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AirFace Privacy Policy

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  1. AirFace Privacy Policy
  2. Last updated: November 1, 2017
  3. * About this Privacy Policy
  4. * EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks
  5. * Information We May Collect
  6. * How We May Use Your Information
  7. * How We May Share and Transfer Your Information
  8. * Communication Preferences
  9. * Interest Based Advertising
  10. * Your Interactions With Third Parties Independent Of Our Services
  11. * Data Accuracy, Access, and Deletion
  12. * Security Safeguards
  13. * Data Retention
  14. * Use By Minors
  15. * Privacy Questions and Complaints
  16. About this Privacy Policy
  17. AirFace develops and publishes interactive games for use on web and mobile devices. “AirFace” (or “we” or “us”) refers to AirFace, Inc. and its affiliates, subsidiaries, parent companies, joint ventures, and other corporate entities under common ownership and/or any of their agents, consultants, employees, officers, and directors.
  18. This Privacy Policy (“Privacy Policy”) explains how we collect, store, use, and share information collected in connection with the use of our website, as well as our related products, services, forums, and sites, including but not limited to AirFace’s games (together, our “Services”), as well as your choices regarding such information.
  19. BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING OUR SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS OUR SERVICES.
  20. AirFace reserves the right to modify this Privacy Policy at reasonable times. We encourage you to periodically review this page for the latest information on our privacy practices. Any changes will be posted on this page with an updated revision date. If we make material or significant changes to this Privacy Policy, we will notify you by email (sent to the email address specified in an account you have registered with us) or by means of a notice within AirFace’s Services prior to the change becoming effective. Please note that your continued use of our Services will signify your acceptance of the changes to this Privacy Policy.
  21. EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks
  22. AirFace participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. AirFace is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Frameworks’ applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
  23. AirFace is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. AirFace complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
  24. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, AirFace is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, AirFace may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  25. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge).
  26. Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
  27. Information We May Collect
  28. For purposes of this Privacy Policy, “personal information” means personally identifiable information that specifically identifies you as an individual. We do not consider personal information to include information that has been de-identified, aggregated, or otherwise made anonymous so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
  29. AirFace collects, processes and retains information about you from four (4) sources: (i) you (i.e., whenever you make personal information available to us); (ii) your devices (including web, mobile and wearable devices); (iii) cookies, web beacons, and other similar technologies; and (iv) social networking sites and gaming partners. The types of information collected may vary depending on the type of activity you are engaged in and the information source.
  30. Personal Information you may voluntarily provide AirFace when you use our Services or register an account with us:
  31. (i) your first and last name, (ii) screen/nick name, (iii) AirFace Services ID or third party service ID, (iv) email address, (v) phone number, (vi) photo or other image, (vii) DOB (month/year), (viii) sex, (ix) address, (x) friend connections, (xi) avatar image, (xii) credit card information, (xiii) shipping information; (xiv) friend’s name and contact information; and (xv) precise geo-location information.
  32. Here are some likely situations when you may make personal information available to AirFace:
  33. (i) registering for our Services and any related contests and special events; (ii) accessing our Services using a third party ID, such as social networking sites or gaming services; (iii) subscribing to newsletters; (iv) purchasing a product or services through AirFace’s online stores; (v) using “tell a friend,” “email this page,” or other similar features; (vi) requesting customer or technical support; (vii) using our Services where personal information is otherwise required for use and/or participation, and (viii) when you provide us with your personal information when applying for a job at AirFace.
  34. Information we collect automatically from your devices (including web, mobile, and wearable devices) when you use our Services may include:
  35. AirFace may use analytical software tools to automatically collect and use data that does not directly enable AirFace to identify you. There are two categories of data automatically collected by AirFace: “Website Use Information” and “Device Use Information.”
  36. Website Use Information may include:
  37. (i) IP addresses, (ii) browser type, (iii) Internet service provider (ISP), (iv) referring/exit pages and URLs, (v) operating system version, (vi) date/time stamp, and/or (vii) clickstream data.
  38. Device Use Information may include:
  39. (i) device properties, such as unique device identifier or other device identifier (“UDID”); (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) data about usage of our Services while connected to devices that you authorize us to integrate; (v) geographical data such as zip code, area code and non-precise geolocation; (vi) game score and achievements; (vii) other anonymous or aggregated data as reasonably required by AirFace to enhance our Services and other AirFace related products.
