Effective Date: November 20th, 2018

OVERVIEW

Introduction and Overview

If you are using the App and are located in the European Economic Area, different privacy practices apply; please refer to the App’s EU Privacy Notice.

You should read this entire Privacy Policy, but here is a partial list of some of the key topics. Any capitalized terms have the meanings given to them where defined in the Privacy Policy.

  • The App is directed and tailored for users who are aged sixteen (16) and older. When you download, register for, play, or otherwise use the App you represent to us that you are sixteen years old or older. Click here for details.
  • Tracking and Targeting:
    • We ask you for, and use Tracking Technologies (defined below), to detect information; and third parties may also do so in connection with our App. Some of the Tracking Technologies may be Location-identifying Technologies (defined below). Click here for details, and to find out how to opt out of certain collection and/or uses of your personal information, including Tracking Technologies.
    • Third parties, including advertisers and advertising services providers, may collect information about you. They may use Tracking Technologies in connection with our App, which may include the collection of information about your online activities over time and across third-party sites or services where permitted by applicable law. Their privacy policies, not ours, govern their practices.
    • We do not monitor or take any action with respect to so-called Do Not Track signals.
  • We do not disclose your Personal Information to third parties for their direct marketing purposes without giving you the choice to give or withhold consent.
  • You consent to our practices detailed in our Privacy Policy. Each time you use the App, the then effective version of our Privacy Policy as posted on our App will apply to that use, subject to Section 10 , so you should check back each time you return for updates. To prospectively change your consent, terminate your account, stop using the App and uninstall any downloads and apps.

INTRODUCTION

Welcome! If you are using the App and are located in the European Economic Area, different privacy practices apply; please refer to the App’s EU Privacy Notice. You have downloaded, used, are otherwise interacting with our mobile application, Jurassic World Alive, the Jurassic World Alive Forum (https://forum.ludia.com/c/JurassicWorldAlive), and the Jurassic World Alive FAQ (https://ludia.helpshift.com/a/jurassic-world-alive/) (collectively, the “App”), which is owned and operated by Ludia, Inc. and/or our Affiliates (defined below) (collectively “Ludia” or “we”, or “our”, or “us”). This Privacy Policy governs your use of the App, but does not apply to data we receive from third parties, unless we combine such data with Personal Information (defined below) that we have ourselves collected under this Privacy Policy. The App may allow you to go to our other services (e.g. website) or third party services in which case the terms of use and privacy policies of those services, and not of this App, will apply.

The App is directed and tailored for users who are aged sixteen (16) and older. When you download, register for, play, or otherwise use the App you represent to us that you are sixteen years old or older.

This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our App (unless otherwise stated below), and does not govern the data practices of third parties that may interact with our App. Also, it is limited to our practices although our App includes access to third-party content and services we do not control. Consult their privacy policies regarding their practices.

To the extent we provide you notice on our App of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern such data collection and use.

In addition, please review the App’s Terms of Service , which governs your use of the App, and includes among other things limits on our liability and your remedies, mandatory arbitration, and waiver of class actions, some of which may or may not apply to you.

Consent to the collection, use and disclosure of personal information may be given in various ways. Consent can be express or implied (for example, when you provide personal information necessary for a service you have requested or the purpose is obvious). You may be asked to provide your specific consent in some special and specific circumstances where notice has been provided to you about our intentions with respect to your personal information and you have not withdrawn your consent for an identified purpose, such as by using an “opt out” option provided, if any. Unless required by law, we will not use or disclose, for any new purpose, your personal information that has been collected without first identifying the new purpose and obtaining your consent. Consent may be given by your authorized representative (such as a legal guardian or a person having a power of attorney).

By using our App, you agree to our Terms of Service (which grants us rights from you, limits our liability to you and limits your remedies) and consent to our collection, use and sharing or disclosure of your personal information and data, and other activities, for the purposes identified or described in this Privacy Policy or otherwise at the time of collection.

By using the App, you also acknowledge and accept NBCUniversal’s privacy policy and Google’s privacy policy, terms of service, and legal notices. Google’s and NBCUniversal’s content and/or services are integrated in the App and required for important App functionality and your acceptance is therefore necessary to use the App.

