Privacy Policy

Last Modified: October 24, 2016

1. SCOPE.

1.1. Privacy Policy. This Privacy Policy (this “Privacy Policy”) applies to information we collect or use on websites, games and mobile applications, including, www.bluebear.ie, products, features, services, or any portion thereof (collectively, the “Service”), owned or controlled by Bluebear Tehcnologies Ltd., trading as Bluebear Technologies, or its affiliated companies (“Bluebear” or “we” or “our” or “us”). Affiliated companies are entities that control, are controlled by or are under common control with us.

1.2. Changes to the Privacy Policy. Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and in our sole discretion. We encourage visitors to frequently check this page for any changes to the Privacy Policy. Your continued use of the Service after any change in this Privacy Policy will constitute your acceptance the changes.

1.3. Terms of Service. This Privacy Policy and the Terms of Service (the “Terms of Service”), which is incorporated herein by reference, are an agreement (collectively, this “Agreement”) between you (“You” or “your” or “you”), a user of the Service, and us. By accessing or using the Service, you acknowledge and agree to this Agreement. If you choose to not agree with this Agreement, you may not use the Service.

1.4. Third Party Links. The Service contains third party links to other websites or services. Please be aware that we are not responsible for the content or privacy practices of such other third party websites or services. We encourage our users to be aware when they leave the Service and to read the privacy statements of any other site that collects personal information.

2. CHILDREN’S PRIVACY. This section explains our information collection, disclosure, and parental consent practices with respect to information provided by children under the age of 13, or the applicable age of consent in your jurisdiction (“child” or “children”).

2.1. COPPA. The Service complies with the Children’s Online Privacy Protection Act (“COPPA”). We don’t knowingly collect personal information from children under the age of 13 in violation of COPPA with the exception of a persistent device identifier for our internal operations, and if in the event that a user identifies himself or herself as a child under the age of 13 through a support request, we will not collect, store or use, and will delete in a secure manner, any personal information of such user. For more information about COPPA and general tips about protecting children’s online privacy, please visit OnGuard Online.

2.2. Information Retention. In any instance that we collect personal information from a child, we will retain that information only so long as reasonably necessary to fulfill the activity request or allow the child to continue to participate in the activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will delete the information as quickly as possible.

2.3. Third Parties and Contextual Advertising. Third Parties may collect a persistent device identifier, such as IP address unique device identifier, advertising identifier (when available on a device) etc. We do not collect and do not allow third parties to collect from children any personal information that may identify an individual (other than the persistent device identifier which is collected for the limited purpose of supporting the internal operations of the games or mobile applications). We do accept advertisements from third party ad networks which may be displayed in the Service. These third party ad networks are selected to preserve compliance with applicable privacy laws, including but not limited to COPPA, in performance of their services and serve only “contextual advertisements”, which are advertisements that are served without connection to any behavioral tracking elements.

3. INFORMATION.

3.1. Information You Provide. We may collect information that identifies you (“Personal Information”) when you use the Service or register for an account. The types of Personal Information that you may choose to provide include:

(a) Information that you provide to us if you register for an account;

(b) Information that you provide to us and/or our third party service providers when you purchase a game, mobile application or in-app purchases, products or services;

(d) Information that you publicly post via links to social media networks, forums, blogs, message boards, chat rooms or similar functionality is public information that we, or others, may share or use in accordance with the law;

(e) Information that you provide to us if you participate in a sweepstakes, contest, rewards program, or other promotion;

(f) Information that you provide if you email, phone, contact or communicate with us or our third party service providers for customer support or other communications.