  40. Please note that if you choose to disconnect a device or any AirFace game, we will no longer collect data from that device or game.
  41. We may on occasion match or combine the information automatically collected from your devices with personal information we obtain from you or other sources, including publicly available databases or third parties from whom we have purchased data, or that is already in our records. This sort of combined information may be used in the ways described in this Privacy Policy. This helps us to update, expand and analyze our records, identify new customers, and provide tailored products and advertising that may be of interest to you.
  42. Information that may be automatically collected using cookies, web beacons, and similar technology:
  43. We, and our partners acting on our behalf, use cookies, web beacons, and similar technologies such as JavaScript and e-tags to collect information about the pages you view, your movements around our websites, the links you click, and other actions you take on our Services. We also use this technology to gather demographic information about our user base as a whole. We may receive reports from our partners (e.g., Google Analytics) providing us with this collected information on an individual and aggregated basis based upon your use of our Services.
  44. You can control the use of certain cookies at the individual browser level. For more information on how you can block, delete, or disable similar technology, please review your browser or device settings. If you reject cookies, you may still use our website and our Services, but your ability to use some features or areas of our website and Services may be limited.
  45. We also use mobile analytics software to allow us to better understand the functionality of our mobile software on your devices. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.
  46. Personal information we may collect from social networking sites and gaming partners:
  47. Some of our Services may offer certain features and functions offered by social networking sites, such as Facebook, Twitter or LinkedIn. These features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the feature to function properly. Please note that these features are subject to the privacy policy associated with the third parties providing them.
  48. When you register to join or use our Services from a third party social networking site or gaming partner, certain personal user and/or membership information may be transferred automatically to AirFace. We may process, use, combine, disclose and retain such information in accordance with this Privacy Policy. This information may include, but is not limited to:
  49. (i) your first and last name, (ii) profile picture, (iii) gender, (iv) age, (v) user ID, (vi) email address, (vii) your country, (viii) your language, (ix) your time zone, (x) the organizations and links on your profile page, (xi) the names and profile pictures of your social networking site “friends” and (xii) other information you have included in your social networking site profile.
  50. Single Sign-On: In some instances, you may log in to our website or Services using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal information with us (such as your name and email address, basic profile information, or list of friends), and to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on our website or Services to your profile page to share with others within your network.
  51. How We May Use Your Information
  52. We may use and retain the information we collect about you and your use of our website or Services for a variety of purposes, including to:
  53. (i) fulfill your purchase, (ii) send you an order confirmation, (iii) send you requested product or service information, (iv) send you product updates, (v) provide customer and technical support, (vi) send you a newsletter and/or marketing communications, (vii) administer contests, surveys and sweepstakes you entered, and to notify contest winners, award prizes, monitor website traffic, and personalize product experience, (viii) analyze usage of our Services, (ix) manage and provide our Services (including our service of advertising), (x) facilitate your communication with other users and buddies, (xi) enable you to post your resume and contact or be contacted by AirFace, (xii) to further develop our Services and other AirFace services and products, and (xiii) to send direct messages to you with informative and/or commercial content about third party products and services AirFace thinks may be of interest to you, such as new features and services, special offers and updated information.
  54. We may use the information you provide about your friends via referral services made available through our Services (such as “Tell A Friend”) for the sole purpose of sending this one-time email and tracking the success of our referral program. If you choose to use such a referral service to tell a friend about our Services, we will automatically send your friend a one-time email inviting him or her to download our Services.
  55. How We May Share and Transfer Your Information
  56. AirFace may share and transfer your information (both inside and outside the country you live in) as described throughout this Privacy Policy and specifically in this section. We may also share your personal information with other third parties if we expressly inform you about such potential disclosure at the point in which you submit the information to us. You have the choice at that time to not allow us to share this information, or to later contact us at privacy@AirFace.com and request that we not share your personal information with such third parties.
  57. Sharing of Non-Personal Information with Third Parties
  58. AirFace may use and disclose to AirFace’s partners and contractors acting on our behalf anonymous, aggregated, and de-identified data for the purpose of analyzing usage of our Services, provision of advertising, and further developing our Services.
