Privacy Policy

The Terms of Service (EULA) can be found at https://cribbagepro.net/eula.html

Privacy Policy

Introduction

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.


Our Services

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:

  • details about how you use and interact with our games, advertising and other Services (for example, information about how and when you play our games or visit our website(s), and what device you use to access our Services;
  • information that you provide us with when you fill in forms when using any of our Services, when you create an account with us or if you invite your friends to use our Services;
  • the content of messages sent using our chat and messaging systems;
  • if you contact us, for instance for customer service or support, or respond to messages and communications that we send to you, we may keep a record of that correspondence;
  • information we collect via cookies and other similar technologies, as explained further below;
  • information as further set out in this Privacy Policy, including Advertising;

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:

  • the type of device(s) you are using to access our Services, identifiers such as IP address, device identifiers, ad identifiers, a unique player ID we create for you, and the country or region that you are playing in; and
  • how you interact with our Services (your progress/score through a game, session time and duration, number of games played and purchases made).

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:

  • to enable us to provide our Services to you, to ensure that any purchases you make are verified, and to provide you with player support if you need it;
  • to enable us to optimize our Services for you and for the device that you are using, as well as to deliver customized events, offers and promotions;
  • For the other purposes as set out in this Privacy Policy, including for Advertising purposes; and
  • to enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our terms of service or where necessary to defend, exercise or establish our legal rights including our rights under our Terms of Service (https://www.cribbagepro.net/eula.html).

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.

Our Websites

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:

  • information that you provide us with when you fill in forms or create posts on our Websites, or when you create an account with us;
  • details of your use of the Websites and the resources that you access (for example, information about how and when you use the Websites, or what device you use to access the Websites);
  • if you contact us or respond to messages and communications that we or other users of the Websites send to you, we may keep a record of that correspondence;
  • your interactions with us on our social media channels; and
  • information we collect via cookies (which are small text files placed on your device). Cookies allow us to collect data, such as your device's model, operating system and screen size and other information about how you use our Services.

We, our suppliers and contracted third parties, may use this information:

  • as necessary in order to provide the Websites and related services to you;
  • for the purposes of contacting you, for example as part of customer support or to send you updates about the Websites;
  • for the purposes of managing your account and relationship with us and improving your experience when you use the Websites;
  • for the purposes of research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes;
  • to 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 the Websites;
  • for the purposes of preventing cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention; or
  • as otherwise expressly set out in this Privacy Policy or as required by law.

Your User Account and Social Networks

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.


Advertising

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:

  • ad identifiers and other information collected from your device;
  • information you provide us that may include your age, country and region, and gender.

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.

Ad Identifiers

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:

  • recognize you and your device;
  • provide interest-based advertising to you;
  • allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction); and
  • enable us and third parties to provide you with more customized services, for example to provide our Services in the correct language.

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.

Your Rights

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:

  • Right of access. You have a right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what specific information you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before providing you with any information. We may not be able to provide all the information you ask for, for legal reasons such as instances where the information may include personal information about another person. Where we are not able to provide you with information that you have asked for, we will tell you why. We try to respond to requests as soon as possible, but we will always do so within 30 days of receipt of your request and following any verification of your identity.
  • Right to correct personal information. We do not verify the correctness of personal data. Should you realize that any of the information that we hold about you is incorrect, please let us know at support@FullerSystems.com and we will try to correct it as soon as we can.
  • Data deletion. In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please Contact Us using the information below. In order to process your request you must delete our games/Services and clear any cookies from any device where you have accessed our Services in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as protecting or enforcing legal rights, maintaining financial records or for technical reasons such as maintaining technical security or database integrity. We may also retain some information in an anonymized form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any messages that may be cached on other devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to the internet.
  • Account deactivation. If you have created an account with us, you can ask us to deactivate that account by contacting us using the information below or by making the request directly in the game/Service where available. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our Services and deleting our apps/games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any virtual items will be lost and we may not be able to be restored.
  • Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
  • Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
  • Right to object. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests (see "Legal Bases" below).

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.

Children

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.

General

This sections contains further details about:

  • what we do to keep your information secure;
  • who we share your information with and why;
  • the legal bases under which we process your data;
  • how long we retain your information and where we store it;
  • when/why we share your information with third parties, including transfers outside of the country or region where you may reside; and
  • changes and updates to our Privacy Policy.

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:

  • where we have your consent to do so (including as set out in this Privacy Policy);
  • as reasonably necessary in order to provide the Services to you (for example, by providing your personal information to suppliers we may use to fulfil the Services or to communicate with you);
  • where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your personal information to a payment processors);
  • where your data is in an anonymous and aggregated format, meaning you could not be personally identified from it;
  • as we reasonably believe is permitted by law or regulation or as necessary to comply with any legal obligation, or in order to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of Fuller Systems, our users, or others; and
  • if there is a sale of the assets of Fuller Systems, or as a result of a change of control of Fuller Systems, or in preparation of any of these events. Any third party to which Fuller Systems transfers or sells assets will have the right to continue to use the information that you provide to us in the manner set out in this Privacy Policy.

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:

  • Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested - and that we have agreed - to provide to you, such as our games, customer support, chat and messaging functionality and third party social network connectivity;
  • Legal Obligation. This covers data used by us to comply with a legal obligation, such as the prevention of crime or fraud or to maintain records relating to tax;
  • Legitimate Interests. This covers data used by us for purposes that are not harmful to your privacy and can be reasonably expected within the context of your use of our Services, such as Advertising, analytics and research and optimization of our Services; and
  • Consent. Where we ask for your consent to use your data for a particular purpose. We will make this clear at the point of collection and we will also make clear how you can withdraw your consent at any time.

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.

Notice of the Right to Opt-out of the Sale of Personal Information

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:

  • For websites: the DAA WebChoices Tool, available at http://optout.aboutads.info/?c=2&lang=EN.
  • For mobile applications and connected devices, such as smart TVs or streaming devices, you should review the device's settings and select the option that allows you to disable automatic content recognition or ad tracking. Typically, to opt out, such devices require you to select options like "limit ad tracking" or to disable options such as "interest-based advertising," "interactive TV," or "smart interactivity". These settings vary by device type.

When enabling advertising opt-out tools please understand the following:

  • Opting out of interest based advertising does not in any way reduce the number of ads you will see. It will only impact how relevant the ads you do see will be to you.
  • The opt-outs described above are device and browser based. Because the information being shared relates to your device ID and/or browser ID, you will need to opt out on each device and each browser.
  • Opt-outs may be stored via cookies. If you clear cookies or if you browser blocks cookies, your opt-out cookie may no longer be available. In this case your opt-out choices can not to be honored.

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.

Contact Us

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:

  1. in an email to support@fullersystems.com; or
  2. in writing to Fuller Systems, Inc. 11230 Gold Express Drive #310-119 Gold River, CA 95670

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.



© 2020 Fuller Systems, Inc. All Rights Reserved.
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