LINKABLE TABLE OF CONTENTS

These Terms are posted in interactive format to ease your review, especially using smart phones and other devices with small screens. It is important that you read and understand these entire Terms before using the App. Each section below includes a brief introductory summary and a link to the full explanation. Please note that the complete provisions, and not the headings or summaries shall govern. You can click on the headings and “More” buttons to be taken to the full explanation.

  1. What Information Does the App Collect?
    We collect and receive certain information about you as you interact with our App, explained further in this section. More
    1. Information About You That You Provide to Us
      We may collect certain Personal Information and Demographic Information that you provide to us when you interact with the App. For example, we may collect this information through various forms and in various places on the App, such as when you create a profile in the App. More
    2. Information Collected and Stored As You Access and Use the App
      Certain information may be collected from you automatically when you access and use the App. For example, we and third parties may use Tracking Technologies to collect Usage Information based on your device and/or your account ID for a variety of purposes, including (where permitted) serving you advertising, based on your having visited our App or your activities across time and third party locations. We do not look for or respond to Do Not Track signals, but you may have certain other options regarding tracking and/or targeting. This Section provides details on:
        • Usage Information
        • Tracking Technologies
        • Tracking Technologies Usage
        • Tracking Technologies Choices and Consent
        • Third Party Tracking and Do Not Track

      More

    3. We may obtain information about you from third parties.
      Information Third Parties Provide About You More
    4. Third-Party Content and Services
      If you interact with third-party services, such as using Facebook Connect to log in, those services may send us information about you and you or we may send them information about you. More
    5. Information You Provide About a Third-Party
      You may provide us information about others, such as when you send a friend a message. If so, the information you provide (names, e-mail addresses, etc.) may be used to facilitate the communication, but will not be used for other marketing purposes unless your friend consents. You may be identified to the friend in connection with such a message. More
  2. How Do We Use The Information Collected?
    We use your Personal Information, Demographic Information and Usage Information for a variety of purposes detailed in this section including:
    • General
    • Interest-based Advertising and Location-based Services, where permitted
    • Contact Us
    • User generated content

    More

  3. How and When Do We Disclose Information To Third Parties?
    We may provide your information to third parties under various circumstances detailed in this section. These may include:
    1. NBCUniversal and GoogleNBCUniversal may receive or collect your personal information in connection with the App. Google provides an integrated service and may collect device identifier information and precise location data from you via the App. Both NBCUniveral and Google provide services that are necessary for the App to function. More
    2. When You Request Information From or Provide Information to Third PartiesIf you request information from third parties, request that we send information to third parties or interact with third-party services, content, ads or tools (including Facebook and other third party services) we may disclose your information to such parties and/or they may collect your information directly. More
    3. Third Parties Providing Services on Our BehalfOur vendors may collect your information on our behalf or we may disclose it to them so that they may provide services to us and you. Some may offer you choices regarding the collection and use of your information. More
    4. To Protect the Rights of Ludia and Others There are a variety of administrative and legal reasons for which we may disclose some or all of your information. More
    5. Affiliates and Business Transfer We may transfer your information with our Affiliates or disclose it in the event of a sale, merger or similar transaction. More
    6. Sweepstakes, Contests And PromotionsPromotions entrants may be required to consent to certain information sharing or disclosure. More
    7. Your California Privacy RightsWe do not share personal information as defined by California Civil Code Section 1798.83 collected by us on the App with third parties for their direct marketing purposes absent your consent. More

    More

  4. Do Third-Party Content, Links to Third-Party Services and/or Third-Party Apps Appear on the App?
    We may allow you to access third-party content on the App, or to link to or interact with third-party applications and locations from the App, but we are not responsible for third-party content, apps, and locations. More
  5. Are Ads Served On the App Or Retargeted to You Later?
    We and third parties may send you targeted ads based on your location, information and/or behavior. If you object, do not use our App and/or exercise choices some third parties may offer. More
  6. How Do I Change My Information And Communications Preferences?
    You may change certain account information and communications preferences as fully detailed in this section. More
  7. What About Transfer of Information to the United States and Canada?
    You consent to your data being transferred to the United States and Canada, which have different data protection laws than other countries, and than each other. More
  8. What Should Parents Know About Children? (Children’s Privacy Notice)
    We do not intend to collect personal information as defined by COPPA from Children. If you think we have, let us know. California minors have certain content removal rights. More
  9. What About Security?
    No data security is absolute, but we endeavor to take reasonable steps to secure data appropriately. More
  10. What About Changes to the Privacy Policy?
    We may change this Privacy Policy upon posting of a revised Privacy Policy. However, we will continue to treat your Personal Information under the terms of the privacy policy in effect when it was collected unless you otherwise consent. More