  59. Sharing of Personal Information with Third Parties
  60. AirFace may hire agents and contractors to collect and process personal information on AirFace’s behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal information only for the purposes for which the third party has been engaged by AirFace. These agents and contractors may not use your personal information for their own marketing purposes. AirFace may use third party service providers such as credit card processors, email service providers, shipping agents, data analyzers and business intelligence providers. AirFace has the right to share your personal information as necessary for the aforementioned third parties to provide their services for AirFace.
  61. Co-Branding
  62. As part of our Services, AirFace may create co-branded webpages or games along with our third party partners and contractors. In connection with these relationships, AirFace may pass your personal information to these partners and developers in order to offer these co-branded games. Transfers to our partners and developers are covered by our Privacy Policy, our agreements with those partners and developers, and our co-branding partners’ and contractors’ privacy policies.
  63. Although different privacy policies may govern how your personal information is treated for co-branded games, we make reasonable commercial efforts to ensure that all of our third party partners and contractors adhere to the terms and conditions of our Privacy Policy. Additionally, AirFace handles all customers’ inquires (e.g., your customer services requests) and other forms of contact regarding our Services.
  64. Sharing in Public Forums
  65. You may choose to share information about yourself in the course of contributing user-generated content to our Services. Any information that you share in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. AirFace is not responsible for any personal information you choose to make public in any of these forums.
  66. Sharing as Authorized by Law
  67. AirFace may disclose your personal information to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or AirFace to legal liability. We may also disclose your personal information to third parties when AirFace has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with AirFace’s rights, property, operations, users or others who may be harmed or may suffer loss or damage, or AirFace believes that such disclosure is necessary to protect AirFace’s rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on AirFace.
  68. Game Play, Scores, and Progress
  69. AirFace may display your username/handle, progress, rank, achievements, and scores to other players in-game and on our website, to enable you to interact and see progress within our games.
  70. AirFace may store and/or transfer your personal information to its affiliates and partners in and outside of EU/EEA member states and the United States in accordance with mandatory legislation and this Privacy Policy.
  71. AirFace may disclose your personal information to third parties in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of AirFace’s stock and/or assets or other corporate change, including, without limitation, during the course of any due diligence process provided, however, that this Privacy Policy shall continue to govern such personal information. You will be notified via email and/or prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
  72. Communication Preferences
  73. You can manage your communication preferences through the means provided below:
  74. Geo-location Information
  75. When you use a smart phone or other mobile device to access our Services, with your permission we may collect your geo-location information to optimize user experience, such as for localization accuracy, language display, or the provision of relevant advertising. We will only collect such information if (a) “location services” for the mobile application is enabled; and (b) the permissions in the mobile device allow communication of this information. We will only share this information, such as with third party business partners to provide you with relevant location-based advertising, if we first obtain your express affirmative consent to do so. If you do not want us to collect your location information, you may prohibit the sharing of this information at any time by changing the relevant preferences and permissions in your mobile device.
  76. Push Notifications
  77. Upon download of certain Services, you are provided the option to opt in to receiving push notifications from AirFace on your device and within the application. We send you push notifications from time-to-time to (i) inform you of service related messages (e.g., notice that it’s your turn), (ii) communicate messages from buddies and (iii) update you about any events or promotions that we may be running. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. If you no longer wish to receive these types of communications, you may turn them off at the device level. Opting out of push notifications will not affect your settings with respect to email communications.
  78. E-Mails and Other Electronic Communications
  79. E-mails and other electronic communications AirFace sends to you may contain code that enables AirFace to track your usage of the communication, including whether the communication was opened and/or what links were followed (if any). AirFace may combine that information with other information AirFace has about you and AirFace may use that information to improve our Services and/or provide customized communications to you. To stop receiving marketing emails from AirFace, you may follow the unsubscribe instructions included in the communications or contact us at unsubscribe@AirFace.com.
  80. Interest Based Advertising
  81. AirFace may use and disclose to our third party advertising partners certain information collected about you for purposes of serving you interest-based advertising based upon your browsing activities and interests. AirFace may employ third party ad serving technology that uses certain methods such as cookies or similar technologies to collect information as a result of ad serving through our Services. We or such third parties operating the ad serving technology may use demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within our Services. AirFace or such third parties may collect and use non-personal data for this purpose including, but not limited to IP address, UDID, software, applications, hardware, browser information, internet and on-line usage information and in-game information. The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology.
