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Privacy Policy
Contents
This policy describes how Fuller Systems, Inc. (collectively described as "Fuller Systems", "we", "us" or "our") collects, uses, processes and shares information about you.
This Privacy Policy applies to all of our apps, games and websites, whether accessed on a website, on mobile devices, PCs or on other platforms. It also applies to our Advertising activities on all platforms and other services that we may provide to you from time to time. In this Privacy Policy we refer to our apps, games, websites, marketing and advertising activities and other services collectively as "Services".
By downloading, accessing, playing our games, using or interacting with our websites or any other Services, you agree to the use of your information in accordance with this Privacy Policy. If you have any concerns about providing information to us, or it being used as described in this Privacy Policy you should not use our Services. We will only collect such Personal Information that is relevant for the purposes described in this Privacy Policy.
This Privacy Policy was last updated on January 1st, 2020.
We collect information about you when you use our Services. Most of this data comes directly from you, such as device information, country and region, and game play information. We use this data to provide our Services to you, including for the purposes of optimization, preventing fraud, customizing offers and verifying purchases. We may also use it for other purposes as provided in this Privacy Policy, including for Advertising purposes.
Most of the information that we collect about you comes directly from you when you play our games, or interact with our websites, advertising or other Services. In general, the information we collect relates to the type of device you are using, how you play our games and may include information that you submit when creating an account with us or which you allow us to access when you connect to your social network accounts through our Services.
In more detail, depending on which of our Services you interact with we may collect and process the following types of information:
If you choose not to create a user account with us, the information that we collect when you play our games will be anonymous, but we will collect device level identifiers and other information associated with those identifiers including:
When you purchase items via our mobile apps (such as those you can purchase in the Apple App Store or Google Play Store) we do not collect or store any payment information from you.
We may use this information:
We may also share your information with third parties who provide Services to you on our behalf.
We also analyze and use the information that we collect on an anonymized/aggregated basis for product development, to analyze the performance of our Services, to troubleshoot and to improve and optimize the Services to ensure the best experience for our users.
Optimizing our Services
We use your information to enable us to provide our Services to you and to optimize them to make them the best they can be. This includes use and analysis of aggregated data to make sure that our Services work properly on all devices and are as enjoyable as possible.
Chat / Messaging
Some of our Services include chat and/or messaging functionality. Users of our chat service(s) can send messages to other players or publicly. Your messages may be used and stored by us: (a) to convey your messages; and (b) to enable you and your recipients to view your message history. We reserve the right to review the content of your messages, including by using automatic filters, to ensure that you are complying with our terms of service and we also reserve the right to prevent your use of our chat service(s) or to block the sending of any message for any reason. We will not use the content of your chat messages for any other purpose.
Customer Service/Support
We use your information, including data that you provide directly to us in email communications or similar, to provide you with support when you need it. We may also use it to contact you, for example as part of a support request or to send you important updates about our Services. Finally, we will use your data to manage your account and relationship with us and improve your experience when you use our Services.
Research and Analytics
We use analytics tools, which may include third party analytics tools, to collect information about how you use our Services. Those tools may use cookies or other similar tracking technologies. We may use your data to carry out research, surveys or to engage directly with you, for example by sending you communications (including by email), for these purposes. We may also create reports, analysis or similar services for use by us for the purposes of research, product development or business intelligence, for example to track potential problems or trends with our Services, or to test new features.
Social and Community
There are a number of social and community channels which can be used to communicate. If you choose to interact with us through those channels, we will receive your information and use it in connection with those channels, including to engage with you, and we may also republish your posts to those channels where appropriate.
Notifications and Other Messages
We may send you notifications and other messages using the contact information we have for you, like your email address. These notifications are limited to those initiated by a valid User Account action (like a password reset request or registration) or by account activity on one of our Services. If any notification or message is no longer wanted and you are unable to directly unsubscribe inside of that communication, please Contact Us.
Contests and Promotions
From time to time we may run promotions or contests during which we may collect personal information from you, such as your name, address, postal code or other information or content submitted in order for you to claim a prize. Those contests will have their own specific terms and conditions, but we will use personal information that you provide in relation to that competition for the purposes of running the contest. We may also publish the names and entries of promotion or contest entrants. That information may also be combined with your online user account and will be processed, stored and shared in accordance with this Privacy Policy.
When you visit our other websites, such as https://www.cribbagepro.net, or other websites operated by us ("Websites"), we collect information about you, such as details about how you use and interact with such Websites. We may use the information we collect about you for a number of purposes, including for operating and optimizing the Websites, in connection with our Advertising purposes, and for research or analysis.