THE FULL DETAILED PRIVACY POLICY

  1. WHAT INFORMATION DOES THE SERVICE COLLECT?
      1. Information About You That You Provide to UsPersonal Information and Demographic Information. On the App, we may ask you to provide us with certain categories of information such as: (1) personally identifiable information, which is information that identifies you personally, such as your name, username, password, and e-mail address (“Personal Information”); and (2) demographic information, such as information about your gender, marital status, education level, occupation, hobbies, interests, zip code, etc., some of which may also be Personal Information (“Demographic Information”). We may collect this information through various forms and in various places on the App, including at registration, when you post on the App, or when you otherwise interact with customer support or with the App. To the extent Demographic Information is also Personal Information, or to the extent we combine Demographic Information with your Personal Information we collect directly from you on the App, we will treat the combined data as Personal Information under this Privacy Policy.
      2. Information Collected and Stored As You Access and Use the AppGenerally. In addition to any Personal Information or other information that you choose to submit to us via our App, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the App (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal tablet, browser, mobile phone or other device (a “Device”) whenever you visit or interact with our App. To the extent we associate Usage Information with your Personal Information we collect directly from you on the App, we will treat such combined data as Personal Information, but we do not otherwise treat it (including UIDs (defined below)) as Personal Information.

        This Usage Information may include:

        • your IP address, UDID, device identifier or other unique identifier (“UID”). A device identifier is a number that is automatically assigned to your Device used to access the App, and our computers identify your Device by its device identifier;
        • your Device functionality (including browser, operating system, hardware, mobile network information);
        • the URL that referred you to our App
        • the areas within our App that you visit and your activities there, including remembering you and your preferences;
        • your Device location;
        • your Device characteristics; and
        • certain other Device data, including the time of day, among other information

        Tracking Technologies. We may use various methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. The App may also receive signals from and otherwise interact with Tracking Technologies that exist in the physical world (e.g., iBeacons, wifi, and Bluetooth Low Energy at retail locations, discussed below). A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

