Privacy Policy

1. Introduction Kulea Games creates fun games for everyone. In this document, “Kulea Games” refers to Kulea Games (Inc.) and its Affiliates, which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. We also refer to Kulea Games as “we”, “our” or “us” and we refer to users of our Services as “you” and “your.” We at Kulea Games strongly believe in protecting your privacy. Our Privacy Policy explains how we collect, process, use and protect any personal information belonging to you. This information can be collected when you use our websites, apps or other related services we may offer (collectively referred to as “Services”) in order to improve the user experience. By accessing and/or using our Services you consent to our collection, storage, use and sharing your personal information as set forth in this Privacy Policy. This policy is effective 30 March 2015. We encourage you to periodically check this page to ensure that you are satisfied with any updates. If you have questions regarding this Privacy Policy or our collection and use of information, please contact us as described in the Contact Us section below (Section 12). If you access our games from a third party Social Media Channels ("SMC") or the App Store™, you may be required to also read and accept the SMC Terms of Service and Privacy Policy. If you have any concerns about our collection and use of information consistent with our Privacy Policy, you should not use our Services. 2. What information do we collect? When you use our Services, we may collect, process and store information from you directly. Some of this information may be personally identifiable information. These data include information that you provide us with when you fill in forms when using our Services, or when you create an account with us. It may also include details of your use of our Services, the resources that you access, and your interactions with us on SMCs. In the event that you contact our customer relations or respond to our correspondence with you, we may retain a record of this communication. Specific information that we may collect with your consent or through the use our services includes, but are not limited to some or all the following: - your first and last name; - your gender - your birthday and/or age - user ID numbers and passwords used for our Services; - your e-mail addresses; - your physical location and that of your access devices; - your mobile device ID; - your IP-address; - how and when you play our games or visit our website(s); - what device you use to access our Services; - your profile picture or its URL from a SMC; - the user ID numbers and other public data for your friends on SMC; - the login e-mail you provided to that SMC when you registered. Kulea Games may supplement your data with data received from third parties in connection with demographic, advertisement, market and other analytics surveys or services. 3. How do we collect this information? Likely situations when you make personal data available to Kulea Games include, but are not limited to: - using our mobile apps or visiting our websites (see cookies); - registration for our Services, contests and special events; - accessing our Services using a third party ID, such as SMCs or gaming services; - subscribing to newsletters; - purchasing a product or services through Kulea Games’s online stores or within the our mobile apps (or "in-app purchase"); - using “tell a friend,” "email this page," or other similar features; - requesting technical support; and - otherwise through use of our Services where personal data is required for use and/or participation. We may also obtain personal information through the use of “cookies” and other technologies such as pixel tags, local shared objects, hardware-based device identifiers, Operating System-based identifiers, clear GIFs and web beacons. Kulea Games treats information collected by cookies and similar technologies as non-personal data. These technologies are described in more detail below. A “cookie” is a small file stored by your browser when told to do so by a website. Websites usually place a number of different cookies on an end-user’s machine to enhance and improve the user experience. Some of the cookies are “1st Party,” from the website itself, and others are “3rd party,” belonging to advertising and analytics entities or social networks. Please note that companies delivering advertisements in our games or on our websites may also use cookies or other technologies, and those practices are subject to their own policies. Kulea Games’s cookies do not include personal data and are typically used to quickly identify your device and to “remember” your browser during subsequent visits for purposes of functionality, preferences, and website performance. You can set your web browser to alert you when cookies are being sent to your device, limit the type of cookies you allow, or disable cookies. Disabling cookies may affect your ability to use the Services. Kulea Games may under certain circumstances also use Flash cookies (local shared objects) and HTML5 local storage. Flash cookies are small files similar to browser cookies, but which are not stored in the browser and can also be used to remember your settings, to personalize the look and feel of the Services, or for advertising and analytics. You may prevent Flash cookies from being stored by following the instructions provided by Adobe at http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html. Web Beacons and pixel tags: A “web beacon” or a “pixel tag” is an electronic image (often not visible to the end-user) that allows Kulea Games to count users who have visited certain pages or viewed certain advertisements. Additionally, e-mails and other electronic communications Kulea Games sends to you may contain pixel tags that enable us to track your usage of the communication, including whether the communication was opened and/or what links were followed, if any. Analytics in our mobile game applications can collect information about how users play our apps. Kulea Games may also use third-party analytic companies, such as Flurry or Parse, in order to develop and analyze use of our Services. For more information about Flurry and its services please see http://www.flurry.com/. For more information about Parse and its services please see https://parse.com/https://parse.com/. 