Altitude Games Privacy and Data Protection Policy

(Updated as at May 30, 2018)

This privacy and data protection policy (“Policy”) governs your use of this website (“Website”) which is owned and operated by Altitude Games Pte Ltd (UEN 201403420K), a company incorporated in the Republic of Singapore (“Altitude Games”, “us” or “we”), and all applications or software that may be made available on this Website (“Applications”).

This Policy does not apply to the practices of persons, organizations or companies (if any) that we do not own or control.  Please check the privacy policies and practices of these other organizations, companies or persons to understand how they treat your personal data.

Lawful Basis for Processing

We only collect and process personal data about you where we have lawful bases to do so.  Lawful bases include consent where you have given consent, contract and legitimate interests.

Where we rely on your consent, you have the right to withdraw your consent at any time, in the manner set out below.

Your use of this Website or your download or use of any Application constitutes your consent for the processing of your personal data for the purposes and in the manner stated in this Policy (including the transfer to and storage of such information in Singapore or any other country to which Altitude Games may store or transfer such information) unless you opt out in the manner provided below.

However, in relation to the purposes set out in paragraphs (a) to (d) under the paragraph entitled, “Do third parties see and/or have access to information obtained by the Application?”, our lawful basis to process your data is our legitimate interests to do so.  Where our lawful basis is our legitimate interests, you have the right to object, in the manner set out below.

Where we use your personal data to fulfil your specific requests, purchase orders and to send you purchase confirmation and other account-related information, our legal basis for processing your data for these aforementioned purposes is to fulfill our contractual obligations to you.

If we plan to use your personal data for a new purpose, we will obtain specific consent from you for that purpose.

“Processing,” includes using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information

 What information does Altitude Games Collect and How Is It Used?

User Provided Information

Altitude Games obtains the information you provide when you download and register any Application or create an account with us, and the information you agree to allow us to collect when you login using your Facebook or other social network account  (“User Provided Information”). Registration with us is optional. However, please keep in mind that you may not be able to use some of the features offered by an Application unless you register with us.

When you register with us and use an Application, you generally provide (a) your name, email address, user name, password and other registration information; (b) transaction-related information, such as when you make purchases, respond to any offers, or download or use applications from us; (c) information you provide us when you contact us for help; (d) credit card information for purchase and use of the Application, and; (e) information you enter into our system when using the Application, such as contact information.

Altitude Games uses User Provided Information to fulfil your specific requests, purchase orders and to send you purchase confirmation and other account-related information.  Our legal basis for processing your data for these aforementioned purposes is to fulfil our contractual obligations to you.

We may also use the information you provided us to contact your from time to time to provide you with important information, required notices and marketing promotions.

Automatically Collected Information

In addition, both this Website and an Application may collect certain information automatically (“Automatically Collected Information”), including, but not limited to, the type of mobile and/or other types of devices you use, your mobile or other devices’ unique ID, the IP address of your computer, mobile or other device, your mobile or computer operating system, the type of Internet browsers you use, and information about the way you use the Internet, this Website or an Application.

We use the Automatically Collected Information to track your in-game behavior.

Does an Application collect precise real time location information of the device?

An Application does not collect precise information about the location of your mobile device.

Do third parties see and/or have access to information obtained by this Website or an Application?

Yes. We will share your information with third parties only in the ways that are described in this Policy.

We may disclose User Provided and Automatically Collected Information:

  • as required by law, such as to comply with a court order, or similar legal process;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this Policy;
  • if Altitude Gamesis involved in a merger, acquisition, or sale of all or a portion of its assets, , we reserve the right to transfer or assign the information we have collected from you as part of such merger, acquisition, sale or change of control, and you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of this information, as well as any choices you may have regarding this information;
  • to advertisers and third party advertising networks and analytics companies as described in the section below.

Automatic Data Collection and Advertising

We may work with third party analytics companies to help us understand how this Website or an Application is being used, such as the frequency and duration of usage.

We work with advertisers and third party advertising networks, who need to know how you interact with advertising provided in an Application which helps us keep the cost of the Application low.

Advertisers and advertising networks use some of the information collected by an Application, including, but not limited to, the unique identification ID of your mobile device and your mobile telephone number. To protect the anonymity of this information, we use an encryption technology to help ensure that these third parties cannot identify you personally.

These third parties may also obtain anonymous information about other applications you’ve downloaded to your mobile device, the mobile websites you visit, your non-precise location information (e.g., your zip code), and other non- precise location information in order to help analyze and serve anonymous targeted advertising on an Application and elsewhere.

