BEELINE INTERACTIVE, INC.
Last Updated: October 18, 2018
I. INFORMATION WE COLLECT
I. INFORMATION WE COLLECT
We may collect through the Services both personal information that identifies you and can be used to contact you, and non-personal information, which is data in a form that does not allow direct association with you, which may include technical information, including the IP address through which you are accessing the Services and the unique mobile device ID or virtual unique device identifier for any mobile device you may be using.
A. Personal Information
For users in the EEA, the legal basis for collection of this information is to provide you with provision and use of the Services.
Please note that some non-personal information would be considered a part of your personal information if it were combined with other information in a way that enables you to be identified, but the same information is considered non-personal information when taken alone or combined only with other non-personal information.
By providing personal information to us, you represent to us that it is accurate and complete. You agree to update personal information you have previously provided to us to reflect any changes. If we suspect for any reason that your personal information is inaccurate or incomplete, we may terminate your access to the Service.
B. Non-Personal Information
Non-personal information, alone, cannot be used to identify or contact you. Beeline collects non-personal information about your use of Beeline Games and includes aggregated information regarding usage of the Services.
The non-personal information collected may include information related to your mobile device or computer system, including mobile device type, IP address, unique mobile device ID or other device identifiers, Media Access Control (MAC) address, telephone number of mobile device, country of registration. It may also include information concerning your geographic location, browser type, language, Internet Service Provider (ISP), referring and exit pages, time spent, information searched for, time and date stamp, clickstream data, feature usage, game play statistics, scores and achievements, user rankings, time spent playing our games, and other statistics.
Beeline also collects login information, user ID and other information from any SNS that you may use to access the Services, or that you may interact with through the Services, as described in more detail under the subsection below “Interaction with SNS’s”.
II. HOW WE USE YOUR INFORMATION
Generally, we use your information to provide you with an efficient and customized experience. For example, we may use information in the following ways to provide you the Services:
To send “push” notifications to your mobile device regarding Beeline Games that you have been playing (for example, suggesting that you open the Beeline Games to take certain actions);
To provide in-game information regarding player achievements, such as leader boards;
To identify and suggest connections with other Beeline users or users of an SNS that you use in connection with a Beeline Game;
To enable communications between you and other Beeline users or users of an SNS that you use in connection with a Beeline Game;
To allow us to enable you to reset your password if you have forgotten it;
To provide technical support and respond to inquiries from you;
To prevent fraud and potentially illegal activities and enforce our End User License Agreement;
To help us to develop, deliver and improve the Services;
Additionally, in the case of real-money competitions, personal information will be used to verify your identity when you establish a real-money account, make a deposit to your account or initiate a withdrawal from your account, and location information will be used for legal compliance.
For users in the EEA, the legal basis for processing of the above personal information is to provide you with the Services you have requested.
Additionally, we may use your information to promote additional products or services, including:
To inform you about new Beeline products and promote Beeline products;
For market research purposes that support our efforts to deliver a more valuable service to our community of Beeline users;
To deliver and target advertising from third parties;
To gather demographic information about Beeline users in order to more effectively manage the Services and provide targeted advertising; and
To track clicks or other ad fulfillment metrics.
The EEA legal basis for this processing of your personal information is our pursuit of legitimate interests, specifically in this case the legitimate interest to optimize your experience with the Services by avoiding display of recommendations and offers that are irrelevant to you. If you or the relevant Data Controller are located in the EEA, you have the right to object, on grounds relating to your particular situation, at any time to such processing. To exercise this right, you may do so by contacting us as provided in the “Contact” link below or by visiting https://beelinesupport.zendesk.com/hc/en-us/requests/new.
If we send e-mail or SMS messages to you for the purpose of promoting Beeline products or services, or those of a third-party partner, we will generally provide you with choices about receiving further such promotional messages. Preferences for “push” notifications may in most cases be adjusted through Beeline Games or your mobile device.
III. HOW WE COLLECT YOUR INFORMATION AND HOW LONG WE KEEP IT
A. Interaction with SNS’s
By registering with your SNS login information, you allow Beeline to access certain information from your profile for that SNS. The information you allow Beeline to access is affected by the privacy settings you and your friends establish at the SNS. You can control and find out more about these settings directly from the SNS. For example, Beeline may access and store some or all of the following information, as allowed by you, the SNS and your preferences:
· Your first and last name;
· Your SNS ID;
· The URL of your SNS profile;
· Your user ID number, which is linked to publicly available information such as name and profile photo
· The user ID numbers and other public data for your friends;
· The login e-mail you provided to that SNS when you registered; and
· Your gender.
