1. Protecting Your Privacy

Prodigy Design Limited, trading as Sidhe (“Sidhe”) provides interactive software products (“Games”) under its “PikPok” brand name (“PikPok”) using various online services such as Apple iOS App Store, Apple iOS TV App Store, Google Play Store, Amazon App Store, Amazon Underground App Store, Apple Mac App Store, PlayStation Network, Oculus Rift, Samsung App Store, Steam, Windows PC Store, Windows Phone Store, Xbox Live Arcade, Facebook, Bandcamp, and Zazzle.

We own and operate various websites and their subdomains including but not limited to www.sidhe.co.nz and www.pikpok.com (our “Sites”) to provide access to information about Sidhe, PikPok, the Games and products, message boards, head to head match play or provide technical support to PikPok users (collectively, our “Content”).

We are providing this Privacy Policy solely to inform you of our practices and procedures concerning our collection, use and processing of your data, as well as your rights with regard to that data. This Privacy Policy is not a contract, and your acceptance and approval are only required where we request your consent to collect certain types of data. However, you are required to comply at all times with the Terms of Use of our Services (located at: http://www.pikpok.com/terms-of-use), and any violation thereof or abuse of our Services, including violations that may impact your privacy rights or the privacy rights of other users, may lead to the suspension or termination of your access to our Services.

2. What Personal Information Do We Collect?

Our Sites

While you are browsing our Sites, your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language and referring website addresses may be logged automatically. We may use this information to monitor and analyze your use of our Services. In addition, we may ask you to submit and we may process data that is personal to you, including but not limited to your name, profile photo, gender, age or birthday, links to your profiles on social networking websites and other third party sites, usernames and email and postal addresses. We may use this information to create a user profile customized to you. We may use your email address to contact you about your experience with our Sites and to notify you about PikPok news and promotions. Your gender and birthday may be used to analyze user trends and target certain promotions to you. Your postal address may be used if we have merchandise or other physical promotional materials to send to you.

Forums

You may, from time to time, have the ability to post content to a blog, message board, chat room or within our Services or other public forums such as our Facebook page (“Forums”). You should be aware that any visitor to the Forums may read anything you post or any information you voluntarily make available on the Forums. For example, any information that you post to a Forum, including your username or other account profile information, will be publicly displayed to all users and viewers of that Forum. Please be aware that we cannot secure any information or statements you personally make available on our public Forums, and you provide such information at your own risk. We do not author, edit, endorse, or monitor any Forum. However, we can remove information you have posted if you contact us at [email protected]. In the alternative, and if the feature is available on the Forum in question, you may also have the option to delete your posts directly. Although we cannot ensure that historical versions, such as cached versions of your post made available through search engines, will not be shared or stored by third parties, upon your request we will do our best to remove such posts from our own application and pages.

iOS and Android Platforms

When you use any of our Services on a mobile platform, we may collect and record certain information such as your unique device ID (persistent / non-persistent), hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), your device name, your email address (if you have connected to Facebook or you Google Account), and your location (based on your Internet Protocol (“IP”) address). This information is useful to us for troubleshooting and helps us understand usage trends. In addition, we create a unique user ID to track your use of our Services. This unique user ID is stored in connection with your profile information to track the Games you are playing, so that we can always make the Games you play available to you.

Facebook Connect, Game Center and Google+

You may connect your PikPok user account to your accounts on the following social networking services (“SNS”): Facebook, Apple’s Game Center, and your Google Account. We may collect and record information through an SNS in accordance with the policies and terms of that SNS. The information we collect when you connect your PikPok user account to an SNS may include: (1) your name, (2) your SNS user identification number and/or user name, (3) profile picture or its URL, and (4) the SNS user identification numbers for your contacts who are also connected to our Games.

If you want us to delete the data we receive from Facebook, Apple’s Game Center, or your Google Account about you, please contact us at [email protected]

Invite a Friend

PikPok may offer you the opportunity to invite your contacts from an SNS (such as your Facebook friends) so that those contacts can be located in our Games and/or you can invite them to join you in playing our Games. Such contact information will be used only for the purpose of sending communications to the addressee. You or the third party may contact us at [email protected] to request the removal of this information from our database to the extent we store any of this information.

Customer Service

We may collect your name, email addresses, postal addresses, and/or telephone calls with names and numbers to return calls when you contact our customer service group. We use that information to contact you about your experience with our Services and notify you about PikPok news and promotions.

Game Data Collection

Whenever you play our Games, we collect data about your interactions with the Game and with the other users inside the Game via server log files. We use this information to help improve your Game experience and monitor the performance of the Game.

Other Collection

We may also acquire information from you through your access and participation in message boards on the Services, your participation in surveys regarding the Services, or your participation in a sweepstakes or contest through the Services.

