and in the case of Personal Information of users that have been identified as Children “verified parental consent as required by COPPA).

If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with others freely. In addition, subject to applicable law (including COPPA where applicable), we may disclose the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. Ludia may disclose your information as follows (subject to applicable COPPA restrictions, more fully explained at Section 8 below):

    (a) When You Request Information From or Provide Information to Third Parties. You may be presented with an option on our Service to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our Service or link to them from our Service. This may include using third-party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third-party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.

    (b) Third Parties Providing Services on Our Behalf. We may use third-party vendors to perform certain services on behalf of us or the Service, such as hosting the Service, designing and/or operating the Service’s features, tracking the Service’s activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including UIDs and Personal Information, to carry out the services they are performing for you or for us. However, for Personal Information of identified Children, if we do, we will require that they restrict its use as required by COPPA (e.g., use for our and their internal operations purposes as permitted by COPPA). Certain service providers may be located outside Canada and your personal information may be transferred to these other jurisdictions and become subject to the laws of such foreign jurisdictions, including those that may grant access to your personal information to the authorities of such foreign jurisdictions.

    Third parties may also collect and use information about you, potentially including Personal Information, on their own behalf and for their own purposes (which may include analytics and tracking activities), including by setting and accessing their own Tracking Technologies on your Device. We are not responsible for those third party technologies or activities arising out of them. However, some provide you with choices regarding their data practices. One way to determine this is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. We are not responsible for the completeness or accuracy of this tool. In addition, we may use Google Analytics for analytics services, and their privacy policy and consumer choice options are available here: www.google.com/intl/en/policies/privacy. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out or other choice options.

    (c) To Protect the Rights of Ludia and Others. To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Ludia or third parties (including through the enforcement of this Policy, our Terms of Service, and other applicable agreements and policies); (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders); or (iii) as otherwise required or permitted by law. To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

    (d) Affiliates and Business Transfer. We may transfer your information, including your UIDs and Personal Information, Demographic Information and Usage Information to our parent, subsidiaries and affiliates (“Affiliates”) provided that for Canadians, this will be limited to Affiliates acting as service providers to us for the purposes of providing you with the Services, subject to applicable law absent your consent. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Service or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change; including, in either case, during the course of any related due diligence process.

    (e) Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Service that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list. Promotions on Mixed Use Services will comply with applicable COPPA requirements.

    (f) Your California Privacy Rights. We do not share personal information as defined by California Civil Code Section 1798.83 collected by us on the Service with third parties for their direct marketing purposes absent your consent.

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4. DO THIRD-PARTY CONTENT, LINKS TO THIRD-PARTY SERVICES, AND/OR THIRD-PARTY APPS APPEAR ON THE SERVICE?

The Service may contain content that is supplied by a third party, and those third parties may collect Usage Information and your UID when such content is served to you. In addition, when you are on the Service you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the Service onto a different site. These third party services may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, serve you their own ads, have practices that differ from ours and may or may not have their own published privacy policies.

Third-party applications may also be available via the Service. The owners of these applications (“Third-Party Owners”) may collect Personal Information and other data from you and may have their own policies and practices differing from ours; however, we restrict access for identified Children on Mixed Use Services. We are not responsible for how Third-Party Owners or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These Third-Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications.

We also encourage you to note when you leave our Service and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

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5. ARE INTEREST-BASED ADS SERVED ON THE SERVICE OR RETARGETED TO YOU LATER?

The Service may use third parties such as network advertisers and ad exchanges to serve you ads, including interest-based ads, on the Service or to serve you ads, including interest-based ads, on third party services after you leave our Service, and we may use third-party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Service and viewing of ads and of our content. “Interest-based ads” are behavioral ads targeted to you based on your activities across third party sites and across time, including retargeting of ads after you have left our Service and are on a third party service. Network advertisers are third parties that display advertisements, which may be based on your visits to the Service and other apps and sites you have visited. Third-party ad serving enables us to target advertisements to you for products and services in which you might be interested. You can avoid receiving ads in connection with our Services by not using the Services and by uninstalling our Apps. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace. In addition, some third parties that serve Interest-based ads via mobile apps may offer your choices regarding such practices and their Tracking Technologies. Some may offer a Device-based opt-out option via a downloadable app available at: http://www.aboutads.info/appchoices. We are not responsible for this app, including without limitation its accuracy or limitations, or any representations made in connection with it.