3.2. Information We Collect. When you download and use our games or mobile applications, we don’t require you to provide any information and we don’t collect any information about you or your device, except we collect:

(a) Traffic and usage information generated from your visit to the Service, including traffic data, pages you visit, browser information, operating system, IP address, cookie information, and the type of device that you use to access the Service;

(b) In connection with your visit or use of the Service, we may automatically collect information about our users, such as the numbers and frequency of users and their characteristics and information about similar groups of users, certain age groups or users that live in a particular geographical area. This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. No street name or city / town name is collected. Aggregate information generally is collected through the use of cookies and beacons;

(d) Whenever you use one of our games or applications on a mobile platform, we may collect data about your interactions with the game or application and with other users via server log files. In addition, we create a unique user ID to track your use of the Service. This unique user ID is stored in connection with your profile information to track the games, applications or services you are using. This information may be associated with your IP address or device ID for the purpose of providing you the Service and improving it.

(e) What other Bluebear apps you have installed on your device.

(f) The language through which the game or mobile application is being operated.

(g) A note on TrueDepth API:

We use TrueDepth API technologies (ARKit, with automatic estimation of the real-world directional lighting environment) to create AR effects within our apps. We do not share information with third parties, do not store or process in any other way the data which we accessed and used via TrueDepth API. For more information about TrueDepth API technologies you may visit https://support.apple.com/en-us/HT208108.

4. TRACKING TECHNOLOGIES. We may use one or more of the following tracking technologies, and similar future tracking technologies, to automatically collect information: cookies, local shared objects, IP address, web beacons, unique telephone numbers, general log information and referral information from third-party services.

4.1. “Cookies” are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in the Service are visited and by how many people. Our cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or your screen name or e-mail address. The ”Help” portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. We recommend that you leave the cookies activated because cookies allow you to use many features of the Service.

4.2. “Web Beacons,” also known as an Internet tags, pixel tags or clear GIFs, link web pages to web servers and their cookies. Web Beacons can be embedded in web pages, videos, or emails, to collect certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the content, the IP address of your computer, and the URL of the web page from which the content was viewed.

4.3. “Local Shared Objects,” sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit.

4.4. In-App Tracking Methods. There are a variety of tracking technologies that may be included in games and mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate user activity to a particular game or mobile application. This information is useful to us for troubleshooting and helps us understand usage trends.

5. HOW WE USE INFORMATION. We may use the information that we collect for any of the following purposes:

5.1. To provide, operate, maintain, improve, and promote the Service;

5.2. To enable you to access and use the Service, including uploading, downloading, collaborating and sharing with other users or third parties;

5.3. To process and complete transactions, and send you related information, including purchase confirmations and invoices;

5.4. To send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;

5.5. To send promotional communications, such as providing you with information about services, features, newsletters, offers, promotions, contests, events and sending updates;

5.6. To monitor and analyze trends, usage, and activities in connection with the Service and for marketing, advertising, administrative, analytical, research, optimization, and other purposes. For example, we may use statistical analyses of usage data in order to measure interest in the various areas of the Service, for development purposes and to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes.

5.7. To investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities;

5.8. To personalize the Service’s content, features or contextual advertisements;

6. SHARING INFORMATION.

6.1. Advertising Partners. Ads appearing on the Service may be delivered to users by advertising partners, who may use tracking technologies. This Privacy Policy covers the use of tracking technologies by the Service and does not cover the use of tracking technologies by any advertisers, each of whom maintain their own privacy policy.

6.2. Service Providers. We engage service providers to perform functions and provide services to us. We may share your private personal information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions. The third party service providers provide certain products or services, such as an analytics service and advertising networks, that are used to monitor to performance of the apps, or monetise them through contextual advertising. You can find a list of these third party service providers below:

· Admob / Google Inc.

· AppsFlyer Ltd.

· Flurry Inc.

· Chartboost

· Adcolony, a division of Jirbo Inc.

· AppLovin Corporation

Any questions about third parties privacy practices should be directed to [email protected]. We will forward your enquiry to the applicable third party and attempt to provide a response within a reasonable timeframe.

6.3. Payment Processors. We share your payment information with payment services providers to:

(a) Process payments;

(b) Prevent, detect and investigate fraud or other prohibited activities;

(d) For other purposes associated with the acceptance of credit or debit cards. We may share your credit or debit card number with payment services providers or card networks to monitor card transactions at participating merchants and track redemption activity for the purposes of providing card-linked services.