Cookies

A cookie is a small text file that we transfer to your computer and/or device, to identify a user’s computer/device and to “remember” things about your visit to our Sites and use of our Services, such as your preferences or a username and password. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of our Services (e.g., improving a user interface or method of input based on how our end users use our Services), tailoring recommendations to your interests (e.g., personalized ads you want to see, personalized interface or Game play), and making the Services easier to use (e.g., including accessibility options or making certain features more prominent). You can disable cookies at any time, although by doing so, you may not be able to access or use all of the features of our Services.

We may feature advertisements served by third parties that deliver cookies to your computer/device so the Content you access and advertisements you see can be tracked. Since the third party advertising companies associate your computer/device with a number, they will be able to recognize your computer/device each time they send you an advertisement. These advertisers may use information about your use of our Services and third party sites and applications in order to measure advertisement performance and to provide advertisements about goods and services of interest to you. This Privacy Policy does not apply to, and we are not responsible for the data collection practices of these third party advertisers, and we encourage you to review their privacy policies (provided below) to learn more about their use of cookies and other technology.

You may click on the following link: http://www.networkadvertising.org (or such other URL as may be specified by us from time to time) for information on how to opt-out of the use of cookies for the delivery of more relevant advertising.

Third Party Services

Our Services may contain third party tracking tools from our service providers, examples of which include tracking tools from Amazon Pinpoint, Google Analytics, Unity Analytics, Appsflyer and AppSumer. Such third parties may use cookies and other software tools in our Services to enable them to collect and analyze user information on our behalf. We use this information to: assist us in providing player feedback to improve player experiences in our Games and apps, manage crash reports and bug reporting, process payments, and prevent, detect, mitigate and prohibit security breaches and/or fraud. These third parties may have access to information such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geolocation information, and IP address.

This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website that is linked to our Sites or Games, you should consult that website’s privacy policy before providing any personal information.

The service providers that PikPok uses can be found here.

Ad and Offer Networks

We may feature advertising and offers within our Services. The advertisers may collect and use information about you, such as your session activity within our Services, advertising identifier, device identifier, MAC address, IMEI, geolocation information, and IP address. They may use this information to provide advertisements of interest to you.

We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third party website that is linked to our Sites or Games, you should consult that website’s privacy policy before providing any personal information.

The advertising partners that PikPok users across its Games can be found here.

In addition, you may see our Games advertised in other services. After clicking on one of these advertisements and installing our Game, you will become a user of our Services. In order to verify the installs, a device identifier may be shared with the advertiser.

Subscribe

We may use the email address you provide to us at www.pikpok.com/subscribe to contact you with newsletters, marketing, or promotional materials. You can easily opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting the Privacy Officer via the information provided in the “Contact Us” section below.

3. How Do We Use Your Information?

We use the personal information we collect from you for a range of different business purposes and according to different legal bases of processing. The following is a summary of how and according to which legal bases we collect and use your personal information.

We use your personal information to fulfill a contract with you and provide you with our Services, to comply with our legal obligations, protect your vital interest, or as may be required for the public good. This includes to:

• Provide and deliver products and services at your request;
• Create game accounts that allow users to play our Games;
• Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• Prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities; and
• Enforce our Terms of Service or other policies, and to comply with this Privacy Policy, our internal data protection processes, and applicable laws.

We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these interests, and we only collect the minimal information necessary to pursue such legitimate interests. This includes to:

• Operate and improve our Games and Sites;
• Understand you and your preferences to enhance your experience and enjoyment using our Games and Sites;
• Communicate with you about promotions, rewards, upcoming events, and other news about products and Services offered by PikPok and our selected partners;
• Identify and suggest connections with other PikPok users;
• Respond to your comments and questions and provide customer service;
• Link or combine it with other information we get from third parties, to help understand your preferences and provide you with better Services;
• Enable third parties to collect device information and personal information solely to deliver contextual or non-personalised advertising; and
• Internally measure our marketing campaign performance.

With your consent, we may use your personal information to:

• Provide personalised or interest-based advertising.

We actively minimize the amount of data we collect about you in connection with our legitimate interests, and only collect the minimal data necessary to provide our Services consistent with our legitimate interests. By way of example, our Games are generally free-to-play and supported substantially through in-game advertisements. We only collect the minimal amount of information about your device as may be necessary to deliver such advertisements, such as your device information, IP address, the country where you are located, and other such information necessary to display non-personalised ads via our third party providers. Where additional information is collected for the purpose of providing personalised ads, we require your consent before we will collect or share that information.

4. Who Do We Share Your Information With?

• We share statistics of each user’s activities and data within reports that are used internally and externally by our publishing and distribution partners to analyze our Games, their features and performance.
• With your consent, for example, when you agree to our sharing your information with third parties and advertising networks for their own marketing purposes subject to their separate privacy policies.
• We may release your information as permitted by law or when we believe that release is appropriate to comply with applicable law; enforce or apply our rights; or protect the rights, property, or safety of use or our uses or others. This includes exchanging information with other companies and organizations for fraud protection.
• We may share your information in connection with any merger, sale of our assets, or financing or acquisition of all or a portion of our business to another company.
• We may share aggregate or anonymous information about you with advertisers, publishers, business partners, sponsors, and other third parties.