However, on Mixed Use Services we will either not serve interest-based ads at all, or take measures to restrict them to non-Children, though we may serve other ads as permitted by COPPA (e.g., run of service ads, contextual ads, etc.) or other applicable law. Further information on our policies for Children is found in Section 8 below.

The Service’s third-party ad network and exchange providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies (including Flash cookies), web beacons and other Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a UID. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities. Further information on Third Party Tracking and Do Not Track is found in Section 1(b) above.

Third-party Tracking Technologies are not controlled by us, even if they are associated with our Service or our ads. Statements regarding our practices do not apply to the methods for collecting information used by these third-parties and others or the use of the information that such third parties collect. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing or disclosure practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

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6. HOW DO I CHANGE MY INFORMATION AND COMMUNICATIONS PREFERENCES?

Authorized employees, agents and representatives will have access to your Personal Information we collect, which will be maintained at our offices or on our servers or those of our service providers. We take reasonable steps to protect Personal Information against loss or theft, or unauthorized access, use, modification or disclosure. You are responsible for maintaining the accuracy of the information you submit to us. The Service may allow you to review, correct or update Personal Information you have provided through the Service’s forms or otherwise. To the extent required by applicable law, you may request access to your Personal Information and request updates, corrections and changes to your Personal Information by contacting us here. If you request changes, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records) and in compliance with applicable law.

With respect to our mobile and other applications (i.e., when we are the application publisher), you can prospectively stop all collection of information by the application by uninstalling the application. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the appropriate application or app marketplace. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the Service, information that you remove may persist internally for Ludia’s administrative purposes. You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails; This will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our Service, such as administrative and service announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Ludia, Inc., 410 St-Nicolas Street, Suite 400, Montreal, Quebec H2Y 2P5; By e-mail here.

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7. WHAT ABOUT TRANSFER OF INFORMATION TO THE UNITED STATES AND CANADA?

Our Service is operated in the United States and/or Canada and intended for users located in the United States and Canada. If you are located outside of the United States and Canada, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States and/or Canada. The data protection laws in the United States and Canada may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States and Canada according to laws of the United States and Canada, respectively, in which countries’ data protection laws materially differ. By using the Service or providing us with any information, you consent to the transfer to, and processing, usage, sharing, disclosure and storage of your information, including Personal Information, in the United States and/or Canada as set forth in this Privacy Policy.

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8. WHAT SHOULD PARENTS KNOW ABOUT CHILDREN (CHILDREN’S PRIVACY NOTICE)?

Many of our Services are intended for a general audience and not directed to Children (i.e., under 13 years of age). Other of our Services are what we refer to as Mixed Use Services, and are intended for both Children and older users. We do not intend to collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe we have, please contact us here and we will remove such data to the extent required by COPPA.

For these Mixed Use Services, consistent with COPPA, we screen for user age and provide a version of the Service for those identified as under 13 that does not collect Children’s Personal Information except as permitted by COPPA. Without limitation, we will either not serve Interest-based ads (ads based on user profiles built by tracking user activities across sites and services) on Mixed Use Services, or do so in a manner that limits interest-based ads to users identified as non-Children. If you are a parent or guardian and believe your child under 13 years of age has misidentified his or her age on a Mixed Use Services, or that we have otherwise collected and/or are using Children’s Personal Information in a manner not permitted by COPPA, please contact us here and we will discontinue that account, or convert it to a Children’s version, and remove associated Children’s Personal Information to the extent required by COPPA.

We may also offer subsections of our general audience Services that are identified as for Children (E.g., “KIDS GAMES”), and on such special subsections of our Service we will limit our data collection and use activities to comply with the obligations of COPPA for Child-directed services.

For more information on COPPA, click here [http://www.onguardonline.gov/articles/0031-protecting-your-childs-privac...] or visit www.FTC.gov and look for parental guidance on child online safety and privacy.

Parents may want to consider commercially available parental control protections to limit what minors can access online and/or monitor their minor children’s online activities. Examples include: www.netnanny.com; www.webwatcher.com and www.sentrypc.com. We do not endorse these or other services and are not responsible for them.


9. WHAT ABOUT SECURITY?

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our Service, and provide us with your information, at your own risk.

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10. WHAT ABOUT CHANGES TO THE PRIVACY POLICY?

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected Personal Information, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

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//End Privacy Policy//