(Last Updated: February 2019 with effective date 27 February 2019)
The data controller is Ames, LLC, with a registered address at Ames, LLC / P.O. Box 120760 / Boston, MA 02112 / United States.
INFORMATION WE MAY COLLECT AND HOW
We use analytical information for supporting business analysis and operations, business intelligence, product development, improving our Services, and personalizing content. While using our Services, we may ask you to provide us with certain personally identifiable information (“Personal Data”). Our Services are designed to avoid collecting information such as your real name, address, email address or other similar contact data unless you provide such data to us. The information we collect include:
- Device Information – When you download and use our Services, we automatically collect information on the type of device you use, operating system, resolution, application version, and the mobile device identifiers (such as your device ID), language and time zone and IP address.
- Usage Information – We collect information automatically about your activity through our Services, for example date and time you used a service, features you have used, in-app purchases history, and data generated when you use our Services, for example your game progress which may be stored with your Apple ID on iCloud for iOS Devices. Our Services may also contain tools from third party service providers that help us troubleshoot crashes and maintain a quality product for our target market.
- Other information – We may collect geolocation information upon your permission to customize your game experience. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, we may ask for access to your camera in case you want to use certain features of our Services.
- Information from third parties – We may receive information from our analytic service providers with data they collect through our Services in accordance with their own privacy policies. A list of the third parties that operate in our Services can be found in the APPENDIX A.
- Customer enquiries – We collect some information from you when you provide it to us directly, such as via the suggestion portal in the application or when you contact us for support or email us directly.
PURPOSES FOR WHICH WE WILL USE YOUR INFORMATION
We have set out below a description of the ways in which we use your information, the legal bases we rely upon to do so and provide opt-out, where applicable:
- To provide and maintain our Services, recognize you when you return to our apps, and to perform essential business operation, our legal basis for processing is performance of a contract with you, which you entered into with us when you use our Services.
- To administer and protect our Services (including troubleshooting, data analysis, testing, support, fraud, reporting and hosting of data), our legal basis for processing is legitimate interests for running our business, provision of administration and services.
- To communicate with you about any contact forms, help desk support and to understand how you use our Services so that we can continuously improve our offerings, our legal basis is performance of a contract, legitimate interests or consent depending on the particular case to keep our users updated about our Services and our new features in accordance with your preference, and to continue to improve the Services we offer.
- To send push notifications for changes to our Services, to allow you to participate in new features of our Services when you choose to do so, our legal basis is legitimate interests to be able to communicate our Services to our users and keep our users updated about our Services and our new features in accordance with your preference.
To opt-out of communication with us for our Services, unsubscribe from our mailing list following instructions in the email. If you opt out, we may still send you transactional or relationship messages, such as those about your account or our ongoing business relations. You can opt-out of from receiving push notifications by turning them off at the device level through the settings of the device.
SECURITY AND RETENTION OF DATA
Ames, LLC takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
YOUR RIGHTS AND OPTIONS
- Access personal data we hold about you – You have the right to request access to your Personal Data collected through our Services. Following your request, we will provide you a copy of your Personal Data in an electronic format.
- Other rights – You also have other rights such as to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You also have the right to withdraw consent where you have previously given your consent to the processing of your personal data, for example by turning off camera access in your mobile device settings. This will not affect any data processed before such a withdrawal.
- Exercise these rights – Any requests to exercise your rights should be made through our support feature located in our apps (by going to the in-app suggestion portal accessible via the profile section). You can also send us an email at email@example.com however we may still redirect you to make the same request through the in-app support feature or we may request additional information in order to accommodate your request. These requests can be exercised free of charge and will be addressed by us as early as possible. You may also contact your local data protection authority for unresolved complaints.
STORAGE, DISCLOSURE, TRANSFER AND SHARING OF YOUR INFORMATION
- Storage – User information is stored by AWS in the United States.
- Share with our service providers and partners – We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including hosting and maintenance, ongoing development, analytics, customer care, and marketing. For further information on analytics service provides go to ‘APPENDIX A – Analytics and other service providers’ below.
- For corporate transactions – We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
- When required by law – We may also share information if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers or others.
- To enforce legal rights – We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
- With your consent or at your request – We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
- Cross-border data transfers – Sharing of information sometimes involves cross-border data transfers, including transfers outside of your home country in accordance with the law. The information we collect about you may be transferred to, and accessed from within, the United States, which may not offer the same level of data protection as your home jurisdiction. We will take steps to maintain an adequate level of protection for this information in the jurisdictions in which we process it.
We appreciate the need to provide extra privacy protections to users who are children. Our Services are intended for general audiences over the age of 16 years. We do not knowingly collect personal information from children under 16 years of age. In order to request the deletion of personal data, for any reason, please use the in-app support feature in our Services or contact us at the address provided below and we will take reasonable measures to promptly delete such personal data from our records.
P.O. Box 120760
Boston, MA 02112
APPENDIX A – Analytics and other service providers