5. How Long Do We Keep Your Personal Information?

6. Is My Information Secure?

7. Does My Information Go Across Borders?

8. Is Sensitive Information Collected?

9. Your rights to access, control, and correct your personal information

Accessing and Controlling your Information

If you wish to modify the information you have provided, or obtain a copy of your information, or if you wish to cancel your account or withdraw your consent to some or all of the personal information collected that requires your consent, there are two methods that we provide.

Option 1 (Recommended): In select Games from mid-2018, you can access and control your personal information from the Settings screen of the Game, by tapping support and going to the privacy section.

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. We may not be able to delete certain information you have provided to us directly through our Services or on our Forum, especially information you make publicly available.

Option 2: You may send an email to [email protected]. Place “[Delete/Change/Access/Request a Copy of] My Data” in the subject line (choose the word that best suits your request) and include:

• Your PikPokPlus (User) ID (per Game). You can find this in the settings screen of most of our Games.
• The name of the PikPok Game(s) or Site(s) you are using.
• Your first name, last name, email address which are used for communication purposes and keeping accurate recordings of processing.
• Identify the information you would like to delete, change, or access.
• If you are requesting a copy of your information, the file format you prefer.

Controlling Personalised Ads

You have the right to withdraw consent at any time for ongoing data collection that requires your consent, such as use in personalized ads. To reset or limit any personal data collected for the purposes of serving personalised ads in our Games:

• For iOS devices with IOS14 and above
  • You can enable or disable tracking of personal data globally in Settings->Privacy->Allow Apps to Request to Track
  • You can Opt in to apps allowing them to track on an individual basis if you do not set the global option.
• For iOS device with older versions of iOS
  • You can reset your advertising identifier in Settings->Privacy->Advertising->Reset Advertising Identifier.
  • Or limit ad tracking by enabling the Limit Ad Tracking option.
  • For more information see: https://support.apple.com/en-nz/HT202074.
• For Android devices
  • Open Google Settings on your Android device by tapping on menu and then on Google Settings once all apps are displayed on the screen.
  • Locate and tap on the Ads menu under Services.
  • Tap on “Reset advertising ID” on the new page.

Some ad networks used in our Games and Sites request your consent before collecting any personal data for the purposes of serving personalised ads. These typically include in-ad controls to allow you to adjust your privacy settings.

For Facebook ads, you can control your personalised ad settings in the privacy settings here.

Information We Receive From a Social Networking Service (SNS) Where You Play Our Games

To manage the information we receive about you from an SNS where you play our Games, you will need to follow the instructions at that particular SNS for updating your information and changing your privacy settings. The privacy management tools for applications on Facebook can be found here. The privacy management tools for you Google Account can be found here. You can also manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions for each application.

Once we receive your information from an SNS, that information is stored and used by us in accordance with this Privacy Policy, and you may access and update that information as described below. Game or other accounts created with us are considered active until we receive a user request to delete or deactivate them.

Additional Rights

In addition to the rights described above, you also have the right to object to any collection practice where we have relied on a legitimate interest as described in detail herein. You may submit any such objection to [email protected]. We will do our best to respond and take measures to mediate any such objection within thirty (30) days.

If you are dissatisfied in any way with our collection of your data, or if you have questions concerning this Privacy Policy, please contact us via the information provided in the “Contact Us” section below.

Individuals Located in the EU: If we are unable to resolve any dispute with you, and you reside in an EU Member State, you may contact the regulatory authority in your Member State responsible for administering rights with regard to GDPR. You may also contact the reporting authority in the United Kingdom, the Information Commissioner’s Office, by following this link: https://ico.org.uk/.

Individuals Located in Brazil: The LGPD grants you certain rights about the processing of your personal information. In addition to any applicable rights mentioned above, eligible residents of Brazil also have the right: (i) to the anonymization, blocking, or elimination of your personal information, if you believe we are processing your personal information in an unnecessary, exceeding or non-compliant manner with the LGPD; (ii) to request the portability of your personal information; (iii) to request information about the entities with which we have shared your personal information; and (iv) to request information about the possibility and consequences of denying consent. While our processing of personal information generally does not include automated decision-making, you are also entitled to a review of our decisions that are made solely based on automated processing of personal information that affect your interests. Notwithstanding any other references to the contrary within this Privacy Policy, in accordance with the LGPD, we will respond to your request within fifteen (15) days after receipt and we will provide any requested information free of charge to you. You may also file a complaint with the National Data Protection Authority in Brazil, the Autoridade Nacional de Proteção de Dados (“ANPD”) for alleged violations of the LGPD, in addition to or alternatively to seeking judicial redress.

10. What Happens When I Remove A Game or Unsubscribe From A Newsletter?

11. Children’s Privacy

12. California Residents: Your California Privacy Rights

13. Changes to the Policy

14. Contacting Us