(1) Information we receive about end users of third-party mobile applications ("Apps") that use our Software Development Kit ("SDK"), Application Programming Interface ("API"), Demand Side Platform ("DSP") or other technologies (collectively, the "CLEGAMES Services"), users that use CLEGAMES Services (Collectively "User", "you" or "your"), and information we receive about Users while Users interact with platforms, applications, websites or other services provided by CLEGAMES's business partners.
We evaluate this Policy and procedures to implement improvements and refinements from time to time. If we make material changes to this Policy we will notify you by means of a prominent notice on CLEGAMES Site prior to the change becoming effective.
This Policy applies to information collection and use by CLEGAMES while Users: (i) playing the game by the CLEGAMES Services;(ii) interact with the CLEGAMES Services; or (iii) interact with platforms, applications, websites or other services provided by CLEGAMES's business partners.
- Adcolony https://www.adcolony.com/privacy-policy
- Facebook https://www.facebook.com/about/privacy
- Appsflyer https://www.appsflyer.com/kr/product/gdpr#our_commitment_to_you
- Google https://privacy.google.com/intl/ko_ALL/businesses/compliance/#?modal_active=none
Our technology enables our partners to show Users more relevant advertising that is based on Users' interests and behaviors. In order to provide CLEGAMES Services, we may collect and use certain information about User activity and preferences. We understand how important it is to keep such User's personal information confidential and discrete, especially in today's online world. To this end, we have designed this Policy in a format that is easy to navigate and read so that our privacy practices can be clearly understood.
The CLEGAMES Services may link to third party websites, Apps or other third party content. Please note that we cannot control the treatment of a User's information by such third parties, and that the privacy practices of third parties likely differ from those described in this Policy.
2. How We Collect Users' Information
Depending on the nature of a User's interaction with the CLEGAMES Services, or any service provided by CLEGAMES's business partners, we may collect information directly from such User or from our business partners (e.g. mobile application developers, Ad Exchange platforms, and advertisers). For example, when we partner with an Ad Exchange platform and the Ad Exchange platform initiates an ad request to our DSP, it may share User's information with us. Where required, the publisher will obtain User consent for and on our behalf for the processing of User personal information to display advertising on a User's device. A User can withdraw their consent at any time. In addition, we may acquire information from other trusted sources to update or supplement the information that the User voluntarily provides to us or that we collect automatically or collect from our business partners (e.g. mobile application developers, Ad Exchange platforms).
3. Information We May Collect From Users
When you view ads served by CLEGAMES Service or interact with services provided by CLEGAMES's business partners, we and/or our business partners may collect your information including the following:
Device make, device model, operating system (e.g.iOS), device type (e.g. smartphone, tablet, etc.), device properties related to screen size, orientation and battery, carrier, name and properties of mobile application through which a consumer interacts with the CLEGAMES Services or services provided by CLEGAMES's business partners, country, time zone and locale settings (country and preferred language), network connection type, IP address, Internet browser user-agent used to access the Advertising Services, identifier for advertisers (IDFA), network provider, SDK version, timestamp, API key (identifier for application), application version, iOS Identifier for advertising, OS version of device, time zone, network status such as WiFi, the geo-location of your device (using GPS or other geo-location data) and the Identifier for Advertising (IDFA) or the Google Advertising ID (AAID), GAID, etc., international mobile equipment identity (IMEI), Internet (IP) addresses or geo-location data, the content type of the ad (what the ad is about, e.g. games, finance, entertainment, news), the ad type (e.g. whether the ad is a text, image, or video based ad), device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
4. How We Use Users' Personal Information
We use your personal information to display advertising on your device, which may include interest-based advertising customized to individuals' inferred interests, preferences, locations and other features. Where required, the publisher will obtain User consent for and on our behalf for the processing of User personal information to display advertising on a User's device. A User can withdraw their consent at any time.
Where necessary in our legitimate interests we use your personal information: (i) to understand and analyze your usage trends and preferences and improve our CLEGAMES Service; or (ii) for purpose of anti-fraud and traffic quality monitoring in order to perform the contractual obligations to our business partners.
We may also use personal information about Users to comply with applicable laws, regulations or codes of practice, and to protect our legitimate interest and protect the rights or property of us or any other third parties.
5. Disclosure of Users' Personal Information
We may disclose the User's personal information to our business partners, including our advertisers, to report the measurement of Users' interactions with the Apps, and for anti-fraud and traffic quality monitoring in order to perform the contractual obligations to our business partners (e.g. advertisers). These business partners may use the Users' personal information to show Users relevant ads, measure Users' ad/site interaction, identify Users' interest areas, better understand the site and app traffic usage or User behavior in order to improve their services. Our business partners' use of the information that we disclose to them will be governed by their privacy policies.
We may also share aggregate or anonymous information with other third parties in accordance with the terms of this Policy.
We may share Users' personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers, law enforcement agencies, judicial and regulatory authorities. We may also transfer Users' personal information to a third party that acquires all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganisation or otherwise.
6. International Transfers
7. Your Data Rights
If you are in the EEA, you have a right to (subject to a limited number of exceptions): (i) request access to and rectification or erasure of you personal information; (ii) obtain restriction of processing or to object to processing of your personal information; and (iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.
To exercise this right please contact email@example.com
8. Security of Users' Personal Information
The security of User's information is our utmost priority, and we take strict measures in order to protect our data from unauthorized access, use, disclosure or destruction of data. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft; our data is only stored in centers that provide high-level security for User's information. Physical access is strictly controlled both at the perimeter and at building ingress points by our staff utilizing video surveillance and other electronic means.
We also protect User's privacy by seeking to minimize the amount of sensitive data and PRI that we store on our servers in the first place. We also seek appropriate contractual protection from our partners regarding their treatment of user data.
CLEGAMES may retain the information relating to you collected from our business partners as necessary for the provision of the services, internal analytical purposes, or to comply with its legal obligations, resolve disputes and enforce agreements (e.g. settlement). The criteria used to determine the retention periods include: (i) how long the personal data is needed to provide the services and operate the business; (ii) the type of personal data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).
We ensure that we complies with the Children's Online Privacy Protection Act (COPPA), and does not knowingly collect personal information about Users of Apps directed to children under the age of thirteen (13). For more detailed information please visit our COPPA policy.
We may contact you periodically by e-mail to provide information regarding our products, services and content that may be of interest to you. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.
If you decide at any time that you no longer wish to receive such communications from us, you may follow the unsubscribe instructions provided in any of the communications or request to be opted-out of receiving such communications via email to firstname.lastname@example.org.
If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such information is deleted from our files.
If you have any question or comment about this Policy, please contact CLEGAMES's Data Protection Officer at email@example.com
You can also write to Clegames, Inc., at:
06122, 4F, 151 Bongeunsa-ro, Gangnam-gu, Seoul, Republic of Korea
Please be sure to include your personal name (and the full company name, if you are inquiring on behalf of such company), address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.