  82. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here, or if located in the European Union, by clicking here. Please note this does not opt you out of being served ads entirely. You will continue to receive generic ads that are not based on your preferences. Please note that the advertising companies who deliver ads for AirFace may combine the information collected in connection with our Services with other information they may have independently collected from other services or products. Although AirFace makes commercially reasonable efforts to oblige such advertising companies to comply with the terms and conditions of our Privacy Policy, any such independent action is done in accordance with the privacy policy of the company providing the advertisements.
  83. Your Interactions With Third Parties Independent Of Our Services
  84. As otherwise noted in this Privacy Policy, your access to and use of our Services may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking site services and payment providers. You recognize and agree that AirFace is not liable for any such third party terms and conditions and/or their use of your information.
  85. AirFace may in its discretion make available links through advertisements or otherwise enable you to access third party products or services through our website or Services. Please note that, while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by AirFace. We are not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that AirFace is linking to those products or services does not constitute our sponsorship of, or affiliation with, those people or companies. If you submit personal information to any third party website, your information is governed by their privacy policies, which may differ from this Privacy Policy. The foregoing data may be used and disclosed in accordance the privacy policy of the third party offering their services. We encourage you to carefully read the privacy statement of any website or service you visit.
  86. Information Accuracy, Access, and Deletion
  87. AirFace does not verify the correctness of your personal information and the accuracy of such information is solely the responsibility of you, the user. However, AirFace makes good faith efforts to enable you to update, confirm, or delete (or otherwise de-identify) your personal information in AirFace’s possession.
  88. Upon request, AirFace will provide you with information about whether we hold any of your personal information. You may access, correct or request deletion of your personal information by:
  89. * opening a help ticket directly in-game via the Help section;
  90. * emailing AirFace at privacy@OKULARION.com;
  91. * contacting us via our physical address as provided below.
  92. AirFace will need sufficient information from you establishing your identity in order for us to fulfill your request. We will ensure that your request is processed and respond to any such request within a reasonable timeframe. In some cases, we may not be able to remove your personal information, in which case we will notify you via email if we are unable to do so and why.
  93. Security Safeguards
  94. The security of your personal information is very important to us. AirFace follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information in AirFace’s possession. Some of the safeguards we use to prevent unauthorized on-line access to your personal information are firewalls and data encryption. Only those persons with a need to process your personal information in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance have access to your personal information in AirFace’s possession.
  95. Personal information collected by AirFace is stored in secure operating environments that are not available to the public. However, no system can be 100% secure and there is the possibility that despite AirFace’s reasonable efforts, there could be unauthorized access to your personal information. By using our Services, you assume this risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem through the contact information listed below.
  96. Data Retention
  97. AirFace will only retain your personal information, or information you provide about your friends, for so long as is necessary to fulfill the purposes for which it was collected, as set out in this Privacy Policy. If you do provide us with personal information, we generally retain it as long as your account is active or as is otherwise necessary to provide the Services and operate our business (including for purposes like complying with our legal obligations, managing internal books and records, preventing fraud, resolving disputes, enforcing our contracts and terms, and operation of our website or Services. AirFace does not store your friend’s name or contact information when you provide it through our Referral Services.
  98. Use by Minors
  99. If you are under the age of 18, you must have your parent’s permission to access the site and our games. If you are under the age of 13, you are not permitted to access the site, use any of our services, or play any of our games. This site and all AirFace games are not intended for children under the age of 13 and we do not knowingly market to or collect, use or disclose information from children under the age of 13. If AirFace learns that AirFace has inadvertently gathered personal information from children under such age, AirFace will promptly erase such personal information from AirFace’s records.
  100. Privacy Questions and Complaints
  101. AirFace regularly reviews its compliance with this Privacy Policy. If AirFace receives a formal written complaint from you, it is AirFace’s policy to attempt to contact you directly to address any of your concerns. AirFace will cooperate with the appropriate governmental authorities, including data protection authorities, to resolve any complaints regarding the collection, use, transfer or disclosure of personal information that cannot be amicably resolved between you and AirFace.
  102. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge).
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