In addition, if you are a member of an SNS, Beeline Games may also enable you to log in through an interface provided by that SNS. Beeline Games may also enable you to access the SNS through the Beeline Games themselves. If you log in to a Beeline Game using an SNS, or access an SNS through a Beeline Game, we may receive the personal and non-personal information that you have provided (or provide in the future) to that SNS.
You may be able to specify what information is provided by the SNS to Beeline using the privacy settings in your SNS profile information.
We may offer you the opportunity to provide us with your e-mail address so that we may register you to receive premium support or provide you with special offers from Beeline or our partner companies.
In certain Beeline Games you may have the option to provide an e-mail address to enable us to contact you with updates about Beeline Games. Your e-mail address may also be used as your user name for certain Beeline Games.
Beeline may provide you the opportunity to participate in include sweepstakes or contests (“Promotions”). If you choose to participate in a Promotion, we may request that you provide us with personal information such as your e-mail address or mailing address.
If you request support relating to a Beeline Game, we may request personal information such as your name and e-mail address and your user name for any SNS’s, if that appears necessary to resolving the problem.
Our Sites may require you to enter a region and language in order to provide relevant information in your language.
We may also request or receive personal information in other interactions you may have with Beeline.
C. Cookies and Other Technologies
A cookie is a small string of text that we, or service providers acting on our behalf, such as Google Analytics, send to your computer’s or mobile device’s browser. Other types of cookies exist, but the cookies in the Services are only used to obtain browser or device-specific information.
Some cookies are necessary to enable a game to function properly and to allow your gameplay experience to continue from one session another, or to prevent you from having to reenter your region and language each time you access our Sites. Other cookies can show, for instance, which parts of Beeline Games are the most popular, how much time users are spending there, and how they are interacting with the content. Cookies may be linked to your Beeline user ID. They do not collect information from your computer or mobile device that is not related to the Service.
You may have the option to disable cookies by changing the options in your browser to stop accepting cookies or to prompt you before accepting a cookie from the pages you visit. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the website of its manufacturer. If you do not accept cookies, however, you may not be able to use all portions of our Services.
We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively “Pixel Tags”) in connection with our Services and to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s device or hard drive. Pixel Tags allow us to count users who have visited certain pages of the Services and to help determine the effectiveness of promotional or advertising campaigns.
D. Retention of Your Information
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or, where applicable law provides for longer storage and retention periods, for the storage and retention period required by law. After that your personal information will be deleted.
IV. HOW WE SHARE YOUR INFORMATION
A. With Third-Party Advertising Entities
We will not share your personal information with third-party advertisers, ad networks and ad platforms ("Advertising Entities") for their direct marketing purposes unless you provide your consent.
We may share certain non-personal information with Advertising Entities to develop and deliver targeted advertising in the Services and on the websites of third parties. We may also allow Advertising Entities to collect non-personal information within the Services which they may share with us, including your device identifier, device type, device brand, device model, OS type/version, network type, device language, device locale, and IP address. Advertising Entities may also collect non-personal information related to the performance of the advertisements, such as how many times an advertisement is shown, how long an advertisement is viewed, and any click-throughs of an advertisement. Advertising Entities may collect this information through the use of tracking technologies like browser cookies and web beacons.
B. With Other Service Providers
To help administer the Services, we may use third-party service providers. In the case of Cash Games, such service providers may include for example companies that monitor for cheating or fraudulent activity. These service providers will have access to your information only to perform the services they have been engaged to perform for us, and they have agreed not to disclose or use it for any other purpose.
C. Under Special Circumstances
We may disclose information about you to law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Beeline or a third party, to protect the safety of any person or to prevent or stop activity we may consider to be illegal or unethical.
If you or the relevant Data Controller is a resident of an EEA country, the legitimate interest in sharing this information is to comply with our legal obligations, and to protect the vital and legitimate interests of third parties, as the circumstances warrant.
In connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy, we may sell, transfer or otherwise share some or all of Beeline assets, including your personal information.
D. Payment Processors
To participate in Beeline’s real-money competitions, you will need to provide your credit card information, including billing address, or PayPal user name and password. Although this information is collected through the Service, it is transmitted directly to third-party payment processors, and Beeline does not review or receive such information. Collection and processing of payment information is subject to the privacy policies and terms of service of these service providers. For more information concerning processing of payment information, please see https://www.vantiv.com/privacy-policy (credit card processing) or https://www.paypal.com/us/webapps/mpp/ua/privacy-full (PayPal).