        • Cookies. A cookie is a data file placed on a Device when it is used to visit the App. A Flash cookie (or locally shared object) is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. HTML5 cookies can be programmed through HTML5 local storage. To identify local shared objects on your computer and adjust your settings, please visit: www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html
        • Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our App’s pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the App, to monitor how users navigate the App, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
        • Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the App, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the App, and is deactivated or deleted thereafter.
        • Browser Fingerprinting. Collection and analysis of information from your Device, such as, without limitation, your operating system, plug-ins, system fonts and other data, for purposes of identification.
        • ETag, or Entity Tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of UID. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash, and/or HTML5 cookies.
        • Recognition Technologies. Technologies, including application of statistical probability to data sets, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user).
        • Location-identifying Technologies. Additionally, the App may use GPS (global positioning systems) software and other location-based technologies such as iBeacons to locate you so we may verify your location, deliver you relevant content based on your location, as well as allow you to share your location to other users as part of the services we provide via the App. Upon downloading the App, we provide location-based services to your approximate and/or exact location information. In addition to traditional GPS location-based services, some of the retailers and others we work with may install low power Bluetooth, wifi, radio transmitters, or other devices in physical locations, which emit a signal that the App can detect to pinpoint your location or otherwise interact with the App (“iBeacons”). Because iBeacons are more precise than GPS, we can improve the App such as to send you more specific and relevant messages and offers. In addition, you may be able to send your location information via the App to other App users. You should consider the pros and cons involved in disclosing your location information to us and to other people. Where a user of the App requests that their location information be revealed to other persons, the user will be provided options for managing sharing services, which may be through third party services such as through Facebook. We are not responsible for the acts, omissions or policies of such third parties.
        • There may be other Tracking Technologies now and later devised and used by us in connection with the App.
        • Tracking Technologies Usage. We may use Tracking Technologies for a variety of purposes, including:.
          • Strictly Necessary. We may use Tracking Technologies that we consider are strictly necessary to allow you to use and access our App, including those required to prevent fraudulent activity, improve security or allow you to make use of in-App purchases.
          • Performance Related. We may use Tracking Technologies that are useful in order to assess the performance of the App, including as part of our analytic practices or otherwise to improve the content, products or services offered through the App.
          • Functionality Related. We may use Tracking Technologies that are required to offer you enhanced functionality when accessing the App, including identifying you when you sign in to our App or keeping track of our specified preferences, including in terms of the presentation of content on our App.
          • Targeting Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on our App and third party sites based on how you interact with advertisements or content. This includes using Tracking Technologies to understand the usefulness to you of the advertisements and content delivered to you. Further information on this, and your opt-out choices, is found in Section 6 below.
        • Tracking Technologies Choices and Consent. We are giving you detailed notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.You may disable certain Tracking Technologies via your Device’s settings, via tools available as part of most commercial browsers, or via the App. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to Flash cookies or HTML5 cookies or other Tracking Technologies. For information on disabling Flash cookies go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies some parts of our App may not work and that when you revisit our App your ability to limit Tracking Technologies is subject to your Device settings and limitations. Some Tracking Technologies can only be disabled by uninstalling the App. To uninstall an app, follow the instructions from your operating system or handset manufacturer. For information on third party Tracking Technologies and browser Do Not Track signals, see the next section.
        • Third-Party Tracking and Do Not Track. Third parties may use Tracking Technologies in connection with our App, which may include the collection of information about your online activities over time and across third-party web sites or online services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with use of our App and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. For more information on our vendors, and their Tracking Technologies, click here. For more information on advertising and advertisers, and related Tracking Technologies, click here.Also, various third parties are developing or have developed signals or other mechanisms known as “Do Not Track signals”. There is not yet an industry consensus as to what app operators should do with regard to these signals. Accordingly, we do not monitor or take any action with respect to these signals or other mechanisms, though we may consider doing so if an understandable and practical standard is developed and widely adopted.
      3. Information Third Parties Provide About You We may receive information about you from your friends and others that use the App, such as when they submit content to us or post on the App. Additionally, we may, from time to time, with your consent or as permitted by applicable law, supplement the information we collect directly from you on our App with outside records from third parties for various purposes, including to enhance our ability to serve you, to tailor our content to you and to offer you opportunities that may be of interest to you. To the extent we combine information we receive from those sources with your Personal Information we collect on the App, it will be treated as Personal Information and we will apply this Privacy Policy to such combined information, unless we have disclosed otherwise. In no other circumstances do our statements under this Privacy Policy apply to information we receive about you from third parties (although we take other steps to ensure that we comply with our obligations under applicable law with respect to this information).
      4. Third-Party Content and Services The App may include functionality that allows certain kinds of interactions between the App and a third-party web site, platform, tool, application or other service, and accessing or display of third-party content via the App. The use of this functionality may involve the third-party operator providing certain information, including Personal Information, to us. For example, when you register with the App, you may have an option to use your Facebook or other account provided by a third-party site or application to facilitate the registration and log-in or transaction process on the App, or otherwise link accounts. If we offer and you choose to use this functionality to access or use our App, the third-party service may send Personal Information about you to us. If so, we will then treat it as Personal Information under this Privacy Policy, since we are collecting it as a result of your accessing of and interaction on our App. In addition, we may provide third-party services’ interfaces or links on the App to facilitate you sending a communication from the App. For example, we may use third parties to facilitate emails, tweets, “likes,” content submissions or postings of comments on Facebook or other social media platforms. We may also enable access to or display of third party content via the App, that is actually being served or published by the third party, and such third party may be collecting data from you in connection with that content. These third parties may collect and retain any information used or provided in any such communications or other activities and these third parties’ practices are not subject to our Privacy Policy. Ludia may not control or have access to your communications through these third parties. Further, when you use third-party services, you are using their services and not our services and they, not we, are responsible for their practices. You should review the applicable third-party privacy policies before using such third-party services in connection with our App.
      5. Information You Provide About a Third-PartyYou may send someone else a communication from the App, such as sending an invitation to a friend. If so, the information you provide (names, e-mail addresses, etc.) is used to facilitate the communication and is not used by us for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you use any send-to-a-friend functionality on our App, your contact information, name or user name and message may be included in the communication sent to your addressee(s). If you send a message to a friend, you represent and warrant to us that you have either obtained the express consent of this friend to do so or that you have a family relationship or a personal relationship with this friend. A “family relationship” means that you are related to this individual through a marriage, common-law partnership or a legal parent-child relationship and have had had direct, voluntary, two-way communication with this individual. A “personal relationship” means that you have had direct, voluntary, two-way communications with this individual and it would be reasonable to conclude that you have a personal relationship with this individual, taking into consideration factors such as the sharing of interests, experiences, opinions and information evidenced in the communications, the frequency of communication, the length of time since you communicated or whether you have met in person. Some of these tools may be third-party tools subject to third-party privacy policies as further detailed in Section 1(d) and Section 5.