The information we collect and process about you when you visit our Websites includes:
We, our suppliers and contracted third parties, may use this information:
You can choose to add information to your user account or to connect our Services to your account with a third party network (such as Facebook). If you do this, then your information you choose to share will be visible to other players and we will also use it for the other purposes set out in this Privacy Policy, including for Advertising.
User Account
When you use our games Services on a mobile device, we will give you a randomly generated unique identifier which we will associate with an anonymous account. That account will not be personally identifiable unless you choose to add your personal information to it, such as a username, avatar, email address or other information.
Your online user account and at least some of the information it contains will be visible to other users of our Services (like your username and avatar image). If you choose to add personal information to your account it may be visible to your friends and other players anywhere in the world. You may also choose to disclose data about yourself in the course of contributing user generated content within our Services. Any data that you disclose in any of these forums, blogs, chats or the like will become public information, and there is no expectation of privacy or confidentiality with respect to that data.
Connecting with a Third Party Network
Where we make this available, you can choose to log in to your online account using your account details with a third party network, such as Facebook. Where available, you will be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress), or access other functionality we make available in our games and other Services, such as inviting friends to play.
Information We Receive from Facebook
If you log in to your account using your Facebook account details, we will receive some of your Facebook account information. If you choose to play our games online, your basic Facebook account information will automatically be associated with your account. Exactly what information we receive will depend on your settings in your Facebook account, but typically we will receive your basic public profile information such as your email address and any other public information.
Logging in with Facebook will not allow us to post anything to your page without your permission and we will not receive any information about your Facebook friends who do not play our games.
We recommend that you read Facebook's Privacy Policy (https://www.facebook.com/full_data_use_policy) and review your privacy settings from time to time to make sure that you understand fully how your Facebook data is shared.
You can disable interest-based advertising by Fuller Systems, or any other company, by following the steps provided below under the section: How to adjust your preferences for interest based advertising.
You should note that if you opt out of receiving interest based or targeted advertising, you will still see advertising, but that advertising will not be targeted using your personal information.
Our Services may include advertising for third party products and services. Unless you opt out of interest-based advertising, we and our advertising partners will use information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our Services.
What information is used for advertising?
We use ad identifiers and other information that we collect about you as described in this Privacy Policy to try to make sure you only see ads in our games that might be of interest to you. This includes information such as:
Advertising Partners
When you play our games or use our Services, non-personal identifiers and other information from your device is collected and shared with advertising partners to enable the technical delivery of ads to your device.
Our advertising partners may combine this information with information which they have collected about you when you use their services (or the websites or services of third parties) in order to serve you more relevant ads in our games or to improve the accuracy of their targeting and measurement systems.
This Privacy Policy does not apply to the collection of your information by our advertising partners. We recommend that you review our advertising partners' privacy policies for more information (a full list of our advertising partners and their Privacy Policies can be found here).
Opting-out of Interest-Based Advertising
You can choose to prevent your device's ad identifier being used for interest-based advertising by updating the settings on your device. For more information, see "How to adjust your preferences for interest based advertising" below.
Please note that if you opt out of interest based advertising, you will still see advertising, but those ads will not be targeted using your private information. However, they may still be delivered based on contextual criteria such as the game that ad is to be displayed in, or the region in which your device is located.
To provide our Services and interest-based advertising, we use ad identifiers. This section describes our use of these technologies and how you can manage your preferences.
Ad identifiers and similar technologies are used by us to provide our Services to you and in order to collect data from your device. These technologies allow us and our third party advertising partners to:
How Ad Identifiers Work
Ad identifiers are non-permanent, non-personal identifiers such as Apple's ID for advertising ("IDFA") or the Android advertising ID, which are uniquely associated with your device. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications.
How to Adjust Your Preferences for Interest-Based Advertising
You can choose to prevent your device's ad identifier from being used for interest-based advertising, or you can reset it, through the settings on your device. The process and settings vary between devices, but you will usually find the ad identifier settings under a "privacy" or "ads" section in your device's settings.
If you live in the USA, Europe or Canada, you can opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for European users) or http://youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available).
If you adjust your preferences to prevent these technologies, you may not be able to enjoy all of the features available in our Services.
Please Note: Adjusting your preferences as described in this section does not mean you will no longer receive advertising, it only means the ads you see will be less relevant to you.
You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods in the Contact Us section below.