V. CHILDREN’S PRIVACY
Beeline Games are not intended for children under the age of 13. We do not knowingly collect any personal information from children under the age of 13. Beeline uses an age screen in certain countries in which users are required to enter their’ ages. When a Beeline Game collects age information via an age screen prior to download and users identify themselves as under 13, the Beeline Game will block such users from providing personal information, will disable the collection of personal information from such users until they reach the age of 13, will not send any cookies to such users and will instruct third parties not to send cookies to such users. We will not collect more information from children under the age of 13 than is reasonably necessary to provide our Services. In one or more countries outside the United States, the applicable age is 14 rather than 13.
We encourage you to talk with your children about communicating with strangers and disclosing personal information online.
VI. FRIEND-FINDING FUNCTION
The Services may include a function that may help you to identify friends with whom you may wish to play a Beeline Game. At your option, the function may access your contacts on Game Center, Facebook, Google, Yahoo! or another SNS, or may scan your computer or mobile device. By providing the applicable Beeline Game with permission to access your SNS contacts, you hereby consent to us processing your information for the purposes of utilizing the friend-finding function.
Your use of the friend-finding function in connection with an SNS is subject to your user agreement with the SNS, and any policies of that SNS.
VII. HOW WE PROTECT YOUR INFORMATION
Beeline is committed to protecting the security of your information. We have implemented security measures to protect against identity theft and unauthorized access.
We do not and will not, at any time, request your credit card information, your login information or other identification in a non-secure or unsolicited communication (such as e-mail).
Should any breach of security occur, we will make any legally required disclosure to you by e-mail or posting on the Services as soon as reasonably possible, subject to (i) the requests of law enforcement and (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
VIII. HOW YOU MAY CHANGE, REMOVE, OR EXPORT YOUR INFORMATION
You may email us at email@example.com to request that we delete your personal information from our database. In that case, please place “delete my account” in the subject line and include your first and last name and e-mail address in the body of the message. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for business administrative purposes.
Please note that communications you may send through the Services, as well as any comments you may post, will be stored by Beeline, and may not be subject to modification or deletion.
You may also control the information that Beeline collects through the settings in your browser or mobile device. You may configure your browser to reject cookies from Beeline and may adjust the settings of your mobile device to prevent a Beeline Game or other Service from obtaining location information. However, please note that Beeline Games may rely on cookies and location information to function properly and some services may not be available if you disable cookies.
In the case of real-money competitions, Beeline needs to obtain location information for legal compliance. If you set your browser or mobile device to prevent a Beeline Game from accessing location information, you will not be able to participate in real-money competitions, or deposit or withdraw funds from a Beeline account.
IX. LINKS TO THIRD-PARTY WEBSITES AND SERVICES
XI. NON-US USERS
XII. RIGHTS OF USERS FROM THE EEA
A. Data Controller
B. Rights of EEA Residents
If you are accessing or using the website or mobile app from within the EEA, you may have the following rights under the GDPR (as well as other rights). If you wish to exercise any of these rights, you may do so by contacting us as provided in the “Contact” link below or by visiting https://beelinesupport.zendesk.com/hc/en-us/requests/new, or as provided in the applicable section below.
· Right of Access: You have the right to obtain confirmation from us as to whether or not Beeline processes personal information from you and you also have the right to at any time obtain access to your personal information stored by Beeline.
· Right to Correction of your Personal Information: If we process your personal information, we use reasonable measures to ensure that your personal information is accurate and up-to-date for the purposes for which your personal information was collected. If your personal information is inaccurate or incomplete, you have the right to require us to correct it.
· Right to Deletion of your Personal Information or Right to Restriction of Processing: You may have the right to require us to delete your personal information or to restrict of processing of your personal information.
· Right to Withdraw your Consent: If you have given your consent to the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal.
· Right to Data Portability: You may have the right to receive the personal information concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller.
· Right to Lodge a Complaint with Supervisory Authority: You have the right to lodge a complaint with a data protection supervisory authority located in the European Union. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
XIII. YOUR CALIFORNIA PRIVACY RIGHTS
If you are a resident of California, USA resident and Beeline user, you are entitled to request certain information regarding our disclosure of certain “personal information” (as defined in California Civil Code Section 1798.83) to third parties for their direct marketing purposes. If you are a California resident and have provided Beeline with personal information within the last year, you may make such a request by emailing us at firstname.lastname@example.org and typing the following in the subject line of the e-mail: “California Privacy Rights”.
Within 30 days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for such third parties’ direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. A request may be made no more than once per calendar year and we are not required to respond to requests made by means other than through the e-mail address above.
XIV. CONTACTING BEELINE