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  2. HOW DO WE USE THE INFORMATION COLLECTED?Generally. We may use your Personal Information, Demographic Information or Usage Information that we collect about you: (1) to provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties; (2) to enable you to participate in a variety of the App’s features such as online entry sweepstakes, contests or other promotion; (3) to process your registration with the App, including verifying your information is active and valid; (4) to manage your account and/or upload your User Generated Content (“UGC”); (5) to improve the App or create new service offerings, to customize your experience on any of the App, or to serve you specific content that is most relevant to you; (6) to contact you with regard to your use of any of the App and, in our discretion, changes to the any of the App and/or any of the App’ policies; (7) for internal business purposes; and (8) for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy or for any other legal purpose not inconsistent with this Privacy Policy.

    Interest-Based Advertising and Location-Based App. As permitted by applicable law, we may also use your Personal Information, Demographic Information or Usage Information that we collect about you: (1) to specifically target relevant advertisements or content to you; (2) to understand the usefulness to you of the advertisements or content that have been delivered to you; and (3) when you comment on or add content to the App. Further, we may use your location information (including proximity to Tracking Technologies existing in the physical world that the App interacts with, for example iBeacons in a retail store) to enable or verify certain actions, as permitted by applicable law. For more on advertising, and your choices regarding it, see Section 6 below.

    Contact Us. Please note that information submitted to any of the App via an inquiry function may not receive a response. We will not use the information provided by you in a customer inquiry communication to contact you for marketing purposes unrelated to your request unless you agree otherwise.

    User Generated Content. The App may permit you to post or submit UGC including, without limitation, written content, user profiles, pictures, data, or other content, including Personal Information. If you choose to submit UGC to any public area of the App, your UGC will be considered “public” and will be accessible by anyone, including Ludia. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Ludia does not assume any obligation to treat this Personal Information included in UGC in accordance with any usage or sharing limitations or other restrictions and this Personal Information may be used and shared by Ludia and third parties to the fullest extent not prohibited by applicable law. We encourage you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the App’s Terms of Service click here. California minors should see Section 8 regarding potential removal of certain UGC they have posted on the App.

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  3. HOW AND WHEN DO WE DISCLOSE INFORMATION TO THIRD PARTIES?App Use Restrictions. We may share non-Personal Information, such as aggregated user statistics, with third parties. We may share your UIDs with third parties along with data related to you and your activities, subject to the requirements of applicable laws and this Privacy Policy. However, we do not disclose your Personal Information that we have collected directly from you on our App to third parties (other than our Affiliates) for those third parties’ direct marketing purposes or for other purposes except as set forth in this Section 3 (e.g., as part of the sale of our business) without your consent.

    If we de-identify data about you, it is not treated as Personal Information by us, and we may share it with others freely. In addition, subject to applicable law, we may disclose the information we have collected about you, including Personal Information, as disclosed at the time you provide your information and as described below or otherwise in this Privacy Policy. Ludia may disclose your information as follows:

      1. NBCUniversal and GoogleNBCUniversal (which co-produced the App) may receive or themselves collect your Personal Information or user data through your use of the App. Google (which provides location services) provides an integrated service and may collect device identifier and precise location data from you via the App. Such collection by NBCUniversal and Google is necessary for the App, including its content features, to function and is governed by their respective terms and polices. To use the App you are required to accept NBCUniversal’s privacy policy and Google’s privacy policy, terms of service, and legal notices. The App will not function without the services provided by these third parties, therefore your acceptance is required to use the App.
      2. When You Request Information From or Provide Information to Third PartiesYou may be presented with an option on our App to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, your Personal Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our App or link to them from our App. This may include using third-party tools such as logging into the App using Facebook, or other third-party posting or content sharing tools and by so interacting you consent to such third-party practices. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third-party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
      3. Third Parties Providing Services on Our BehalfWe may use third-party vendors to perform certain services on behalf of us or the App, such as hosting the App, designing and/or operating the App’s features, tracking the App’s activities and analytics, and enabling us to send you special offers or perform other administrative services. We may provide these vendors with access to user information, including UIDs and Personal Information, to carry out the services they are performing for you or for us. Certain service providers may be located outside the United States and Canada and your personal information may be transferred to these other jurisdictions and become subject to the laws of such foreign jurisdictions, including those that may grant access to your Personal Information to the authorities of such foreign jurisdictions.
      4. To Protect the Rights of Ludia and OthersTo the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect or defend the rights, safety or property of Ludia or third parties (including through the enforcement of this Policy, our Terms of Service, and other applicable agreements and policies); (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas or court orders); or (iii) as otherwise required or permitted by law. To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.
      5. Affiliates and Business TransferWe may transfer your information, including your UIDs and Personal Information, Demographic Information and Usage Information to our parent, subsidiaries and affiliates (“Affiliates”) provided that for Canadians, this will be limited to Affiliates acting as service providers to us for the purposes of providing you with the App, subject to applicable law absent your consent. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the App or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change; including, in either case, during the course of any related due diligence process.
      6. Sweepstakes, Contests and PromotionsWe may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the App that may require registration. By participating in a Promotion, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
      7. Your California Privacy RightsWe do not share personal information as defined by California Civil Code Section 1798.83 (“Shine The Light law”) with third parties for their direct marketing purposes without your consent, except for Affiliates, and NBCUniversal. NBCUniversal (which co-produced the App) provides necessary App functionality services and, in doing so, may receive or may collect your “personal information” in connection with the App. To this end, you are required to accept NBCUniversal’s privacy policy of which may allow them to use your “personal information” they collect for their own direct marketing purposes.If you are a California resident, you may request further information about our compliance with the Shine the Light law by contacting us at [email protected] or by sending a letter to:

        Ludia Inc.
        Attention: California Privacy Rights Request
        410 St-Nicolas Street,
        Suite 400
        Montreal, QC, H2Y 2P5
        Canada

        Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.

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  4. DO THIRD-PARTY CONTENT, LINKS TO THIRD-PARTY SERVICES, AND/OR THIRD-PARTY APPS APPEAR ON THE SERVICE?The App may contain content that is supplied by a third-party, and those third parties may collect Usage Information and your UID when such content is served to you. In addition, when you are on the App you may be directed to other services that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their services and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. For example, if you “click” on a link, the “click” may take you off the App onto a different site. These third-party services may associate their Tracking Technologies with you, independently collect data about you, including Personal Information, serve you their own ads, have practices that differ from ours and may or may not have their own published privacy policies.

    Third-party applications may also be available via the App. The owners of these applications (“Third-Party Owners”), may collect Personal Information and other data from you and may have their own policies and practices differing from ours. For instance, the App can only function as intended with NBCUniversal in-App content and Google-provided location services. Therefore, you are required to accept NBCUniversal’s privacy policy and Google’s privacy policy, terms of service, and legal notices. We are not responsible for how Third-Party Owners or their applications collect or use your information and they may be tracking you across multiple sites and may be sharing the results of that tracking with us and/or others. These Third-Party Owners may have their own terms of service, privacy policies or other policies and ask you to agree to the same. We are not responsible for these third-party privacy policies or the practices of Third-Party Owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications.

    We also encourage you to note when you leave our App and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.

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  5. ARE INTEREST-BASED ADS SERVED ON THE SERVICE OR RETARGETED TO YOU LATER?The App may use third parties such as network advertisers and ad exchanges to serve you ads, including interest-based ads, on the App or to serve you ads, including interest-based ads, on third-party services after you leave our App, and we may use third-party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the App and viewing of ads and of our content. “Interest-based ads” are behavioral ads targeted to you based on your activities across third-party sites and across time, including retargeting of ads after you have left our App and are on a third-party service. Network advertisers are third parties that display advertisements, which may be based on your visits to the App and other apps and sites you have visited. Third-party ad serving enables us to target advertisements to you for products and services in which you might be interested. You can avoid receiving ads in connection with our App by not using the App and by uninstalling our App. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the App or application marketplace. In addition, some third parties that serve Interest-based ads via mobile apps may offer your choices regarding such practices and their Tracking Technologies. Some may offer a Device-based opt-out option via a downloadable app available at: http://www.aboutads.info/appchoices. We are not responsible for this app, including without limitation its accuracy or limitations, or any representations made in connection with it.