Those rights include:
There are other ways in which you can control the personal information that we collect about you. For instance, you could disconnect your Facebook or other social network account from our games, or delete our games from your mobile device. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings on your device. Finally, you could limit or prevent the use of cookies in your web browsers. More information on these options is available through your device or web browser manufacturer.
You must be over 13 years of age to play our games and use our Services. We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the age of 13, or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age of 13, please Contact Us uwing the contact details below.
If you believe that we might have any information from or about a child under the relevant age set out above, please Contact Us. In the event that we learn that we have collected personal information from a child under the relevant age set out above, we will delete that information as quickly as possible.
This sections contains further details about:
Security
Fuller Systems takes appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security. However, we cannot guarantee the absolute security of your information online and offline, as the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving. As such you should always take care when sharing your information online.
Sharing
In addition to the other disclosures described in this Privacy Policy, we will also share your information:
Legal Bases
In each case where we process your information, we do so lawfully in accordance with one of the legal basis set out under European data protection law, and/or other jurisdictions where applicable. The legal bases which we rely upon are the following:
In this Privacy Policy we have explained how you can opt out of certain types of processing that we undertake and where any processing is based on your consent, you can withdraw that consent at any time. Nonetheless, if you play our games we will still collect some personal data about you and process it as otherwise described in this Privacy Policy. If you do not wish us to collect any personal data about you at all, you should cease using our Services.
Retention
We will keep your information for as long as your account is active or we consider necessary for the purposes described in our Privacy Policy. We will also retain and use your information for as long as is required in order to comply with our legal obligations.
Location of Storage
We store your information on servers which are based in the USA. We may also use servers and engage providers that are located outside the USA in order to process and store your information and to provide services to us.
Personal data may be disclosed to third parties including third parties located outside the European Union or the European Economic Area in accordance with applicable legislation and this Privacy Policy. Fuller Systems may use third parties to collect and process personal data on our behalf and in according with our instructions. Fuller Systems is not liable for the acts and omissions of these third parties, except as provided by mandatory law.
International Transfer
We may store and/or transfer your personal data to our affiliates or partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy. Please note that these countries may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place to allow the transfer of your information across borders.
Changes to this Privacy Policy
We may update this Privacy Policy from time to time and we will post the updated Privacy Policy on this page. Please come back to this page periodically to make sure you are familiar with the latest version. Any new policy will be effective from the date it is published by us.
Fuller Systems, Inc. offers our customers certain choices about how we use their information. The California Consumer Privacy Act ("CCPA") gives California residents the right to opt-out of the "sale" of their personal information.
Interest-based Advertising Opt-Outs
Certain Fuller Systems, Inc. apps and services may feature interest-based advertising. Advertising, including interested-based advertising, enables these Fuller Systems to provide you certain content for free and offers that are more relevant to you.
The CCPA broadly defines "sale" of personal information in a way that may include allowing third parties to receive certain information to add to a profile about your device, browser, or you. This profile enables interest-based advertising on applicable Fuller Systems, Inc. apps and other online services.
Advertising Opt-Out Tools
The Digital Advertising Alliance ("DAA") provides you with a choice as to whether participating third parties can use your information to provide interest-based advertising. To opt out of sharing your information with such participating third parties for interest-based advertising, please use the following tools:
When enabling advertising opt-out tools please understand the following:
We do not maintain or control these opt-out mechanisms and are not responsible for their operation. Fuller Systems, Inc. may still use your data to deliver contextual advertising, conduct cross-device tracking to serve you first-party ads directly, or for non-interest based advertising purposes, such as attribution and analytics.
If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are a few ways of contacting us:
For information collected under this Privacy Policy, the data controller is Fuller Systems, Inc. Our Data Protection Officer can be contacted here: dataprotectionofficer@fullersystems.com
Parties to a dispute arising out of or related to this Privacy Policy agree that: (i) the Website shall be deemed solely based in California; (ii) the Website shall be deemed a passive website that does not give rise to personal jurisdiction over Fuller Systems, Inc. in jurisdictions other than the State of California; (iii) hereby consent to the personal jurisdiction of the state and federal courts of the State of California; and (iv) agree that resolving all disputes in California is convenient and appropriate, and agree to execute all stipulations reasonably related to submitting to the personal jurisdiction of the State of California and using California as the venue for resolving all disputes. This Privacy Policy shall be governed by the laws of the State of California, without respect to its conflict of laws principles. Any claim or dispute that arises in whole or in part from the Website or this Privacy Policy shall be decided exclusively by a federal or state court located in California.