6.4. Authorized Personnel. Our employees, agents, consultants, contractors, or other authorized personnel, may have access to user information as necessary in the normal course of our business.

6.5. Business Transfers. In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if the Service or Bluebear, or substantially all of its assets, were acquired, liquidated, or dissolved, user information would be one of the assets that is transferred.

6.8. Government, Law Enforcement or Third Parties. We may disclose any information, including, without limitation, Personal Information that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We also may exchange information, including, without limitation, Personal Information, with other companies and organizations to protect the rights, property, or safety of Bluebear and its affiliates, personnel, users, third parties, or others. We reserve the right to disclose a user’s Personal Information if we believe, in good faith, that the user is in violation of the Terms of Service, even without a subpoena, warrant or other court order.

6.9. Social Media Networks. We may include applications or widgets from social media networks that allow interaction or content sharing by their users. These widgets, such as a Facebook “Share” or “Like” button, are visible to you on the web page you visit. Integration between the Service and social media networks such as Facebook, Twitter and others may allow social media networks in which you participate to collect information about you, even when you do not explicitly activate the network’s application or widget. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal information transmitted to that network.

6.10. Push Notifications. Some of our games and mobile applications may send local notifications to a user’s device; however, local notifications operate differently from “push” notifications. Specifically, local notifications are messages delivered directly through the game or mobile application and do not require collection or use of your personal information (other than the use of device ID, if necessary, solely for the purpose of sending the local notification). Please note that you may opt-out of receiving local notifications by changing your device settings.

7. CHOICE AND OPT-OUT. We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information.

7.1. Choice. In accordance with local law, your controls and choices may include:

(a) You may correct, update and delete your account information, as described below;

(b) You may change your choices for subscriptions and newsletters;

(d) You may choose whether you received targeted advertising from us or our partners.

7.2. Opt-out. We may also use tracking technologies to collect information about your visits over time and across third-party services or other online services. The Network Advertising Initiative (the “NAI”) is a cooperative group of ad serving providers. The NAI has developed a set of privacy principles to which its members adhere. The NAI is committed to providing consumers with clear explanations of Internet advertising practices and how they affect you and the Internet generally. For more information about the NAI, third party ad servers generally and the opt-out options offered through the NAI, visit http://www.networkadvertising.org/index.asp.

7.3. Accessing and Correcting Your Information. If you have an account, you can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account or by emailing us at [email protected]. For other personal information we hold, we will provide you with access for any purpose including requesting that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

8. SECURITY.

8.1. Security Measures. We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.

8.2. No Security Guarantees. Although we take appropriate measures to safeguard against unauthorized disclosures of Information, we cannot assure you that Information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy.

9. CALIFORNIA PRIVACY RIGHTS AND DO NOT TRACK DISCLOSURES. If you are a California resident, you may have certain additional rights.

9.1. Privacy Rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by us to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. To make any such requests, please email us at [email protected] or contact us at the address below.

9.2. Do Not Track Disclosures. California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take action to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

10. USERS FROM OTHER JURISDICTIONS. By using the Service, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and processed on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you do not accept this Privacy Policy, please do not use the Service. The Service is controlled and operated by Bluebear from Ireland. If you are not a resident of Ireland or you are located outside Ireland and choose to use the Service or provide information to us, please note that we will transfer the information, including Personal Information, to Ireland and process it there. Your acceptance of this Privacy Policy, followed by your submission of such information represents your agreement and consent to that transfer. We do not represent or warrant that the Service, or any portion thereof, are appropriate or available for use in any particular jurisdiction. Those who choose to access the Service do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the availability of the Service, in whole or in part, to any person, geographic area or jurisdiction that we choose, at any time and in our sole discretion.

11. CONTACT INFORMATION. If you have any questions, feedback or to report a violation regarding the Privacy Policy, you may email us at [email protected] or contact us by mail addressed to:

Bluebear Tehcnologies Ltd.
74 Fitzwilliam Lane
Dublin 2
Ireland