    The App’s third-party ad network and exchange providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own Tracking Technologies on your Device and track certain behavioral Usage Information regarding users of your Device via a UID. These third-party Tracking Technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the usefulness to you of the advertisements that have been delivered to you. You acknowledge and agree that associated technology may access and use your Device and may set or change settings on your Device in connection with the associated operations. Note that any images (or any other parts of content) served by third parties in association with third-party ads or other content may serve as web beacons, which enable third parties to carry out the previously described activities. Further information on third-party tracking and Do Not Track is found in Section 1(b) above.

    Third-party Tracking Technologies are not controlled by us, even if they are associated with our App or our ads. Statements regarding our practices do not apply to the methods for collecting information used by these third parties and others or the use of the information that such third parties collect. The relevant third-party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing or disclosure practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

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  7. HOW DO I CHANGE MY INFORMATION AND COMMUNICATIONS PREFERENCES?Authorized employees, agents and representatives will have access to your Personal Information we collect, which will be maintained at our offices or on our servers or those of our service providers. We take reasonable steps to protect Personal Information against loss or theft, or unauthorized access, use, modification or disclosure. You are responsible for maintaining the accuracy of the information you submit to us. The App may allow you to review, correct or update Personal Information you have provided through the App. To the extent required by applicable law, you may request access to your Personal Information and request updates, corrections and changes to your Personal Information by contacting us here. If you request changes, we will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records) and in compliance with applicable law.

    You can prospectively stop all collection of information by the App by uninstalling the App. You may use the standard uninstall process as may be available as part of your applicable Device or potentially via the App or application marketplace. Please note that it is not always possible to completely remove or delete all of your information from our databases and that residual data may remain on backup media or for other reasons. When you edit your Personal Information or change your preferences on the App, information that you remove may persist internally for Ludia’s administrative purposes. You may cancel or modify our e-mail marketing communications you receive from us by following the instructions contained within our promotional e-mails; this will not affect subsequent subscriptions and if your opt-out is limited to certain types of e-mails the opt-out will be so limited. Please note that we reserve the right to send you certain communications relating to your account or use of our App, such as administrative and App announcements and these transactional account messages may be unaffected if you choose to opt-out from receiving our marketing communications. If you have any questions about the Privacy Policy or practices described in it, you should contact us in the following ways: Postal Mail: Ludia, Inc., 410 St-Nicolas Street, Suite 400, Montreal, Quebec H2Y 2P5; By e-mail here.

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  9. WHAT ABOUT TRANSFER OF INFORMATION TO THE UNITED STATES AND CANADA?Our App is operated in the United States and Canada. If you are located outside of the United States and Canada, please be aware that information we collect, including Personal Information, will be transferred to, and processed, stored and used in the United States or Canada. The data protection laws in the United States and Canada may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States and Canada according to laws of the United States and Canada, respectively, in which countries’ data protection laws materially differ. By using the App or providing us with any information, you consent to the transfer to, and processing, usage, sharing, disclosure and storage of your information, including Personal Information, in the United States or Canada as set forth in this Privacy Policy.

    If you are using the App and are located in the European Economic Area, please refer to the App’s EU Privacy Notice.

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  11. WHAT SHOULD PARENTS KNOW ABOUT CHILDREN (CHILDREN’S PRIVACY NOTICE)?The App is directed and tailored for users who are aged sixteen (16) and older. When you download, register for, play, or otherwise use the App you represent to us that you are sixteen years old or older. We do not intend to collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) from children under the age of thirteen (13) in a manner that is not permitted by COPPA. If you are a parent or guardian and believe we have, please contact us.

    Any California residents under the age of eighteen (18) who have registered to use the App, and who posted content or information on the App, can request removal by contacting Ludia here, detailing where the content or information is posted and attesting that you posted it. Ludia will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that Ludia does not control.

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  12. WHAT ABOUT SECURITY?We endeavor to incorporate commercially reasonable safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our App, and provide us with your information, at your own risk.

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  13. WHAT ABOUT CHANGES TO THE PRIVACY POLICY?We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of our App indicates your consent to the Privacy Policy posted at the time of use. However, we will not use your previously collected Personal Information, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

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