4. What happens with the information we gather? As mentioned above, we collect, store and use your information to enhance the experience of our Services for all users. You agree that we (or a supplier or group company acting on our behalf and only under our instructions) may use your Personal Information in any one or more of the following ways for the purposes of: - managing your account and relationship with us and improving your experience when you use our Services; - administering games and improving game play; - identifying and suggesting connections with other Kulea Games users; - enabling user-to-user communications; - preventing cheating, fraud or potentially illegal activities, and enforcing our Terms of Service. We may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention; - notifying you about in-game activity; including comments from friends, notifications about in-game status, and notifications of requests from other users; - providing in-game leader boards and promoting in-game player achievements; - communicating information about our existing Services, including updates to our current games, modifications to our Terms of Use or changes to our policies; - informing you about new products or promotional offers related to our Services, or updating you about our partner nonprofits and their activities. For example, we might send you promotional communication with information about a new game or information about a nonprofit featured in one of our Services. When you receive promotional communication from us you will generally have the opportunity to choose whether or not you want to receive additional massages by following the unsubscribe instructions provided in the promotional communication or by contacting us at info@kuleagames.com; - soliciting input and feedback so as to improve Kulea Games products and services and in order to customize your user experience; - providing technical support and responding to your inquiries; - resolving disputes, collecting fees, and troubleshooting problems; - analyzing trends and user traffic and gathering statistical information for the purposes of research or business intelligence that allows us to track potential problems or trends with our Services, as well as conduct product development, improve products and services, personalize content, provide advertising, and make recommendations; - and as otherwise expressly set out in this Privacy Policy or as required by law. One important use of your information is communication. Some messages, such as invites for friends to join you in a game, may include your name and profile photo. We may also send promotional e-mail messages and promotional SMS messages directly or in partnership with parties other than Kulea Games. With your consent, we may send push notifications to your mobile device to provide game updates and other messages relevant to the game or its focus. You can manage push notifications from the “options” or “settings” page within the relevant game. You may also be able to manage them from your device’s settings page for the relevant game. 5. Sharing of your information We may share the information that we receive from you, including personally identifiable information, with third parties (for example, our nonprofit partners) for marketing, advertising, research or similar purposes as follows: - with your consent (including as set out in our Privacy Policy); - as reasonably necessary in order to provide the Services to you (for example, by providing your Personal Information to suppliers we may use to fulfill the Services or to communicate with you); - where it is necessary to carry out your instructions (for example, to complete an online petition or survey, or to provide an award, gift or prize, we may need to provide your Personal Information to a third party processor); - where your data is on an anonymous and aggregated basis, meaning you could not be personally identified from it. We may share aggregated or de-identified information about users with third parties for marketing, advertising, research or similar purposes. For example, Kulea Games will not share your IP address with third parties without your consent. To the extent Kulea Games makes available location-based data available to third parties in accordance with this Privacy Policy, it will be aggregated to a coarse level and without any personally identifiable information; - when you submit information as part of a competition or otherwise interact with our SMCs (for example, by providing a testimonial about one of our Services) we may publish the information you submitted, alongside your name and home country on our website and social media channels; - In the event that we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the successor company. We will notify you and other users of the business transition prior to transferring your personal information as set forth in section 10 of our Privacy Policy. - in order to comply with any legal obligation (such as in response to a court order or a subpoena), or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of Kulea Games, our users, or others; - as we reasonably believe is permitted by law or regulation. Specific services where information may be shared: - Facebook Friends. Kulea Games may offer you the opportunity to invite your contacts from a SMC (such as your Facebook friends). Such contact information will be used only for the purpose of sending communications to the addressee. Under certain circumstances, your username and profile picture will be visible to all other Kulea Games users, regardless of whether they are your Facebook friends. In addition, when you join a Kulea Games game, if you grant the request to post on your wall under settings, a notification will be visible on your Facebook page telling your friends that you have started using Kulea Games. The Kulea Games Facebook application will also be visible on your Facebook page under “applications.” You or the third party may contact us at info@kuleagames.com to request the removal of this information from our database to the extent Kulea Games stores any of this information. - Kulea Games Users. Your username and any information that you post to Kulea Games, including, without limitation, reviews, comments, scores, participation in the game, and text will be available to, and searchable by, all other Kulea Games users. - Crowdfunding. Sites such as Kickstarter offer independent studios like Kulea Games the freedom to develop the games that people want to play without going through a third-party game publisher. As part of any fundraising campaign, Kulea Games may collect personally identifiable information for those individuals who participate and use it to satisfy our commitments, such as transmitting gifts. Kulea Games will not share this information with any other third parties without a user’s express permission. 