We may also share encrypted versions of information you have provided in order to enable our partners to append other available information about you for analysis or advertising related use.

If you’d like to opt-out from third party use of this type of information to help serve targeted advertising, please visit the section entitled “Opt-out” below.

How Else Does Altitude Games Use User Provided and Automatically Collected Information?

Altitude Games uses personal and non-personal information, both individually and combined together, to better enhance your user experience, improve our products and services, understand the behaviour and preferences of our customers, to troubleshoot technical problems, to serve advertising, for authentication purposes, to enforce our Terms of Service, to ensure proper functioning of our products and services as well as to help improve them. In addition, we combine non-personal information with personal information, such as an email address, for purposes including providing improved customer service, administering loyalty programs and tailoring our communications, offerings, web pages or game play experience to you.

What are my opt-out rights?

There are multiple opt-out options for users of this Application:

Opt-out of all information collection by uninstalling the Application: You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Opt-out from the use of information to serve targeted advertising by advertisers and/or third party network advertisers: You may at any time opt-out from further allowing us to have access to your location data by disabling the location tracking feature on your mobile device or tablet.  For more information about the practices of third party ad serving companies that may collect information based on your interaction with ads on this Website, in our mobile products, and other sites or products not owned/managed by Altitude Games, or to “opt out” of targeted advertising delivered by National Advertising Initiative (NAI) member ad networks, you should visit www.networkadvertising.org

Data Retention Policy, Managing Your Information

We will retain User Provided and Automatically Collected Information for as long as you use an Application or after you cease to use this Website.  If you uninstall an Application, we will retain User Provided and Automatically Collected Information for up to 24 months and thereafter may store it in an anonymized form.

Right of Access: If you wish to have access to and obtain a copy of your User Provided and Automatically Collected Information, including the purposes of processing your data and who the data has been disclosed to, please contact us.

Right to Data Portability: You have the right to data portability by receiving a copy of your User Provided and Automatically Collected Information. You can request a copy of such information in a commonly used electronic format so that you may transfer it to another organization.

Right to Rectify or Change Data: If you wish to rectify any inaccurate personal data concerning you, you may be able to correct some data via your account if you have one. Otherwise, please contact us.

Right to Object to, or Restrict or Limit the Use of Data:  You can ask us to stop using some or all of your  User Provided and Automatically Collected Information (e.g. if we have no lawful basis to do so), or to limit our use of it (e.g. if your data is inaccurate) including for the purposes of direct marketing.

Right to Delete: If you’d like us to delete your User Provided Information or Automatically Collected Information, please contact us at [email protected] and we will respond in a reasonable time. Please note that some or all of the User Provided Information  may be required in order for an Application to function properly.

Storage and Transfer of Your Information

We transfer to and store User Provided and Automatically Collected Information in Singapore and may engage the services of third party service providers to do so.

We ensure that third party service providers provide sufficient guarantees that they comply with all applicable law, including the General Data Protection Regulation.

Where relevant, we have determined that your rights under the Personal Data Protection Act 2012 of Singapore will be the same even if such information is transferred to and stored outside of Singapore.

Children

We do not use the Application to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected] We will delete such information from our files within a reasonable time.

Security

We are concerned about safeguarding the confidentiality of your information. We use commercially reasonable physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application.

Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches and Altitude Games cannot ensure or warrant the security of your personal information.

Changes

This Policy may be updated from time to time for any reason.

We will notify you of any changes to our Policy by posting the new Policy on this Website and informing you via email or text message. You are advised to consult a copy of this Policy (which will be made available on the Altitude Games’ website) regularly for any changes, as continued use is deemed approval of all changes.

You agree that your continued use of the Application after we publish or send a notice of our updated Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

Contact Information-Withdrawal of Consent, Access and Correction of Your Personal Data

 Please contact our Data Protection Officer by email at [email protected] if:

  • you have any questions regarding our Policy;
  • you wish to obtain the contact information of the person who is able to answer questions about the collection, use or disclosure of the personal data by Altitude Games;
  • you wish to request for the personal data about you that is in the possession or under the control of Altitude Games and information about the ways in which the personal data may have been used or disclosed during the past year and to correct an error or omission in your personal data (if any);
  • you wish to rectify or change your personal data;
  • you wish to exercise your right to object to, or restrict or limit the use of data:
  • you wish to exercise your right to delete your personal data; or
  • you wish to withdraw your consent to Altitude Games’ use of your personal data.

Do note that Altitude Games cannot assist you in relation to information about you that may be collected by other entities.other entities.