6. Our Policies Concerning Children’s Information Kulea Games believes in the need to protect all users’ privacy and recognizes that extra sensitivity for those users who are younger than 13 years old. Kulea Games does not knowingly collect personal information from children under 13 years of age. Most of our Services are oriented to users over the age of 13 in compliance with the U.S. Children’s Online Privacy Protection Act (COPPA). For example, our websites are intended for users over the age of 13. If the user is a child under the age of 13, they are advised to leave it. In the case of our mobile games, the apps will be obtained through the various Third Party app stores. Apple’s iTunes Store, for example, does not allow users who are younger than 13 to create an account. Therefore, even with app-based games that are intended for an audience younger than 13 years old, it is assumed that their legal guardians will download the apps and be familiar with our Privacy Policy and Terms of Use. We recognize that our Services could be appealing to children under 13 years old, which is why we offer simplified versions of our games that have no social media functionality, no advertising, no in-app purchase options and that collect no personalized information. Kulea Games and its partners may still collect non-personally identifiable data from children from these services, including IP-based data to ensure that the product, service or features served comply with applicable laws of that nation. In any case, we do not collect, use or share personally identifiable information about any users younger than 13 years old. Kulea Games also does not allow our third party partners who may engage in behaviorally targeted advertising to intentionally target users under 13 in our standard free games. If Kulea Games learns that personal information has inadvertently been gathered from any child under the age of 13, Kulea Games will take reasonable measures to promptly delete such personal data from Kulea Games’s records. If you have additional questions about Kulea Games’s Privacy Policy as it relates to children under the age of 13, please contact us at info@kuleagames.com. 7. How to Access and Update Your Information Users in certain jurisdictions have a right to access personal information held about themselves. Your right of access can be exercised in accordance with applicable law. Kulea Games does not verify the correctness of personal data. Please submit any requests for access to your personal data in writing to info@kuleagames.com. Using a SMC, such as Facebook, enables certain features of our games. In accepting the integration of any SMC, you accept that Kulea Games has access to certain personal information and changes the way you may interact with other SMC users. SMCs offer direct ways for you to: - control what your friends can share about you when using applications and websites; - block and remove specific applications from accessing your information and contacting you - ignore application invitations from specific friends - control who can see your activity in the "Friends' Recent Activity," "Friends' Applications" and "Friends' Games" sections of the Facebook Applications and Games Dashboards. Once Kulea Games receives your information from a SMC, that information is stored and used by Kulea Games in accordance with this Privacy Policy, and you may access and update that information as described below: - If you no longer want Kulea Games to make active use of your information, you may send an e-mail to info@kuleagames.com. Place "Delete My Account" in the subject line and include your first name, last name, e-mail address and user ID number for the SMC from which you access our games (if applicable) in the body of the e-mail. We will respond to your request within thirty (30) days. Please note that certain records, for example those pertaining to payments or customer service matters, will be retained for legal and accounting purposes. If you have sent or posted content on the Service, we may not be able to delete it; - If you wish to review or change the information Kulea Games has about you, e-mail us at the address provided herein; - You may change your e-mail preferences at any time, by sending us an e-mail. Be sure to reference the e-mail address you would like to have us delete from our records and include the replacement e-mail address; - If you have additional questions about this Privacy Policy, contact us at info@kuleagames.com. 8. Retaining and Safeguarding Your Information The security of your Personal Information is very important to us. We maintain appropriate technical and physical safeguards to protect your Personal Information against accidental or unlawful destruction or loss, alteration, unauthorized disclosure or access, use and all other unlawful forms of processing of the data in our possession. These safeguards follow generally accepted industry standards for protecting your Personal Information. Please be aware that despite our best efforts, no data security measures can guarantee 100% effectiveness. You should take steps to protect against unauthorized access to your password, mobile device, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your password private. Kulea Games is not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. In order to change your Facebook password, you must go to the Facebook site and follow its procedures for changing your password. Kulea Games retains the collected data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. 9. Changes to Our Privacy Policy If we decide to make material changes to our Privacy Policy, we will notify you and other users by placing a notice on Kulea Games.com or by sending you a notice to the e-mail address we have on file for you. We may supplement this process by placing notices in our games and on other Kulea Games websites. You should periodically check www.kuleagames.com and this privacy page for updates. 10. International Users Personal data of users that reside outside of the United States is managed by Kulea Games in the United States. As part of our international operations, Kulea Games may transfer data to our Affiliates from time to time for our legitimate business purposes. For example, Kulea Games provides certain services to its Affiliates (which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership). If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Policy. Kulea Games stores information about site visitors and players on servers located in the United States, and Kulea Games may also store such information on servers and equipment in other countries. Personal data collected within Switzerland and the European Economic Area (“EEA”) may be transferred to, and stored at, a destination outside of Switzerland and the EEA. Data Kulea Games holds may also be processed by employees operating outside of Switzerland and the EEA who work for Us or one of our Affiliates or for one of our vendors. Such staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. By submitting your personal data or playing games released by Kulea Games, you agree to this transfer, storing or processing. 11. Your California Privacy Rights We do not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure by "opting in" to receive information from a third party that is participating in a sweepstakes, online petition or other promotion on one of our sites. Requesting more information from one of our partner organizations means you could receive direct marketing communication from them. If you do ask Kulea Games to share your personal information with a third party for its marketing purposes, your information will only be shared in connection with that specific organization, promotion or action. Kulea Games does not share information with any third party (other than our service providers and nonprofit partners) on a continual basis. To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt in to such use when you provide personal information on one of our sites. 12. Contact us If you have any comments, questions or concerns after reading this Privacy Policy, please send an email to info@kuleagames.com.

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